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Methylene Chloride & Dichloromethane

In April 2024, the Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride (CAS# 75-09-2, also identified as dichloromethane or DCM) under the Toxic Substances Control Act (TSCA). University research operations are impacted, and Environmental Health and Safety (EHS) is tasked with ensuring compliance with this new rule.  

Key Changes to Existing Regulations 

The TSCA methylene chloride rule prohibits most consumer and commercial uses of methylene chloride. The rule will allow 13 conditions of use to continue, including use as a laboratory chemical with strict new requirements including:  

  • Documentation of attempts to eliminate or substitute methylene chloride.  
  • Documentation of all control measures, including those not implemented. 
  • Initial and periodic exposure monitoring for anyone potentially exposed, including recordkeeping and dissemination of monitoring data. 
  • Development and implementation of a Workplace Chemical Protection Program. 
  • Recordkeeping to maintain an auditable paper trail of these measures. 

University of Florida Program Requirements 

Program requirements are described in the University’s Worker Chemical Protection Program

  1. All current and future use or storage of methylene chloride must be reviewed and approved by EH&S.
  2. All laboratories are required to complete the short survey 5-Question Survey 
  3. Laboratories with no plans for current or future use have fulfilled their compliance obligations. 
  4. Laboratories wishing to move away from methylene chloride use must dispose of current stocks through Hazardous Waste Management by requesting a Hazardous Waste Pick-up – UF | EHS. 
  5. Laboratories that store, use, or plan to use methylene chloride will be contacted by EH&S to coordinate further actions for compliance. At minimum each lab is responsible for the following: 
    • Exposure Monitoring –
      • Must be conducted every 5 years for all labs using or storing DCM.
      • Must be conducted quarterly or annually for laboratories that approach or exceed EPA exposure limits.
      • EH&S will assume the cost of the initial monitoring. All future monitoring will be borne by the laboratory or department. 
    • Regulated Areas – if exposure limits are reasonably expected to be exceeded.  
    • Exposure Control Plan – must describe consideration or implementation of the following: 
      • Elimination of DCM 
      • Substitution of DCM 
      • Engineering Controls 
      • Administrative Controls
      • Personal Protective Equipment 
    • Training Prior to Job Assignment
    • Recordkeeping 

Resources

Templates