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Methylene Chloride
EPA Regulations on Dichloromethane (DCM): Compliance Guidelines for Sac State
Methylene Chloride Rule
In May 2024, the U.S. Environmental Protection Agency (EPA) issued a final rule under the Toxic Substances Control Act (TSCA) Section 6(a), significantly restricting the use of Methylene Chloride, also known as Dichloromethane (DCM) or Methane Dichloride, due to its health risks, including cancer, liver toxicity and neurotoxicity. Exposure to DCM can occur from inhalation and skin absorption.
DCM is now banned in most consumer products and is restricted in many industrial and commercial applications. Only specifically allowed uses, such as use as a laboratory chemical, will continue to be permitted. However, the new rule creates additional documentation, record keeping and air monitoring requirements that users will need to comply with in order to continue using Methylene Chloride as a laboratory chemical. In addition, the exposure threshold is lowered to 2 ppm, well below the current OSHA PEL of 25 ppm.
Health risks associated with DCM
Carcinogenicity: DCM is listed under California Proposition 65 as a chemical known to cause cancer.
Acute and Chronic Effects: Exposure can lead to short term effects such as dizziness and nausea, with long term effects of potential of liver and kidney damage, and in severe cases, death.
Compliance requirements for Sac State DCM Users
- Initial Air Monitoring: Initial air monitoring will need to be conducted prior to use of DCM to quantify the potential exposure to users. Applicable costs of monitoring supplies and analysis through an accredited laboratory will rest with the Responsible Party of the chemical use. Sampling needs to be conducted under the supervision of a Certified Industrial Hygienist (CIH) and copies of sampling results need to be sent to Sacramento State Environmental Health and Safety (EHS) for regulatory documentation and recordkeeping. Sacramento State EH&S is available to assist in sample collection, providing labor, CIH services, and result analysis, free of charge to campus users, however the cost of sampling materials and sample analysis will be the responsibility of the Responsible Party. Results will be provided to affected employees within 15 days after EHS receives the sample analysis report and will be kept for a minimum of 30 years.
- Training: In addition to Laboratory Chemical Safety Training, SOP Review and documentation, and lab specific training, additional Methylene Chloride training must be given and documented for laboratory personnel in groups who have Methylene Chloride.
- Continuous Periodic Monitoring: Periodic monitoring will be conducted as directed by the rule, including when work practices are changed in the laboratory or upon introduction of new processes.
- Engineering Controls and Work Practices:If air monitoring results indicate that Methylene Chloride levels exceed the regulatory threshold, EHS will work with groups to identify and implement exposure reduction techniques including but not limited to engineering controls, administrative controls, and PPE selection. This could include ventilation systems, process enclosure, or equipment modifications. Changes in work practices may also be required to minimize exposure, such as limiting the time employees spend in high-exposure areas or altering the way tasks are performed.
- Personal Protective Equipment (PPE):Regardless of exposure levels, PPE must be worn as required when working with hazardous materials including Methylene Chloride. If exposure monitoring indicates that respiratory protection is required, EHS will consult with end users to determine how to utilize elimination, substitution, or engineering controls to reduce exposure to below the regulated exposure limits.
Frequently Asked Questions
Frequently Asked Questions
Most uses are being phased out unless they meet specific critical exemptions (e.g. in research or certain manufacturing processes). Continued use requires approval from EH&S and must follow strict safety protocols, including exposure monitoring and worker protection programs.
DCM-containing products refer to household or commercial products that contain DCM or have a percentage of DCM in their ingredients. Below is a common list of items that are known to contain DCM. This list is not all inclusive and specific items in your inventory should be checked for DCM.
- Paint stripper
- Adhesive, tape, or tacky remover
- Surface preparation cleaner for painting/gluing
- Epoxy dissolver
- Caulk/sealant remover
- Tile remover
- Choke and valve cleaner
- Wallpaper and/or carpet glue remover
- Mold-release agents
- Foam dissolver
- Paint brush cleaner
- Carburetor cleaner
- Spray equipment cleaner
- Contact cement – particularly older spray contact cement
Check the products Safety Data Sheet (SDS) and label for:
- Chemical name: Methylene chloride or dichloromethane
- CAS number: 75-09-2
If unsure after evaluation of the chemical data, please contact EH&S to discuss.
Yes. DCM waste will continue to be disposed of adhering to the existing rules for hazardous chemical waste disposal. The primary difference between this and other upcoming EPA regulations is that users should not fill or pour chlorinated organic waste in the open laboratory or workshop but rather only under ventilation (such as in a fume hood).
Halogenated/chlorinated waste containers must be kept capped at all times when stored outside of ventilated space. These apply unless and/or until exposure monitoring determines whether overexposure may occur with these activities.
There are many ways to reduce exposure to chemicals in the workplace. These include:
- Elimination- Complete removal of the material in question.
- Substitution- Substitute the material in question for one of lower risk/hazard. Please consult EH&S for an evaluation of appropriate substitutes.
- Engineering controls- Utilizing proper ventilation systems, including conducting work within a chemical fume hood, has been shown to greatly reduce the potential for exposure
- Administrative controls: Implement work practices that reduce the quantity of DCM used, the duration of exposure, and/or the frequency of use if possible.
- Personal Protective Equipment (PPE)- Seen as the final line of defense. Utilizing respiratory protection, laboratory attire, chemical resistant gloves, safety eyewear, etc.
The American Chemical Society (ACS) has several tools available for identifying substitutes on their Tools for Innovation in Chemistry page. Additionally, the Environmental Protection Agency (EPA) has a list of common substitutes for general applications listed below. Please be aware that some substitutes may introduce different hazards, such as flammability.
- D-Limonene
- Propylene Carbonate
- Acetone
Exposure monitoring measures a person's exposure to airborne chemicals during use. There are several different methods for conducting exposure monitoring, and the method selected will be based on the specific use scenario.
Examples may include:
- Use of industrial hygiene sampling pumps connected in a sampling train to appropriate collection media, and analyzed for concentration of the chemical in question by an accredited third-party laboratory.
- Use of direct reading equipment to identify real-time concentrations of chemical in the occupational environment.
Please contact the Industrial Hygiene team in EH&S for specific questions.
Yes, the Environmental Protection Agency (EPA) has stated that while a properly working fume hood should be sufficient to control methylene chloride exposures, exposure monitoring is needed to demonstrate the protection provided
Violations can lead to regulatory fines, revocation of laboratory access, and institutional liability. Sac State is committed to full compliance with EPA regulations.
Resources and Contacts
If you have any additional questions or concerns, please reach out to EH&S at (916) 278-2020