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Environmental Health & Safety

Laboratory Safety

Methlyene Chloride Use at the University of Rochester


On July 8, 2024, the EPA issued a new federal standard regarding Methylene Chloride (Dichloromethane; CAS# 75-09-2) under the Toxic Substances Control Act (TSCA). The University will be required to comply with the EPA Risk Management Rule regarding Methylene Chloride. The EPA has issued this federal standard regarding the use of Methylene Chloride with a series of deadlines that must be met starting May 5, 2025. These requirements supersede the current OSHA standard, and will affect all Students, Faculty, and Staff. There is no research exemption. This ruling lowers the respective 15-minute Short Term Exposure Limit (STEL), the 8-hour Permissible Exposure Limit (PEL), and Action Limits severely:

 

15 Minute STEL

8 Hr PEL

Action Limit

OSHA

125 ppm

25 ppm

12.5ppm (8 Hr)

EPA TSCA Ruling

16 ppm

2 ppm

1 ppm

Therefore, the use of Methylene Chloride will be restricted to areas and tasks that have been formally evaluated by EH&S are able to meet the EPA requirements.

There are several new requirements that will have to be met with this new ruling:

  1. Chemical monitoring must be performed and recorded by EH&S for all tasks identified, even tasks performed within a chemical fume hood. Similar Exposure Groups (SEGs) can be used for similar tasks.
  2. Initial monitoring must be completed by May 5, 2025.
  3. Repeat monitoring may be needed depending on the exposure. All tasks must be re-monitored every 5 years at a minimum.
  4. A Workplace Chemical Protection Program (WCPP) must be established. (This will be written and held by EH&S)
  5. Specific Personal Protective Equipment must be used - no nitrile gloves; only Polyvinyl Alcohol (PVA) or poly-laminate are acceptable.

For those who cannot find suitable solvent alternatives, all future use of methylene chloride will have to meet the following requirements:

  1. Each task must be documented with a formal assessment by EH&S.
  2. ALL manipulations and handling must be performed within a chemical fume hood.
  3. EH&S must perform chemical exposure monitoring for all tasks or similar exposure groups.
  4. All exposures MUST be below the newly established EPA TSCA limits for all tasks.
  5. Additional training is required (MyPath Course) for all laboratories that continue to store or use Methylene Chloride.
  6. Labs are required to supply PVA or poly-laminate gloves for all users.

The compliance timeline dictated by the EPA is currently:

  • May 5, 2025 - Initial chemical monitoring completed of all tasks
  • August 1, 2025 - Exposure Limits and Dermal Protections in place
  • October 30, 2025 - Exposure Control Plan Documented

EH&S is currently in the process of creating a Methylene Chloride Policy, a corresponding training module in MyPath, and the University's Workplace Protection Plan.

Please see the EPA's Compliance Guidance document for more information.

If you have any additional questions, please reach out to your EH&S Safety Specialist, call us at (585) 275-3241, or email us at questions@safety.rochester.edu.


QUESTIONS or COMMENTS?
Contact EH&S at (585) 275-3241 or e-mail EH&S Questions.

This page last updated 2/28/2025. Disclaimer.