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Complying with EPA rule on Methylene Chloride

In its latest action to protect worker health, the United States Environmental Protection Agency (EPA) using the Toxic Substance Control Act (TSCA) framework is prohibiting most consumer and commercial use of Methylene Chloride. University research and operations are impacted by this rule. EPA has allowed certain exempt conditions, including laboratory research but with strict monitoring and exposure requirements.

In accordance with EPA TSCA Final Rule of May 8, 2024, entities like UTA are required to develop a Workplace Chemical Protection Program (WCPP) no later than October 2025. In addition, those entities would be required to periodically monitor their workplace to ensure that workers are not exposed to levels of methylene chloride that would lead to an unreasonable risk.

The timeline for compliance is below:

• May 5, 2025: Complete initial exposure monitoring.
• August 1, 2025: Implement controls.
•    – Or 3 months after initial monitoring.
• October 30, 2025: Develop and implement Exposure Control Plan.
• Additional mandated timeframes will depend on initial monitoring results.

 What Steps is EH&S taking?

September 2024: The UTA Environmental Health & Safety (EH&S) has initiated plans to prepare the university towards compliance and will be working directly with affected research laboratories and operational units. So far, about 200 containers of methylene chloride, also known as Dichloromethane (DCM) and mixtures thereof have been identified in the online chemical inventory system (CEMS). Affected units will be contacted by an EH&S team member to review options. 

How about an alternative to Methylene Chloride?

Yes, but plans to substitute methylene chloride with another chemical should be shared with EH&S for evaluation because certain substitutes may be currently evaluated under the new TSCA process. See EPA Designation of Ten Chemical Substances for Initial Risk Evaluations Under the Toxic Substances Control Act.

More information on the rule and EPA actions to manage risks from Methylene Chloride is available on the EPA website at https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-methylene-chloride.

If you have any questions or concerns, contact Environmental Health & Safety at 817-272-2185 or ehsafety@uta.edu.