EPA Releases Compliance Guide for Recent Methylene Chloride Rule
A guide published recently by EPA is intended to help industry understand and comply with the agency’s new risk management rule for methylene chloride, which went into effect on July 8. The rule bans the manufacturing, processing, and distribution of methylene chloride for all consumer uses by July 2025 and most industrial and commercial uses within two years. Certain uses of methylene chloride are allowed to continue under the new rule, including its uses in the production of battery separators for electric vehicles, as a laboratory chemical, as a bonding agent for solvent welding, and some other specific uses that EPA describes as “highly industrialized and important to national security and the economy.” Such uses will continue with strict workplace controls, which are outlined in the new compliance guide.
One of the components of the rule described in EPA’s guide is the workplace chemical protection program, which is intended to help protect workers who are potentially exposed to methylene chloride during allowed uses. Provisions of the program include inhalation exposure limits, exposure monitoring, an exposure control plan, criteria for respirator selection, and other requirements. EPA’s exposure limits for methylene chloride include an EPA existing chemical exposure limit (ECEL), an EPA short term exposure limit (STEL), and an ECEL action level.
“The ECEL and EPA STEL identify the levels at or below which a potentially exposed person will be protected against unreasonable risk,” the compliance guide states. “The ECEL and EPA STEL are similar to the OSHA permissible exposure limit and STEL in that they are regulatory exposure limits, although OSHA PELs do not protect against unreasonable risk as defined under [the Toxic Substances Control Act].”
The EPA ECEL for methylene chloride is 2 ppm (8 mg/m3) as an eight-hour time-weighted average (TWA), and the EPA STEL is 16 ppm (57 mg/m3) as a 15-minute TWA. The ECEL action level, which the agency describes as a “trigger that indicates whether certain compliance activities (e.g., periodic monitoring) are required,” is 1 ppm (4 mg/m3) as an eight-hour TWA.
Additional topics discussed in the guide include compliance timeframes and requirements for recordkeeping and downstream notification to inform processors, distributors, and others about the restrictions on methylene chloride under TSCA.
The compliance guide is available as a PDF from the EPA website. The methylene chloride rule was published in the Federal Register in May. For more information, see the agency’s risk management page for methylene chloride.