Methylene Chloride (DCM)

CAS 75-09-2

Introduction to EPA Methylene Chloride Final Rule - K-State EHS Presentation

The Environmental Protection Agency (EPA) recently finalized new regulations governing methylene chloride (DCM), effective July 8, 2024. These regulations introduce requirements for the use, handling, and inventory management of DCM to protect our campus community. The Office of Environmental Health and Safety (EHS) has conducted comprehensive research, benchmarked policies against peer and aspirational institutions, and reviewed best practices and compliance strategies.

As a result, EHS has developed guidelines to ensure efficient and effective compliance with these new regulatory standards. We strongly urge departments and laboratories to prioritize eliminating or substituting DCM with safer alternatives. Proactively removing or replacing DCM significantly reduces hazards to personnel, streamlines regulatory compliance processes, and minimizes associated financial burdens. Departments opting to continue using DCM may incur additional costs related to compliance, including exposure monitoring requirements, specialized personal protective equipment (PPE), mandatory training sessions, comprehensive recordkeeping, and heightened regulatory oversight. The Green Chemistry Teaching and Learning Community has highlighted substitutes for DCM for consideration: Methylene Chloride (DCM) Replacements.

EPA-Identified Product Categories Involving Methylene Chloride

According to the EPA's 2022 Revised Risk Determination, methylene chloride is associated with the following product categories. These categories may represent a wide variety of current and historical uses across campus. We need individuals across all campus departments and functions to be vigilant in taking comprehensive inventories to identify products containing methylene chloride (DCM) CAS 75-09-2, which may appear as a pure substance or as a component of a mixture/product.

Industrial and Commercial Uses

Solvent in batch and in-line vapor degreasing

Cold cleaning operations

Aerosol spray degreasers and cleaners

Adhesives, sealants, and caulks

Paints, coatings, and their removers

Metal degreasers (aerosol and non-aerosol)

Finishing products for fabrics, textiles, and leather

Automotive care products (e.g., air conditioner fluids, interior cleaners, degreasers)

Apparel and footwear care products

Spot removers for textiles

Lubricants and greases (liquid and spray)

Cold pipe insulation

Solvent in formulations or mixtures

Processing aid in manufacturing

Propellant and blowing agent

Electrical equipment, appliance, and component manufacturing

Plastic and rubber product manufacturing

Cellulose triacetate film production

Anti-spatter welding aerosols

Oil and gas drilling, extraction, and support activities

Toys, playground, and sporting equipment

Lithographic printing plate cleaners

Carbon removers, wood floor cleaners, and brush cleaners

Laboratory chemicals

Consumer Uses

Solvent in aerosol degreasers and cleaners

Adhesives and sealants

Brush cleaners for paints and coatings

Methylene Chloride (DCM) Regulation

Key Provisions of the EPA Rule

Consumer Use Ban: All consumer uses of DCM are prohibited.

Industrial and Commercial Restrictions: Most industrial and commercial uses, including paint and coating removers, are banned.

Workplace Chemical Protection Program (WCPP): For remaining critical uses, such as laboratory research, DCM use is permitted under strict safety protocols, including:

- Exposure monitoring.

- Use of air-supplied full-face respirators.

- Skin (dermal) protection.

- Recordkeeping.

- Training.

- Development of an exposure control plan.

Kansas State University Compliance Requirements

1. Inventory Assessment

Deadline: June 30, 2025
Requirements: Departments must report current storage locations and quantities of DCM to EHS. Refer to the EPA-Identified Product Categories Involving Methylene Chloride dropdown on this website to visualize identified products that may contain DCM.
Actions:
- Complete Methylene Chloride Inventories Survey
- After completing the survey, submit a Waste Pickup Request with EHS if you wish to discontinue use or storage of DCM

2. Procurement Approval

Immediate Action: All future DCM purchases require prior approval from EHS.
Action: Submit purchase requests to safety@ksu.edu.

3. Exposure Monitoring and Limits

EPA Proposed Deadline: November 9, 2026
Responsibility: Cost of monitoring supplies and compliance with monitoring requirements will be the responsibility of the laboratory, facility, or department.
Action: EHS will conduct monitoring in collaboration with PIs/Lab Managers/Responsible Individuals for each space reporting DCM use.
Frequency based on initial monitoring:
- Below ECEL action level: Every 5 years
- Equal or above ECEL action level: Every 6 months
- Above ECEL or STEL limits: Every 3 months
Exposure Limits:
- Existing Chemical Exposure Limit (ECEL): 2 ppm (8-hour TWA)
- Short-Term Exposure Limit (STEL): 16 ppm (15-minute period)

4. Mandatory Training

Start Date: July 2025
Attendees: All personnel working in areas where DCM is used or stored.
Content: Handling protocols, safety measures, PPE use, emergency response, exposure control procedures, requirements under the EPA regulation.
Frequency: Initial training must be completed prior to handling or use of Methylene Chloride. Refresher training will be offered for those who retain Methylene Chloride.

5. Workplace Chemical Protection Program (WCPP)

Deadline: May 10, 2027

Components:

- Exposure Control Plan (ECP) that includes:
  - Identification and rationale of exposure controls
  - Procedures for implementing exposure controls (installation, inspection, training)
  - Regulated areas and activities
  - Procedures for updates and responding to changes
  - Performance standards for evaluation of controls
  - Monitoring strategies and documentation
  - Comprehensive communication plan
  - Detailed recordkeeping

Action: All locations that retain Methylene Chloride must have a site-specific WCPP. A template has been created that may be used to create a plan for all university locations, including laboratories, maintenance areas, workshops, and storage facilities, that store, use, handle, or dispose of methylene chloride.

6. Personal Protective Equipment (PPE)

Respiratory Protection (Where exposure limits are exceeded):
- Deadline: February 8, 2027
- Required Equipment: Supplied-air respirators (airline or SCBA only)
- Requirements: Enrollment in the KSU Respiratory Protection Program, medical evaluation, fit testing, user training

Glove Protection:

- Deadline: February 8, 2027
- Approved: Polyvinyl alcohol, Silver Shield®, Laminate gloves
- Not Approved: Nitrile, Latex, Neoprene, Polyethylene gloves

7. Regulated Area Demarcation

Deadline: August 1, 2025
Requirements:
- Clearly marked areas where exposure limits could exceed defined thresholds
- Access control measures
- Required training and detailed recordkeeping of access