Methylene Chloride (DCM)
CAS 75-09-2
Methylene Chloride (DCM) Bulletin
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.
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
The Environmental Protection Agency (EPA) has finalized regulations governing the use, handling, and storage of methylene chloride (DCM), effective July 8, 2024. The Office of Environmental Health and Safety (EHS) provides comprehensive guidance below to ensure full compliance and campus safety.
- 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.
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