Are You Prepared for the EPA's Methylene Chloride Ban?

Industries across the board are facing a major federal ban on the widely used solvent methylene chloride. This could cause them operational disruptions, lost time and effort, and noncompliance. Planning for compliance now, as the full details of the ban trickle out, will allow operations to weather any regulatory storm.

Methylene chloride, commonly known as dichloromethane (DCM), is a widely-used chemical across industries. Studies have repeatedly shown negative health effects associated with its use, however, leading many environmental, health, and safety (EHS) industry professionals to wonder why it has yet to be banned. As of yet, the substance’s wide array of uses and many important benefits seem to have outweighed its bad effects.

The tide appears to be turning, however: The Environmental Protection Agency (EPA) has finally announced a ban on the solvent. This ban will ripple out to the wider community, being felt by organizations nationwide, and cause EHS compliance impacts for all.

Organizations that fail to implement the terms of the ban in a timely manner risk safety and noncompliance—which may mean citations, fines, and lost time, money, and effort in the struggle to play regulatory catch-up.

Variety of Common DCM Uses

Methylene chloride has a chemical composition that makes it a powerful and effective compound. Its many uses include, but are not limited to:

• Degreasing
• Paint removal
• Adhesives

Its powerful properties make it a very commonly-used laboratory solvent, especially in pharmaceutical and university labs. In these settings, scientists favor DCM because it is a polar aprotic solvent with a low boiling point—making it ideal for extraction, synthesis, and purification processes.

Long History of Negative Methylene Chloride Impacts

Methylene chloride exposure most commonly occurs through inhalation or skin absorption. Without adequate personal protective equipment (PPE), training, and biosafety precautions, this could mean immense suffering.

Even with all the correct safety measures in place, accidents can still happen—leaving lab staff exposed to risk. In some labs, the repeated use of DCM in operations makes it almost inevitable that workers are harmed.

Studies have repeatedly shown that methylene chloride use has both acute and chronic effects on those who directly interact with it—but the substance can impact anyone even simply passing through the general area in which the chemical is being used. These adverse effects can mean damage to the central nervous system, heart, and liver. On top of this, DCM exposure increases the risk of cancer in users and consumers.

Road to a Federal Ban

Given these risks and because of how common these chemicals are, an EPA DCM ban has been a long time coming. In 2020, the EPA conducted a risk evaluation in accordance with the Toxic Substance Control Act (TSCA).

In 2022, the final risk evaluation was released—announcing that the administration found unreasonable risk of injury to human health. On May 8, 2024, the EPA issued the Methylene Chloride Regulation under TSCA, and on July 8, 2024, the Final Rule on the Regulation of Methylene Chloride, also known as the Methylene Chloride Rule, went into effect.

The EPA has set a target date of May 8, 2029, five years after publication of the final rule, to transition to full compliance. Over the next few years, organizations across industries must phase out their use of DCM. This will involve:

• Close review of the Methylene Chloride Rule and strict adherence to its guidelines
• Solvent disposal that is safe for both workers and the environment
• Finding new processes, with chemical alternatives, that can replicate methylene chloride’s effects
• Establishing safe storage areas to hold DCM containers slated for disposal

Will the DCM Ban Impact You?

Any organization that creates, uses, or disposes of DCM must prepare for compliance in all of their facilities. Although incomplete, the above compliance checklist will be difficult for managers to tick down without wide organizational commitment and resources. To assist with the transition to ban compliance, the EPA has created a Workplace Chemical Protection Program (WCPP) to mitigate the various risks organizations face while storing, handling, and disposing of methylene chloride. The WCPP will include requirements for:

• Occupational Exposure Limits (OELs)
• Monitoring parameters
• Exposure Control Plans (ECPs)
• Identification of regulated areas
• Respiratory protection and PPE
• Training
• Recordkeeping

By early May 2029, the use of methylene chloride across various industries will be prohibited. The precise deadlines for regulatory compliance may vary slightly from organization to organization, based on the condition of DCM use. Ultimately, however, all affected organizations must comply.

Various timelines for different classes of methylene chloride users can be found in the EPA’s “A Guide to Complying with the 2024 Methylene Chloride Regulation Under the Toxic Substances Control Act (TSCA),” but this document can be long and complex.

There are also some ban exemptions, outlined in TSCA 40 CFR 751.10. In short, the exemption applies to organizations that use amounts of methylene chloride under the de minimis threshold of 0.1% by weight.

Partnering for Methylene Chloride Ban Compliance Success

With widespread implications, various exemptions, long and complex guidance documents, and the demand for innovative solutions to replacing worksite DCM, it will be hard even for managers with robust EHS and chemical inventory management and related resources to comply.

If you’re unsure of how to comply with the Final Rule on the Regulation of Methylene Chloride, contact Triumvirate Environmental today. Our dedicated team can help to implement the WCPP in your workplace, advise you on best practices and industry changes, and ultimately keep you and your team safe and compliant.