University of Kentucky research Laboratories with active storage or use of methylene chloride (a.k.a. dichloromethane), or products with this chemicals as a constituent, are asked to review the following information:
You may already be aware that on April 30, 2024, the U.S. Environmental Protection Agency finalized a ban on most uses of methylene chloride, a dangerous chemical known to cause liver cancer, lung cancer, breast cancer, brain cancer, cancer of the blood, and cancer of the central nervous system, as well as neurotoxicity, liver harm and even death. The EPA’s final action has also established a Workplace Chemical Protection Program for those still working within the scope of allowable use. This Workplace Chemical Protection Program has strict exposure limits, monitoring requirements, and worker training and notification requirements that will protect workers from cancer and other adverse health effects caused by methylene chloride exposure.
Uses that will continue under the Workplace Chemical Protection Program are highly industrialized and important to national security and the economy. These are uses for which EPA received data and other information that shows workplace safety measures to fully address the unreasonable risk could be achieved. These uses include:
1. Use in the production of other chemicals, including refrigerant chemicals that are important in efforts to phase down climate-damaging hydrofluorocarbons under the bipartisan American Innovation and Manufacturing Act.2. Production of battery separators for electric vehicles.3. Use as a processing aid in a closed system.4. Use as a laboratory chemical.5. Use in plastic and rubber manufacturing, including polycarbonate production.6. Use in solvent welding.
For uses of methylene chloride continuing under the Workplace Chemical Protection Program, most workplaces will have 18 months after the finalization of the risk management rule to comply with the Workplace Chemical Protection Program and will be required to periodically monitor their workplace to ensure that workers are not being exposed to levels of methylene chloride that would lead to an unreasonable risk. Please see the following link for full policy verbiage: Final Risk Management Rule for Methylene Chloride.
1. Ensure the lab's chemical inventory is up to date and accurate in terms of the amounts of this chemical on site. It is to your advantage to ticket for waste any methylene chloride or products with methylene chloride as a constituent that are no longer in use.
2. Ensure the lab's Chemical Hygiene Plan (CHP) contains established documented standard operating procedures (SOP) for the use of this chemical. As a reminder, lab-specific CHP and documented SOP for utilization of hazardous chemicals is a requirement under the OSHA Laboratory Standard (29 CFR 1910.1450). If the lab does not already have an SOP in place, a fillable template for this purpose can be accessed HERE, using UK Linkblue username and password. SOPs must be submitted to the Department of Research Safety (labsafety@uky.edu)for the continued use of this chemical. Once this is completed, UK OHS will contact the PI/Lab Supervisor on record to arrange for the required exposure assessment.
3. Ensure personnel have been documented as trained on methylene chloride's safe use. An online training module for this purpose is available for use within the SciShield Sytem.
4. The Chemical Safety office will follow up with the lab after the results from the exposure assessment are received to ensure finalized copies of the lab's SOP and Exposure Control Plan are received by the PI/Lab Manager and maintained in the lab's specific Chemical Hygiene Plan.
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