DCM Usage Compliance

In April 2024, the Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride (commonly referred to as DCM) under the Toxic Substances Control Act (TSCA).

  • Research operations are covered by the rule.
  • BU Environmental Health and Safety (EHS) will be working with the research staff that use this chemical, in order to comply with this new rule.

Under the Final Rule, these key changes were made:

The TSCA methylene chloride rule prohibits most consumer and commercial uses of methylene chloride. The rule will allow 13 conditions of use to continue, including use as a laboratory chemical with strict new requirements including:

  • Documentation of attempts to eliminate or substitute methylene chloride.
  • Documentation of all control measures, including those not implemented.
  • Initial and periodic exposure monitoring for anyone potentially exposed, including record keeping and dissemination of monitoring data.
  • Development and implementation of a Workplace Chemical Protection Program.
  • Record keeping to maintain an auditable paper trail of these measures.

Also under the Final Rule, the following timeline was established. These requirements are mandated and include the following:

  • May 5, 2025: Complete initial exposure monitoring.
  • August 1, 2025, or three months after monitoring: Implement controls.
  • October 30, 2025: Develop and implement an Exposure Control Plan.

BU EHS Compliance

As required by this federal regulation, BU EHS is working on developing a program to track and monitor laboratory staff who work with or are potentially exposed to methylene chloride (DCM).

  • Step 1 – EHS requested that all laboratories review their chemical inventories and update, to determine if methylene chloride is present in their laboratories.
    • Target Audience – all laboratories
    • Due Date – December 2, 2025
  • Step 2 – EHS submitted a program update to all laboratories with methylene chloride in their ChemTracker inventory. The program update included the following three options for laboratories with methylene chloride in their chemical inventories:
    1. Remove and dispose of their inventory of methylene chloride. Instructions for SciShield pickup and disposal are linked here.
    2. Laboratories that require a chlorinated solvent for their research but wish to substitute for alternative chemical will be directed to the BU Chemical Safety Officer, Dawn Hengl (dhengl@bu.edu). Resources for selection of alternative solvents are included in our DCM Additional Resources section below.
    3. Laboratories participating in the personal monitoring program should complete this questionnaire, regarding the processes where methylene chloride is used. Laboratories will need to comply with EHS personal monitoring requirements.

As previously reported, laboratories who want to continue using methylene chloride must work with EHS to join the DCM monitoring program by March 31, 2025.  After April 1, 2025, any methylene chloride discovered in a laboratory that is not part of the DCM monitoring program must be discarded.

Please feel free to reach out to your EHS safety specialist or our Chemical Hygiene Office, Brendan Phelan (bnphelan@bu.edu) with any questions.

 

DCM Additional Resources :