Methylene Chloride
Methylene Chloride Workplace Chemical Protection Program (WCPP)
Laboratories and other research areas that use methylene chloride must do so in compliance with the U-M Workplace Chemical Protection Plan (WCPP).
Laboratories and other research units are required to evaluate options for eliminating methylene chloride from their operations or substitute it with a less hazardous alternative. Units that continue use of methylene chloride must be granted approval by EHS, implement all components of the U-M WCPP, and maintain personal exposures below the EPA exposure limits.
Appendix A: Operation Specific Exposure Control Plan (ECP)
Appendix A: Operation Specific Exposure Control Plan documents actions taken to mitigate occupational exposures and comply with the WCPP. This includes information regarding the operation involving methylene chloride, the control methods in place, and for control measures not selected, the rationale for why they cannot be implemented.
Supervisors, or a competent representative must complete Appendix A for any operation involving methylene chloride. Multiple operations by one user group may be listed under a single ECP, only if the controls implemented for the operations are the same. Multiple ECP forms may be required if the operations involve substantially different control measures.
Completed ECP forms must be submitted to EHS and a local copy should be stored with the group’s Chemical Hygiene Plan Documentation.
Regulation of Methylene Chloride (Dichloromethane) under TSCA
In May 2024, the US Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride (also known as DCM or Dichloromethane) under the Toxic Substances Control Act (TSCA). The regulation prohibits most industrial and commercial uses of methylene chloride and creates strict workplace protections for 13 conditions of use that are permitted under the new rule.
Detailed information about the EPA ruling, including the full text of the regulation, is available on the EPA website.
Implementation Timeline
December 2024: Initial publication of the WCPP and ECP
January 2025 – April 2025: Initial exposure assessment and personal exposure monitoring
Action items: All laboratories, shops, and studios should review their chemical storage areas to ensure an accurate inventory record of all methylene chloride and methylene chloride containing (≥0.1%) mixtures. Old, surplus, and unneeded inventory of methylene chloride should be sent for disposal via EHS and removed from the MISP inventory.
Units that plan to continue to use of methylene chloride:
- Evaluate options to eliminate or substitute for a safer alternative.
- Review current procedures and identify potential sources of high exposure. Implement controls to minimize exposures wherever possible.
- Complete the initial survey to briefly describe your intended operations
EHS representatives will contact units that have reported they intend to continue to use methylene chloride or have methylene chloride listed in their chemical inventory. The initial exposure assessment and personal exposure monitoring will consist of a review of procedures conducted, exposure controls utilized, and monitoring of airborne methylene chloride concentrations within the breathing zone of exposed persons.
Following exposure monitoring that shows exposures are below the EPA exposure limits, the Exposure Control Plan will be finalized to document the control measures.
If the results of the initial monitoring are not below the EPA exposure limits, additional controls must be implemented. Subsequent monitoring will be required to verify the effectiveness of the new controls.
August 1, 2025: Compliance deadline
By this date, all activities involving methylene chloride must be in compliance with the WCPP and be approved for use by EHS. Activities that cannot meet these requirements will not be permitted to continue. EHS must be notified prior to commencing any new operation involving methylene chloride.