Hi,

I’m interested in talking to members here about the proposed regulation, its impact to universities, and commenting on behalf of DCHAS (we may need approval from ACS, can the board members comment?). If others are interested, reply here and we can try to organize a sidebar conversation on zoom.

Admittedly I haven’t read the Risk Evaluation that this regulation is based on, but I do question the necessity of requiring SCBAs when exposures exceed 2 ppm as an 8-hour TWA. I suspect they added that stringent of PPE to effectively ban DCM at exempt employers because frankly, an SCBA is a non-starter. I sincerely hope our fume hoods control below that level, but am not 100% sure all the time.

Jennifer

Jennifer Mattler Guzman, CIH, M.S., M.S. (she/her)
Industrial Hygienist/Chemical Hygiene Officer
Environmental Health and Safety
Stanford University
650.723.0183

Just alerting folks to the publication in the Federal Register of a proposed rule to ban the manufacture and use of methylene chloride (dichloromethane). Here is the link https://www.govinfo.gov/content/pkg/FR-2023-05-03/pdf/2023-09184.pdf?utm_source=federalregister.gov&utm_medium=email&utm_campaign=subscription+mailing+list

It seems that research at universities might fall into the category of “Industrial and Commercial Use as a Laboratory Chemical” which would require  a “Workplace Chemical Protection Program” (WCPP) with exposure monitoring. However, this is not explicitly clear.

Comments should be submitted before June 2, 2023. Has DCHAS discussed submitting a response? Should we?

Chris

Christine Rogers, PhD, CIH

Director of Research Safety

Environmental Health & Safety

Cornell University

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