Hi Ralph,

EPA is aiming regulations as lab uses of DCM. Lab use will be exempted, so lab users will be able to continue to order and use DCM, but their employers will be required to make an additional protection plan, do air monitoring, and have a new OEL of 2 ppm as an 8 hour TWA. This can have a very significant impact to lab users and in many cases can result in alternative solvents to be used.

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

-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Ralph Stuart
Sent: Tuesday, May 9, 2023 10:56 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EPA ban of methylene chloride

> Moral is that we need to be careful about making things worse with overly simplistic thinking.

The unspoken question in this statement is worse for who? I don’t believe that EPA is aiming its regulations at lab uses of methylene chloride, but if the rule leads to greener chemistries being explored, that could lead to unexpected discoveries of value in chemical processes.

As your note suggests alternatives need to be evaluated carefully, but I have seen successful substitutions for a variety of chemicals driven by compliance concerns. I have also seen unfortunate substitutions occur for the same reason. But I don’t think that the moral is as simple as the one you proposed.

- Ralph

Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org

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