From:
Jennifer Mattler Guzman <jmattler**At_Symbol_Here**STANFORD.EDU>
Subject:
Re: [DCHAS-L] EPA ban of methylene chloride
Date:
May 12, 2023 21:12 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<SJ0PR02MB8642EBB4BF567A35D7D5A015AA759**At_Symbol_Here**SJ0PR02MB8642.namprd02.prod.outlook.com>
In-Reply-To:
<1704409183.869721.1683907587861**At_Symbol_Here**mail.yahoo.com>
Hi all,
Thanks for your conversation. As promised, here’s a doodle poll to find a good time to chat live about this proposed regulation and potential impacts to our researchers. Please reply by noon Pacific on Tuesday May 16 so I can send a meeting
invitation to those who reply.
https://doodle.com/meeting/participate/id/dwKNRzRd
In the meantime, does DCHAS leadership know if ACS is planning to comment on this proposed rule? Organizations like ACS typically have a governmental affairs staff that coordinates commentary on behalf of the organization.
Best,
Jennifer
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Monona Rossol
Sent: Friday, May 12, 2023 9:06 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EPA ban of methylene chloride
No, that's about right. EPA sets standards for the public and all users. OSHA, ACGIH, and the DFG MAKs are set for most healthy adult workers. I don't like the
use of OSHA standards for labs that include non-workers like students, people with disabilities, young people, etc.
Monona
-----Original Message-----
From: Kolodziej, Christopher <ckolodziej**At_Symbol_Here**EHS.UCLA.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Thu, May 11, 2023 10:52 am
Subject: Re: [DCHAS-L] EPA ban of methylene chloride
My reading of the proposed regulation is that “use as a laboratory chemical” would include use as a solvent in research laboratories. Their rationale for not banning
it was essentially that laboratories have fume hoods, and are therefore probably able to use methylene chloride safely. I happen to agree with this logic, which is why I agree with Jennifer that requiring a supplied air respirator as the only form of is overkill,
as is the requirement that “initial” exposure monitoring be performed every five years irrespective of use of engineering controls.
I’m also surprised by the PEL that they chose. We all know the inadequacies of OSHA’s existing PELs, but there are other regulatory/advisory bodies out there we can
look to whose approaches are generally more protective. The Cal/OSHA PEL is 25 ppm, the ACGIH’s TLV is 50 ppm, and the EU’s OEL is 100 ppm. It’s not impossible that all three could have set values an order of magnitude or two too high, but it doesn’t seem
very likely.
________________________________
Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer
> 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.
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