Jennifer,
I think we are missing the bigger picture, whether it is DCM or chemical XYZ..., EPA is not responsible for additional protection plans in the lab/workplace, OSHA is.
But from a practical perspective we should be ensuring the laboratory controls are functioning properly (and validated), then obtaining an OEL of 2 ppm should not be a problem. Those same controls are typically used for the control of more potent compounds that have much lower OELs. But the point is, EPA is outside of their scope and legal authority and should be challenged. Their potential regulations should have no driving impact regarding the scientifically necessary use of some chemicals, necessitated by previously published, peer reviewed and commonly accepted chemicals that they cannot regulate on a lab scale v. commercial scale.
Regarding emissions - regulate away. But EPA you still need adequate justification/laws supporting your position.
However, in the workplace for occupational exposures or laboratory for incidental exposures - stay out of our lanes. Respect our mission and let us do our job of implementing, following and validating the hierarchy of controls to prove effectiveness at preventing exposures.
Please don't misinterpret. I have relied upon PhD Chemists to determine the proper chemistry, including reagents to achieve the desired outcome. My role was simpler, implementing the hierarchy of controls, specifying what was required to prevent exposures, while validating the effectiveness to prevent human exposures to below acceptable limits regardless of if it was for solvents or highly potent compounds. Remember Paracelsus? The dose makes the poison!
Ralph - Please do not post if I've overreached with this response, but I think it is on target for what needs to be addressed.
BruceV
Sent: Wednesday, May 10, 2023 1:52 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EPA ban of methylene chloride
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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