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Subject: [DCHAS-L] LSI Free Webinar on DCM Regulations

Date: Jul 3, 2024 02:33 UTC

Author: Samuella Sigmann <00001d2fb4580b5b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>

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Subject: Re: [DCHAS-L] Methylene chloride in teaching labs

Date: Jul 3, 2024 15:19 UTC

Author: Jonathan Dannatt <jdannatt**At_Symbol_Here**UDALLAS.EDU>

From: Margaret Rakas <mrakas**At_Symbol_Here**SMITH.EDU>

Subject: Re: [DCHAS-L] Methylene chloride in teaching labs

Date: Jul 3, 2024 15:09 UTC

Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>

Message-ID: <CAAszpkz1dacsb_UmU07pP9m8wXc1E+cWb1+L-wLLCg-3if=TTg**At_Symbol_Here**mail.gmail.com>

In-Reply-To: <DM3PR08MB9587AF79C8FADAF93A3A44E4A3DC2**At_Symbol_Here**DM3PR08MB9587.namprd08.prod.outlook.com>

Demystify: 
Yep, the EPA explicitly defines "commercial use" as including academic and other research laboratories.

Pg. 71 of the final rule

iii. Industrial and commercial use as a laboratory chemical.

This condition of use refers to the industrial or commercial use of methylene chloride in a

laboratory process or in specialized laboratory equipment for instrument calibration/maintenance

chemical analysis, chemical synthesis, extracting and purifying other chemicals, dissolving other

substances, executing research, development, test and evaluation methods, and similar activities,

such as use as a solvent, reagent, analytical standard, or other experimental use. For the purposes

of this rulemaking, EPA emphasizes that industrial and commercial use of methylene chloride as

a laboratory chemical applies to research, government, and academic institutions, as well as to

industrial and commercial laboratories.


here's a fact sheet
https://www.epa.gov/system/files/documents/2024-06/mecl-fact-sheet_final_6-03-24.pdf

Use will require monitoring; there are personnel badges available for this.  



On Wed, Jul 3, 2024 at 10:58 AM Alex Hagen <fischera**At_Symbol_Here**uw.edu> wrote:

Good afternoon,

 

Like many others, our institution is currently trying to assess the impacts of the new methylene chloride regulation from EPA, and a question has come up around use of this chemical in teaching labs. Our chemistry department currently uses methylene chloride for some of their higher level courses. Do activities with methylene chloride conducted in teaching labs qualify as “commercial use as a laboratory chemical”?

 

How is your institution addressing this issue (if it is relevant for you)?

 

Any input is appreciated!

Regards,
~Alex

ALEX HAGEN, CCHO

Laboratory Safety Inspection Program Manager

Environmental Health & Safety Department

fischera**At_Symbol_Here**uw.edu / www.ehs.washington.edu

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--
Margaret A. Rakas, Ph.D.
Lab Safety & Compliance Director
Clark Science Center
Smith College
413-585-3877 (p)

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