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