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>
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
Use will require monitoring; there are personnel badges available for this.
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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For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at
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