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From: Kevin Beltis <000019dea84e24bd-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Methylene chloride in teaching labs
Date: Jul 3, 2024 21:10 UTC
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: <BN2P110MB12690F30AABADBDED0564EBFBFDDA**At_Symbol_Here**BN2P110MB1269.NAMP110.PROD.OUTLOOK.COM>
In-Reply-To: <BL0PR14MB3795A7CDAEC0C0F8EB79BF6AC7DD2**At_Symbol_Here**BL0PR14MB3795.namprd14.prod.outlook.com>
It may take a legal review, but there may (should) be a distinction (at least a clarification) for academic research labs v. academic teaching labs as is being alluded to in
some of the inquiries. On a related basis, OSHA may cover use in research but not teaching (except for the instructor).
I’ll also raise the question for specific use under engineering controls (i.e., within a functioning fume hood) or within an open environment where IH monitoring (e.g., badges)
makes sense.
-Kevin
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Kevin J. Beltis
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TIAX LLC
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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Kristi Ohr
Sent: Wednesday, July 3, 2024 1:08 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: EXTERNAL [DCHAS-L] Methylene chloride in teaching labs
True, but the badges are not meant for STEL monitoring, which is also required. Teaching labs are absolutely covered, including students.
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Margaret Rakas
Sent: Wednesday, July 3, 2024 11:09 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Methylene chloride in teaching labs
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.
On Wed, Jul 3, 2024 at 10:58 AM Alex Hagen <fischera**At_Symbol_Here**uw.edu> wrote:
