Dear CHAS Colleagues,

Attached are the comment and supplemental information that CSHEMA (Campus Health, Safety and Environmental Management Association) submitted to the EPA today regarding the proposed extension of the compliance dates for the methylene chloride standard. If you have not already submitted a comment and if your work or interests involve research laboratories that are already subject to the OSHA Lab Standard, please consider supporting CSHEMA’s comment by end of day tomorrow, June 26 (before midnight EDT).

CSHEMA’s comment not only supports the extension of compliance dates for laboratories, but suggests:

• EPA allow laboratories complying with the OSHA Laboratory Standard to address methylene chloride through the Chemical Hygiene Plan.
• Allow laboratories complying with the OSHA Laboratory Standard to conduct testing in accordance with those rules, providing flexibility in conducting monitoring in situations where EHS professional judgment suggests that exposure above the new action level, STEL, and ECEL are likely, allowing representative sampling rather than exposure monitoring for each individual.

EPA generally gives more attention to comments that are repeated or have multiple signatories. Thus, we are asking you all to consider providing comments on behalf of yourself or your institution. To make it easier, we have provided a template (attached) that allows you to simply say that you agree with CSHEMA’s comment or to add more detail.

Simple Instructions for Commenting

Before tomorrow, June 26 at 11:59 PM EDT:

1. Create a comment on your own or using one of the templates.
2. Go to Regulations.gov page: https://www.regulations.gov/document/EPA-HQ-OPPT-2020-0465-0441/comment
3. Copy and paste your comment in the comment box or write “Comment attached” and upload your PDF.
4. Select whether you are commenting as an individual, organization, or anonymously.
5. Select “Submit Comment”

Thank you in advance for considering amplifying the message.

Best,

Robin

Co-chair, CSHEMA Advocacy Committee
Immediate Past Chair, EPA Division of Chemical Health and Safety