John,

Waste is the least of your worries. You CHP should state no procurement without prior approval. Your CHP can also refer to MeCl  (workplace chemical protection plan) WCPP if you have one.

Anyone using methylene chloride must perform initial monitoring to determine employee exposure levels. If you do not exceed the 2ppm level 8 hr TWA, you don’t need to have a WCPP, but is prudent to have one that lays out periodic monitoring requirements, storage and use locations.

If using in a laboratory fume hood correctly, I can’t imagine exceeding the limits of the TSCA rule

There are a few other caveats, like demarking the work areas, restricted access when in use, but anyone possessing and using MeCl must follow the EPA TSCA 2024 final rule.

As for your initial question, you should check with your TSDF end facility and see what their requirements are for waste containing MeCl. Anyone handing waste may also need to be monitored for exposure levels.

Finally, some have been using 1,2-dichloroethne as an alternative solvent but are not as pleased with the performance in their work ups as with MeCl. This may be good for commerce, but it hurts basic research. Please let the list know if you have any good MeCl monitoring techniques, vendors, or alternatives to MeCl.

Best,

James