Background
On May 8, 2024, the Environmental Protection Agency (EPA) issued a final rule under the Toxic Substances Control Act (TSCA) for Methylene Chloride, also known as Dichloromethane (DCM). This regulation went into effect on July 8, 2024, and updated the code of Federal Regulations at 40 CFR Part 751, subpart B. The EPA has determined that the use of DCM presents an unreasonable risk of injury to health due to acute human lethality. This is based on the assessment for methylene chloride issued by the EPA in 2020 pursuant to TSCA section 6(b). The details of the EPA’s unreasonable risk determination were finalized in November 2022.
While this rule does not ban the use and handling of DCM in research laboratories, it does place DCM on the EPA's regulatory list. Laboratory handling is permitted only when covered by a compliant Workplace Chemical Protection Program (WCPP).
Timeline
| Required Actions | EPA Timeline | Target Dates for ORS |
|---|---|---|
| PI Submits Initial survey | NA | September 2024- October 2024 |
| ORS Conducts Initial monitoring | May 5, 2025 | October 2024- March 2025 |
| ORS Determines PPE and Provides Training | August 1, 2025 (or within 3 months of results) | January 2025- August 2025 |
| ORS Updates Chemical Hygiene Plan with WCPP Inclusion | October 30, 2025 | January 2025- October 2025 |
Table 1: DCM Compliance Timeline EPA and UChicago |
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ORS Needs Your Help to Ensure Compliance with EPA and OSHA
- If your lab has DCM that is no longer in use, please submit a waste pickup request via the EHSA website (for a refresher on how to do this, click here). Please remove the DCM from the lab’s chemical inventory to reflect its disposal.
- If the lab is using DCM for applications prohibited by the TSCA final rule (e.g., paint, paint strippers in arts, coating removers, metal aerosols, and aerosol degreasing applications), this use is no longer allowed for these applications. Please submit a waste pickup request via the EHSA website (for a refresher on how to do this, click here). Refer to this guide for examples of products containing DCM. Please note that the use of DCM in facilities for non-laboratory purposes is prohibited unless the use is specifically exempted by the EPA Final Rule.
- If your lab is using DCM or plans on future use, you must fill out the short DCM survey form by October 10, 2024. This information will then be used to develop a plan that complies with the new EPA regulations and does not adversely affect your work.
- If your lab is interested in substituting another solvent for DCM, please refer to Table 2 and/or contact ORS with any additional questions/concerns.
The Office of Research Safety (ORS) will work with labs and/or facilities using DCM to develop a WCPP (Workplace Chemical Protection Program) document in order to comply with the new EPA regulations.
| Application | Alternative Solvent(s) for DCM | References |
|---|---|---|
| Extractions or Chromatography | Ethyl Acetate, Heptane, Toluene, 2-MeTHF, Methyl tert-butyl ether | |
| Peptide Synthesis | 2-methyl tetrahydrofuran (2-Me-THF) | |
| Other | Selected Solvents | |
Table 2: Alternatives to DCM in research laboratories |
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