CSHEMA - Campus Safety, Health, and Environmental Management Association

CSHEMA Comment to EPA Highlights Efficacy of Existing Lab Controls for Methylene Chloride and Calls for Harmonized Regulations

June 25, 2025 – The Campus Safety Health and Environmental Management Association (CSHEMA) today submitted a comprehensive comment to the Environmental Protection Agency (EPA) supporting an 18-month extension for the Methylene Chloride Rule (40 CFR 751 subpart B) for non-federal laboratories. CSHEMA's comment provides critical data demonstrating the effectiveness of current laboratory controls and highlights the burden of duplicative regulations.

Representing over 400 higher education institutions, CSHEMA has actively collaborated with its members to develop resources. These efforts, including recent benchmarking by the CSHEMA DCM Working Group, informed their detailed response to the EPA's proposed compliance date extensions.

Key Findings from CSHEMA's Data Submission to the EPA:

• Effective Existing Controls: Quantitative and qualitative data from numerous institutions show methylene chloride exposure values are well below regulatory limits when used in chemical fume hoods or fully enclosed systems.
• Minimal Risk with Best Practices: Following the OSHA Laboratory Standard (29 CFR 1910.1450) and common academic best practices results in very low risk of approaching exposure limits.
• Adequate Alternative Controls: When exposure limits have been exceeded, existing protective laboratory practices and equipment are sufficient to meet EPA's limits. Common-sense solutions like rerouting rotary evaporator pump exhaust are effective.
• Duplicative Regulations Create Burden: The EPA's Methylene Chloride Rule imposes significant financial and operational burdens on laboratories, including substantial costs for exposure monitoring, recordkeeping, and staff time for new programs and training.
• OSHA Laboratory Standard is Sufficient: CSHEMA requests the EPA reconsider applying the TSCA rule to laboratories already adhering to the OSHA Laboratory Standard. A well-designed Chemical Hygiene Plan is sufficient to eliminate unreasonable risk.

Mary Lindstrom, incoming President of CSHEMA, stated, "Our data clearly demonstrates that academic institutions are effectively managing methylene chloride exposures through existing robust laboratory controls and well-established chemical hygiene practices mandated by the OSHA Laboratory Standard. Imposing a separate, prescriptive regulation for a single chemical creates unnecessary confusion, significant financial strain, and administrative burden without adding substantial value to worker protection".

CSHEMA recommends that if a more prescriptive approach is deemed necessary, the EPA consider the approach laid out in the EPA Perchloroethylene Final Rule, which prioritizes engineering controls and dermal protection over mandatory periodic monitoring and chemical-specific programs. CSHEMA urges the EPA to adopt a harmonized, risk-based approach for all applicable TSCA-regulated laboratory chemicals to reduce confusion, lower compliance costs, and maintain high health protection.

About CSHEMA:
The Campus Safety Health and Environmental Management Association (CSHEMA) is the premier association for health, safety, and environmental management in the College and University Sector, serving higher education institutions for over 70 years.

Learn More:
Access CSHEMA's Methylene Chloride Toolkit and stay updated at https://www.cshema.org/index.php/resources/dcm-resources. To become a member, visit CSHEMA.org.