The EPA has announced new regulations to protect workers from the toxic effects of dichloromethane under the Toxic Substances Control act. Normally academic labs are exempt from this but the EPA is classifying academic research labs as "commercial" under the new rule.
What this means for Binghamton Research Labs
If your lab cannot eliminate or or substitute DCM, you will need to work with EHS to complete exposure monitoring, an Exposure Control Plan, and a Worker Chemical Protection Plan. EH&S will cover the first round of exposure monitoring, but every round after will need to be covered by the lab group.
Due Dates:
Search for alternates, substitutions: Immediate
If none exist, alter procedures so DCM is only used in a closed system or fume hood: Immediate
Initial Exposure Monitoring: May 5 2025
Exposure Control Plan: October 30 2025
Continuation: If monitoring results permit continued use, periodic monitoring will need to be done every 5 years
Exposure Monitoring Guide
If your lab cannot find a substitute you will need to complete exposure monitoring by May 5th 2025. This monitoring will consist of finding an 8 hour time-weighted average (TWA) and a 15 minute short-term exposure (STEL). Not everyone in the lab needs to be monitored- up to three "worst case" scenario workers to be monitored.
If you are one of the lab workers that will partake in the monitoring there are more detailed instructions below:
Determine which day would be a good day to complete the monitoring- this will be a typical day where you work with DCM. You should have already adjusted work methods to work in fume hoods or closed systems by this point.
On the day you will monitor- take the badge from the pouch and affix it to your lapel or lab coat pocket with the white film facing out and not covered by any fabric.
Fill out the log with a description of each activity during the 8 hour monitoring window.
NOTE: The 8-hour monitoring window is a continuous 8-hours during one day. For example if you only work 2 hours per day in the lab do not split the monitoring period up over 4 days.
Once we receive the results you will be notified and informed if further action is needed.
Spill Procedures for DCM
Uncontrolled spills, such as outside of a fume hood, and large quantity spills of DCM need to be reported immediately to EH&S for proper cleanup, as general lab users do not have the proper respiratory protection to protect them from exposure. Refer to section 3.3 of the Chemical Hygiene Plan as a reminder to the proper protocols to follow in the laboratory in the event of a chemical spill.
DCM Waste
Keep in mind that collection of DCM in a hazardous waste container is still part of the Exposure Control Plan. Many labs use DCM and other solvents for chromatography within a fume hood, but will pour the contents into a container outside of the fume hood (i.e. without an engineering control in place to limit exposure). If possible, collect this waste within the fume hood or under ventilation to keep within the scope of your control plan. DCM can still be collected as normal chromatography waste, where it is often mixed with other halogenated solvents and compatible wastes.
More Information:
We have compiled all resources listed here along with others on our new website: EH&S DCM Compliance Website
