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EPA Proposes to Ban Most Uses of Methylene Chloride

EPA Proposes to Ban Most Uses of Methylene Chloride

The EPA recently published a notice of proposed rulemaking (NPRM) that seeks to ban most uses of methylene chloride under the Toxic Substances Control Act (TSCA).

The proposed ban may affect ILMA members that formulate, manufacture and sell spray lubricant or grease formulations that contain methylene chloride as a solvent. ILMA is requesting that affected members contact ILMA’s regulatory counsel, Ben Idzik, at, as it considers whether to submit comments on the NPRM.

Methylene chloride is commonly used in various industries, including metal cleaning and degreasing, paint stripping, pharmaceutical manufacturing and paint remover manufacturing. Specifically, the agency proposes to prohibit the manufacture, processing and distribution of methylene chloride for all consumer uses and prohibit its use in most industrial and commercial applications. Permitted industrial and commercial uses will require users to adopt workplace chemical protection programs (WCPP).

The NPRM, if finalized, will categorically prohibit methylene chloride from being used in
the following industrial and commercial applications:

  • Lubricants and greases
  • Solvent for batch vapor degreasing
  • Solvent for in-line vapor degreasing
  • Solvent for cold cleaning
  • Solvent for aerosol spray degreaser/cleaner
  • Metal degreasers
  • Non-aerosol degreasers and cleaners

Industrial and commercial uses of methylene chloride permitted under the NPRM will require the adoption of WCPPs. WCPPs are mandated workplace risk management rules for chemicals. They will apply broadly to owners, operators and potentially exposed persons. The NPRM proposes that WCPPs for permitted uses of methylene chloride limit inhalation exposure to 2 ppm within an 8-hour time-weighted average and 16 ppm within a 15-minute time-weighted average.

Additionally, the EPA proposes new downstream and recordkeeping notification requirements in the NPRM. Downstream notification would be carried out by safety data sheet updates, and the recordkeeping updates focus on maintaining records of WCPP monitoring and compliance.

If finalized, the methylene chloride use restrictions would become effective three months after publication for manufacturers, six months for processors, nine months for distributors, and 12 months for retailers. Compliance with the WCPP requirement for permitted uses will be implemented in a similarly staggered fashion.

Methylene chloride was among the first ten chemicals selected for review under the 2016 TSCA amendments. The EPA’s risk evaluation concluded that methylene chloride presents an unreasonable risk under its conditions of use, as it is harmful to brain and liver function and causes cancer. The NPRM is the EPA’s enforcement response to the risk assessment.