Methylene chloride controls depend on the permitted use

October 7, 2026

EPA’s methylene chloride risk-management rule separates prohibited uses from specified uses that may continue under workplace controls. The 2024 final rule, effective July 8, 2024, therefore requires a use-specific review before an employer selects an exposure assessment or control approach.

APT’s methylene chloride workplace protection rule tracker record identifies the permitted-use pathways and their exposure requirements.

Determine whether the activity may continue

EPA’s risk-management page describes prohibitions on most consumer and industrial or commercial uses. A Workplace Chemical Protection Program, or WCPP, applies to specified continuing uses. The presence of ventilation, monitoring or a respirator does not by itself establish that an otherwise prohibited activity is permitted.

For covered WCPP uses, the rule sets an existing chemical exposure limit of 2 parts per million as an eight-hour time-weighted average. The action level is 1 ppm on the same basis, and the short-term exposure limit is 16 ppm averaged over 15 minutes. These are EPA TSCA values for the covered uses. Applicable OSHA requirements need their own assessment.

Laboratory schedules have changed

EPA amended laboratory compliance dates in 2025. Its current chemical page warns that older implementation materials are being updated. Covered laboratory milestones differ from those for other WCPP workplaces, so an original 2024 calendar should not be applied to laboratories without checking the amendment.

APT’s practical interpretation is to record the condition of use alongside the chemical inventory entry. That allows the prohibition, continuing-use requirements and any relevant exception to be traced to the same activity. Sampling records should also identify whether they address the eight-hour exposure basis or the short-term limit.

A facility decision requires the applicable provisions of part 751 and the current laboratory amendment, where relevant.

Find related developments in the industrial hygiene regulatory tracker.

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