Chemical Concepts has been working to keep folks in the industry informed about the rapidly changing regulatory environment for methylene chloride. There has been much speculation in recent months about a proposed ban and when this might take effect. This new action begins phasing out most industrial and commercial uses for MC.

Our previous communications on the subject were intended to bring attention to this developing situation and highlight actions that users of MC can take to protect themselves, their supply chains, and stay compliant. Now that it has been finalized, we have more clarity on the timing and scope of the ban.

The EPA’s final rule:

• Prohibits most industrial and commercial uses of methylene chloride
• Creates strict workplace protections through a Workplace Chemical Protection Program to ensure that for the remaining uses, workers will not be harmed by methylene chloride use.
• Requires manufacturers (including importers), processors, and distributors to notify companies to whom methylene chloride is shipped of the prohibitions and to maintain records.
• Some industrial uses have exceptions and will be allowed to continue under the Workplace Chemical Protection Program:
• Use in the production of other chemicals, including chemicals that are important in efforts to reduce global warming
• Production of battery separators for electric vehicles.
• Use as a processing aid in a closed system.
• Use as a laboratory chemical.
• Use in plastic and rubber manufacturing, including polycarbonate production.
• Use in solvent welding.

However those using MC for the above purposes may have additional reporting and health/safety compliance requirements.

Chemical Concepts is taking action for businesses that use MC also known as dichloromethane.

• Creating a list of known adhesive products containing MC
• Notifying customers of the timeline and advising on inventory levels and supply chain strategy to avoid costly shut downs and down time
• Advising on replacement or substitute products
• Increasing our inventory of Methylene Chloride and MC containing adhesives to help manage supply during this transition

We understand the complexity of adapting to new regulatory environments, especially when alternatives may not always clearly offer safer or more environmentally friendly solutions. Manufacturers who use methylene chloride or adhesives containing MC are in a tough position. While we recognize the risks associated with methylene chloride, we also acknowledge the challenges presented by alternative solvents that might be less studied, equally toxic and/or introduce other risks like flammability. Our role is to help our customers navigate these changes and find the best solution that balances performance, health/safety, compliance, risk and supply chain management. It’s not going to be an easy fix for everyone and people in the industry should be prepared to make some compromises to satisfy these competing needs.

Fortunately, there are some resources out there and the EPA action does provide some time to make the necessary changes to remain compliant.

Reach out if you have concerns!