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Introduction

Methylene chloride (MC), also known as Dichloromethane, is used as a solvent, especially when high volatility is required. MC is a good solvent for oils, fats, waxes, resins, bitumen, rubber, as well as a useful paint stripper or degreaser. MC is used in propellant mixtures for aerosol containers, as an extracting agent in the pharmaceutical industry, and a blowing agent in polyurethane foams. The MC solvent property is sometimes increased by mixing it with methanol, petroleum naphtha, or tetrachloroethylene. The Occupational Safety and Health Administration (OSHA) estimate that approximately 35,000 employees are exposed to MC per year.

Studies indicate there is suggestive, but not absolute evidence that MC is a suspect human carcinogen. Long-term (chronic) airborne exposure in excess of 25 parts per million (ppm) for 8-hour time weighted average is reported to be associated with an increased risk of cancer of the lung, liver or salivary and mammary glands.

Short-term (acute) airborne exposure above 125 ppm may cause mental confusion, light-headedness, nausea, vomiting and headache. Continued exposure may also cause eye and respiratory tract irritation. Exposure to MC may make symptoms of angina (chest pain) worse. Skin exposure to liquid MC may cause irritation. Liquid MC placed on the skin may cause chemical burns.

MC is commonly used in paint strippers, laboratory work and degreasing parts. MC exposure concentration should be assessed during initial and periodical use.

Applicable ASU Policies

Applicable ASU Guidelines

Applicable Regulations

Summary of Requirements

Initial Monitoring

Initial monitoring must be performed for employees exposed to MC, unless objective data demonstrates that MC cannot be released into the workplace in airborne concentrations at or above the Action Level or above the short-term exposure limit (STEL). The objective data must represent the highest MC exposures likely to occur under reasonably foreseeable conditions of MC processing, use, or handling. All objective data must be documented. Initial sampling is also exempt when exposure monitoring was conducted 12 months prior to April 10, 1997 and samples were collected under conditions which are present now. Initial monitoring is also exempt when employees are exposed to MC fewer than 30 days per year and the department can determine the employee exposure with a direct-reading instrument to provide sufficient information to determine what control measures are needed to reduce exposures to acceptable levels.

Periodic Monitoring

Exposures below the Action Level, but above the STEL, must be monitored for STEL exposures every three months. For exposures at or above the Action Level, but below or at the time weighted average – permissible exposure limit (TWA-PEL) of 25 ppm and below the STEL of 125 ppm, monitoring must be repeated for 8-hour TWA-PEL exposures every six months. For exposures above the TWA-PEL and at or below the STEL, monitoring must be repeated every three months. For exposures above the TWA-PEL and above the STEL, monitoring for the 8-hour TWA-PEL and STEL are required to be performed every three months.

Reduction in Frequency of Monitoring

The department may decrease the frequency of 8-hour TWA monitoring to every six months when at least two consecutive measurements taken at least 7 days apart show the employees exposure to be below the 8-hour TWA. Periodic TWA measurements can be discontinued when 2 consecutive measurements taken at least 7 days apart are below the Action Level. Periodic STEL measurements can be discontinued when 2 consecutive measurements taken at least 7 days apart are at or below the STEL. Measurements would have to be collected if the process of change of product occurred.

Notifications

Employees must be notified in writing within 15 days after the receipt of final laboratory monitoring results of the air samples taken in their breathing zones. Whenever samples indicate that employee results are above the 8-hour TWA-PEL or the STEL, EH&S must describe in the written notification the corrective action being taken to reduce exposure to or below the 8-hour TWA-PEL or STEL and the schedule for completion of this action.

Regulated Areas

Regulated areas must be established whenever an employee exposure to airborne concentrations of MC concentrations exceed the TWA-PEL or the STEL. They must be distinguished from the rest of the workplace in any manner (such as yellow barrier tape or signs) that adequately establishes and alerts employees not authorized to enter the area. Respiratory protection must be supplied to each person who enters the regulated area. Employees entering the regulated area must also be trained in proper work practices to help reduce possible exposures.

Control Methods

Engineering controls and work practices must be instituted to maintain exposures below the TWA-PEL or STEL. Where necessary, controls may be supplemented with respiratory protection.

Respiratory Protection

Where respirators are required, they will be provided by the department at no cost to the employee, and will reduce MC exposures to levels at or below the TWA-PEL and STEL. Respirators are necessary when installing engineering or work practice controls, conducting maintenance operations when work practice and engineering controls are not feasible, and when work practice and engineering controls are not sufficient to reduce employee exposures below the PEL. Since organic vapor cartridge respirators do not protect against MC, only appropriate atmosphere-supplying (air fed) respirators can be used. Each employee using a supplied air respirator, or gas mask with an organic-vapor canister for emergency use must have a physician or other licensed health-care professional evaluate the employee's ability to use such respirators. In the case of an emergency escape the respirator cartridge must be replaced before the gas masks are retuned to service. Whenever a respirator is required, a respiratory protection program must be implemented.

Protective Equipment and Clothing

Protective clothing and equipment must be provided to each employee to prevent MC induced skin and eye irritation. All eye and face protection must be provided by the department and must meet the OSHA requirements of 29 CFR 1910.133. All personal protective equipment must be made of material that is impervious to MC.

Hygienic Practices

Conveniently located washing facilities capable of removing MC must be provided for all employees whose skin may come into contact with solutions containing 0.1 percent or greater MC. Appropriate emergency eye washes must be made available to all employees who may have eye contact (e.g., splashes or spills) to MC solutions containing 0.1 percent or greater MC.

Housekeeping

Preventative maintenance of equipment, including visual inspections for leaks and spills, will be performed regularly. In areas where there spillage may occur, provisions will be made to contain spills, decontaminate the work area, and dispose of the waste. Employees repairing equipment leaks and cleaning up spills will be properly trained and will wear suitable protective equipment. MC contaminated waste will be disposed of following ASU waste disposal guidelines.

Medical Surveillance

A medical surveillance program is required for all employees exposed to MC at concentrations at or exceeding the Action Level on 30 or more days per year or above the TWA-PEL or STEL on more than 10 days per year. Medical surveillance should also be conducted as an initial surveillance, periodic surveillance, and at the termination of employment or reassignment. Periodic surveillance should be conducted within 12 months of initial surveillance for employees 45 and older. Employees 45 and younger are required to have a medical surveillance with 36 months of their initial surveillance. Medical disease questionnaires and medical examinations must be administered. All medical procedures will be performed or directly supervised by a physician or other licensed health care professional. The physician or licensed health care professional must provide the employer and the affected employee a written opinion regarding the results of that examination within 15 days of completion of the evaluation of medical and laboratory findings, but not more than 30 days after the examination.

Hazard Communication

The employer must communicate the following hazards associated with MC on labels and in material safety data sheets in accordance with the requirements of the Hazard Communication Standard, 29 CFR 1910.1200 or 29 CFR 1926.59, as appropriate: cancer, cardiac effects (including elevation of carboxyhemoglobin), central nervous system effects, liver effects, skin irritation, and eye irritation.

Training

All employees with any potential exposure to MC must receive training to provide an understanding of hazards and protection methods. Employees assigned to work sites where exposure to MC is at or above the Action Level must be informed of the requirements of the OSHA Standard 29 CFR 1910.1052 or 29 CFR 1926.1152. Training must be provided at the time of initial assignment and whenever a new exposure to MC is introduced into the work area.

Recordkeeping

Records must be maintained for all of the following:

• All measurements and reports to monitor employee exposure to formaldehyde must be kept by Campus Health Service for at least 30 years
• All employee training records will be kept by EH&S
• Medical surveillance records must be kept for the duration of employment plus 30 years by Campus Health Service
• Respirator fit testing records must be kept by EH&S until replaced with a more recent record

Written Program

A written MC Management Plan must be developed, implemented, and maintained, containing the following components:

• labeling and signage
• material safety data sheets (MSDS)
• medical surveillance
• potential health hazards from exposure
• signs and symptoms of exposure
• adverse effects and reporting requirements
• descriptions of operations where MC is present
• safe work practices
• personal protective equipment
• spills, emergencies, cleanup procedures
• engineering and work practice controls
• review of emergency procedures and specific duties or assignments
• access to training materials

Updated 11/21/06

Mailing Address: PO Box 873804, Tempe, Arizona 85287-3804
Contact Email: EHS@asu.edu
Phone: (480) 965-1823
FAX:  (480) 965-0736