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Environmental Health and Safety (EH&S) Summer Update

Published July 16, 2024, via Research News

EPA Establishes New Rules to Govern Methylene Chloride Use in Labs under TSCA

In April 2024, the Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride under the Toxic Substances Control Act (TSCA).

The TSCA methylene chloride rule prohibits most consumer and commercial uses of methylene chloride; however, will allow use as a laboratory chemical with new requirements including:

  • Documentation of attempts to eliminate or substitute methylene chloride
  • Documentation of all control measures, including those not implemented
  • Initial and periodic exposure monitoring for anyone potentially exposed, including recordkeeping and dissemination of monitoring data
  • Development and implementation of a Workplace Chemical Protection Program
  • Recordkeeping to maintain an auditable paper trail of these measures

Implementation of these requirements is mandated to the following timeline:

  • May 5, 2025: Complete initial exposure monitoring
  • August 1, 2025 or three months after monitoring: Implement controls
  • October 30, 2025: Develop and implement an Exposure Control Plan

Based on the above compliance timelines, EH&S personnel are quickly working to determine where and how methylene chloride is used on campus, which uses can continue and which must stop, and developing an initial exposure monitoring plan. More information will be provided as the initial regulatory deadline approaches.

If you have been identified as a lab who uses or stores methylene chloride, you will be receiving an email with a survey and instructions. It is very important that these surveys be completed and submitted to assist with these new regulatory requirements.

United States Government Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential

On May 6, 2024, the White House Office of Science and Technology Policy (OSTP) released an expanded and unified Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential. This new U.S. Government-wide policy, which combines the current dual use research of concern (DURC) and enhanced potential pandemic pathogen oversight frameworks, expands the scope of research requiring additional scrutiny and introduces new training and oversight responsibilities for Principal Investigators and the Institution. EH&S and the Institutional Biological & Chemical Safety Committee (IBC) are currently evaluating this U.S. Government policy change and associated implementation guidance and will update or develop policies, procedures, and training as needed. More information will be provided closer to the May 2025 implementation deadline.

New Resources!

  • FY25 Lab Inspection Checklist and Guidance
    • The FY25 Lab Inspection Checklist and associated Lab Inspection Process and Guidance have been published. These documents can be accessed on this page under Relevant Resources.
  • Reproductive Health Guidance for Researchers
    • The previous “Pregnant Worker Guidelines for Hazardous Material Work” was recently updated to provide more comprehensive reproductive health guidance when working in research spaces. The new guidance can be accessed on this page under Relevant Resources – Reproductive Health in Research Spaces.
  • SOPs
    • EH&S continues to expand the library of available SOPs to assist research labs in ensuring compliance with the OSHA Lab Standard. Be sure to visit the Standard Operating Procedures (SOPs) page for current resources.

Questions? 
Please contact Environmental Health and Safety at ehs@wustl.edu.