Toxic Substance Control Act (TSCA) Regulated Chemicals

1. If methylene chloride is being used as a commercial product in your space, such as an adhesive remover, metal cleaner, or lubricant, please dispose of the products as a hazardous waste and substitute them with a methylene chloride-free alternative.
2. If methylene chloride is used under an exemption specified in the regulation, such as a laboratory chemical, it is highly recommended that the laboratory considers eliminating or substituting with a safer substance. If elimination or substitution are not options, please review the requirements for use below.
3. If methylene chloride is used as a laboratory chemical and cannot be substituted or eliminated. Please complete the Methylene Chloride Use Survey. Once the survey is received, EH&S will reach out to coordinate monitoring and next steps.  

The EPA requires employers to implement a Workplace Chemical Protection Program (WCPP) to protect people from exposure to methylene chloride. Under the WCPP, Columbia University is required to:  

• Meet exposure limits for methylene chloride established by the EPA. The EPA exposure limits for methylene chloride are listed in the table below.  

• Conduct exposure monitoring for potential methylene chloride exposures.
• Establish a regulated area when airborne concentrations of methylene chloride exceed, or there is a reasonable possibility they may exceed the exposure limits.
• Identify controls that will be used to reduce exposures to below the exposure limits. 

Columbia University’s Exposure Control Plan.

All researchers at Columbia University must complete an Exposure Control Plan if they are unable to eliminate or substitute methylene chloride in their processes. A laboratory can complete their Exposure Control Plan on Rascal. For more information about how to complete the Exposure Control Plan, please review the How-To-Guide. 

Every laboratory and department must check their chemical inventory for anything containing methylene chloride. Any mixture that includes methylene chloride at concentrations >0.1% is considered to contain methylene chloride and is covered under this regulation.  

If a laboratory stores or uses products containing methylene chloride, the most effective way to reduce exposure is to eliminate or substitute it:  

• Elimination: Elimination removes the hazard at the source. This would involve changing the work process to stop using methylene chloride or switching to a new process that does not require the use of methylene chloride. This is the most effective method of preventing exposure.
• Substitution: Substitution is the process of using a safer alternative to the source of the hazard. For more information and resources about potential alternatives for methylene chloride review the below table below. Additional options can be found using Americal Chemical Society’s Solvent Selection Tool. 

Never substitute methylene chloride with a non-recommended substitute. Non-recommended substitutes are chemical replacements that increase risks to health, safety, and/or the environment. Avoid replacing methylene chloride with chemicals that are similarly hazardous but unregulated. For example:  

• Chloroform is unsuitable due to its toxicity and because it is reasonably anticipated as a human carcinogen.
• Trichloroethylene (TCE) and n-propyl bromide (nPB) are poor alternatives because they can cause serious health issues, including carcinogenicity, reproductive toxicity, and neurotoxicity.
• Hydrochlorofluorocarbons (HCFCs) contribute to ozone depletion and global warming.   

If a laboratory cannot eliminate or substitute methylene chloride in your research a Exposure Control Plan must be developed and exposure monitoring must be conducted in order to continue use. 

If the elimination or substitution of methylene chloride is not feasible, follow the below guidance for engineering and administrative controls.  

Engineering Controls: Engineering controls seek to control hazards at their source by designing the work environment or the job itself to eliminate or reduce exposure to hazards. 

• All research with methylene chloride must be conducted in a chemical fume hood, with the sash at the lowest working height and with sliding sash position (if applicable) aligned to form a barrier.
• Glove boxes may be used as a substitute for chemical fume hoods.
• Use of methylene chloride outside a chemical fume hood must be reported to EH&S for evaluation prior to research.  

Administrative Controls: Policies, work practices, and procedures designed to limit personnel exposure to workplace hazards. Administrative controls should be used in conjunction with engineering controls to ensure the lowest possible exposure.  

• All occupants of laboratories that use methylene chloride shall review the WCPP and their laboratory’s Exposure Control Plan.
• Read the safety data sheet for methylene chloride or methylene chloride containing products prior to use.
• Stop all use of methylene chloride if any malfunction of the local exhaust ventilation system occurs.
• Purchase containers of methylene chloride in the smallest possible quantity possible.  

When engineering and administrative controls are not feasible or do not provide sufficient protection from hazards, appropriate PPE will be provided to laboratory personnel by the PI.  

Many common glove materials do not provide strong protection from methylene chloride, including nitrile, latex, neoprene, and butyl rubber. At a minimum, double glove with nitrile or neoprene combination gloves when performing low risk work (i.e. pipetting and handing of mL scale quantities) with methylene chloride.  The double glove barrier will protect against momentary, incidental contact, but not significant contact or heavy exposure. 

Gloves should always be changed frequently and whenever contamination occurs.  

Gloves of laminates of polyethylene (PE)/ethylene vinyl alcohol (EVOH), polyethylene vinyl alcohol, and ethylene vinyl alcohol (PVA/EVA), polyvinyl alcohol (PVA), Silver Shield, or another laminate resistant to methylene chloride are the preferred material type. These gloves should be used for any high-risk activity (i.e. pouring and other handling that is prone to splashing) or when working with high volumes of methylene chloride. Disposable gloves (e.g. nitrile, neoprene, etc.) can be layered over laminated gloves to protect the inner gloves and provide dexterity if needed. 

When a spill occurs, it has the potential to expose personnel to hazardous chemicals through inhalation, skin contact, ingestion, or eye contact. 

A small chemical spill is one that the laboratory staff is capable of handling safely without the assistance of safety and emergency personnel. In the event of a small chemical spill, use the following information for a safe cleanup process. 

• Alert people in the immediate area of the spill.
• Open outside windows, if possible.
• Wear protective equipment, including safety goggles, gloves, and a lab coat.
• Avoid breathing vapors from the spill.
• Confine spills to as small an area as possible.
• Do not wash spill down the drain 

For more information about what to do in the event of a chemical spill, please refer to the Chemical Spills and Explosions page on the EH&S website. 

EH&S is available to evaluate potential exposures and perform assessments of methylene chloride use. Labs should notify EH&S prior to starting work with methylene chloride and before changing protocols using methylene chloride. Requests may be placed by completing the Methylene Chloride Use Survey.    

A GUIDE TO COMPLYING WITH THE 2024 METHYLENE CHLORIDE REGULATION UNDER THE TOXIC SUBSTANCES CONTROL ACT (TSCA) (RIN 2070-AK70) 

Methylene Chloride Fact Sheet  

Substitution Resources:

• ACS solvent selection tool
• Green Chemistry  

As of September 15^th, 2025 the Environmental Protection Agency (EPA) prohibited the use of TCE as a laboratory chemical. Due to this change in standards, the use of TCE at Columbia University is prohibited. EH&S requires that all users of TCE dispose of the chemical.  

Risk Management for Trichloroethylene 

Fact Sheet: Regulation of TCE Under TSCA 

The final rule published in December 2024 prohibits most consumer and commercial uses of PCE. The final rule provides an exemption to the ban on the use and handling of PCE in research laboratories. As a condition of the exemption for laboratory use, employers are required to create a workplace chemical protection program.  

If you plan to use PCE at Columbia University you must complete the Perchloroethylene Use Survey.    

Please take the following steps to ensure your laboratory’s compliance:  

• If your lab or area has PCE that is no longer in use, please submit a Chemical Waste Pickup Request Form.
• If your lab or area is using PCE for applications prohibited by the TSCA final rule  (e.g. general aerosol degreasing, wipe cleaning, paints or coatings, and aerosol lubricants), this use is no longer allowed for these applications. Use this guide for examples of products that contain PCE.  Please find a substitute for PCE or if possible eliminate the process.  

The EPA requires employers to implement a Workplace Chemical Protection Program (WCPP) to protect people from exposure to perchloroethylene. Under the WCPP, Columbia University is required to:  

• Meet exposure limits for PCE established by the EPA. The EPA exposure limits for PCE are listed in the table below.  

• Conduct exposure monitoring for potential PCE exposures.
• Establish a regulated area when airborne concentrations of PCE, exceed, or there is a reasonable possibility they may exceed the exposure limits.
• Identify controls that will be used to reduce exposures to below the exposure limits. 

Due to the risks associated to exposure to PCE the EPA, requires people using PCE in the laboratory do the following:  

• PCE must be used in a fume hood or glove box at all times. Use outside a fume hood or glove box is prohibited. 
• Use dermal protection that is impervious to PCE. Disposable latex and nitrile gloves are not impervious to PCE and should not be used while working with PCE. 
• Document and keep records of: 
• Who may be potentially exposed to PCE and dermal PPE they are using. 
• Any occurrence of direct dermal contact with PCE.