Dichloromethane (DCM) Research Compliance Program

1 Overview of the U.S. EPA Ban on Dichloromethane

Methylene chloride (dichloromethane, DCM) is a volatile solvent used in labs, degreasers, and paint strippers. Its volatility makes inhalation the primary exposure route. On campus, many products containing >0.1% DCM are used, including reagent-grade DCM and various consumer goods. In laboratories, DCM is common in extractions, chromatography, tissue clearing, and other processes.

DCM (dichloromethane) poses health risks through dermal contact and inhalation. It's classified as a carcinogen and acute neurotoxin. Acute exposure can cause irritation to eyes and skin, dizziness, nausea, and drowsiness. Chronic exposure may impact liver function and the central nervous system. Target organs include eyes, skin, cardiovascular and central nervous systems. DCM can lead to CNS depression, with symptoms like headache, slurred speech, and impaired gait. In severe cases, it can cause loss of consciousness, seizures, and death.

The United States Environmental Protection Agency's risk evaluation of dichloromethane found unreasonable health risks in 52 of 53 use conditions. The final rule, published April 2024, applies to products with >0.1% DCM. The rule aims to eliminate unreasonable risks to everyone – which includes all people in the MSU Community: employees, students, visitors, and members of the public.

2 How MSU Meets the New EPA Standards for DCM

2.1 Eliminate DCM Use in Teaching, Facilities and Housing

The surest way to prevent DCM exposures is to eliminate its use entirely. The University aims to eliminate all uses of DCM by December 2026.

Infrastructure Planning and Facilities and Residential Housing will comply with the rule by eliminating DCM entirely. Any products used for cleaning, maintenance and operations will be free of DCM by May 2025 and substituted with less hazardous materials.

In addition, all MSU teaching laboratories will be required to dispose of all DCM and replace with alternative solvents by May 1, 2025.

Research Groups which did not self-identify in the November 2024 DCM Survey as wanting to continue use of DCM should submit their remaining stocks of DCM for waste disposal prior to April 2025. Request waste pick up of DCM via the EHS website.

2.2 Substitute with Alternative Compounds

The research community is encouraged to eliminate or substitute DCM to avoid administrative and infrastructure burdens. The Office of Research and Innovation recognizes the challenges of eliminating and/or substituting DCM entirely, and the time and expense of finding alternative solvents for ongoing research projects. However, our reputation as a Green University challenges us to be leaders in eliminating our dependence on DCM in the future.

2.3 Workplace Controls for Continued Use in Research

The USEPA provides an exemption for use of DCM in research; MSU will comply with the requirements of this exemption until December 1, 2026, at which time its continued use will be reevaluated. This approach reduces DCM exposure and aligns with EPA regulations while maintaining research capabilities during the transition period.

The research exemption has stringent Federal requirements and will necessitate substantial investment in administrative and infrastructure resources. Therefore, Michigan State University will limit use of DCM to tasks performed in a fume hood AND have DCM exposure limits of less than 1ppm. Exposures between 1-2ppm would require medical monitoring and surveillance; MSU will strive to prevent exposures above 1ppm to eliminate this requirement.

In addition, to ensure resources and burdens are shared across the research enterprise, DCM use at MSU will also require the following:

2.3.1 Locations

A total of no more than four (4) research laboratories across campus permitted for DCM use. Deans, Directors and Chairpersons will be provided with the list of self-identified DCM users; the Deans and Chairs should then collaborate to determine the location of the 4 DCM rooms. Facility requirements are below. Once identified, Deans/Chairs can complete a Qualtrics form to submit to EHS for assistance and review of the 4 proposed DCM Rooms

2.3.2 Facilitator

Each DCM Room must have a faculty/staff person identified as the DCM Facilitator for the DCM Room. The DCM Facilitator will be the single point of contact for EHS to ensure all DCM permitting steps are completed by the deadlines. DCM Facilitators will also ensure continuous compliance in the DCM Room until the DCM Room is returned to normal laboratory service by December 2026 or before.

2.3.3 Infrastructure Upgrades

Any infrastructure repairs and/or upgrades required for DCM Rooms will be the responsibility of the Colleges/Departments whose employees and students use the DCM Room. After May 1, 2025 all use of DCM must take place in a fume hood – benchtop work (even in small quantities) will not be permitted.

2.3.4 Restricted Access

After May 1, 2025, access to DCM permitted rooms will only be available to people identified on the DCM Task List.  All other people, including visitors, students, custodial, IPF workers, etc. cannot enter the DCM Room unless all DCM work is shut down and/or DCM is closed and capped.

2.3.5 Adherence to Timelines

Missed deadlines will have DCM use prohibited in the DCM Room until all compliance documents, air monitoring and training tasks are complete and approved

2.4 DCM Facility Requirements

To meet the requirements of the EPA rule, laboratories identified by Deans, Directors and Chairpersons must meet the following requirements to be designated a DCM Room:

  1. Functioning fume hood for DCM work only. All DCM use must take place in a functioning fume hood – no exceptions. 
  2. Working fume hood monitor
  3. Negatively pressured laboratory (air moves from the hall into the laboratory at all times)
  4. Ventilated storage cabinet for product and waste storage
  5. Single-pass air, no recirculation
  6. Card key access
  7. Functioning eyewash
  8. Emergency shower in the laboratory

2.5 DCM Permitting Responsibilities

2.5.1 MSU Environmental Health and Safety

  • Inspecting laboratories for infrastructure requirements
  • Scheduling and performing air monitoring for identified DCM tasks
  • Providing all necessary template documents
  • Reviewing submitted forms for completeness and compliance
  • Completing quarterly fume hood inspections/calibrations
  • Offering DCM training modules in Ability 
  • Updating the MSU Chemical Hygiene Plan to incorporate the MSU DCM Compliance Program

2.5.2 Deans, Directors and Chairpersons

  • Collaborating on appropriate shared DCM facilities and identifying potential DCM Rooms to EHS
  • Funding necessary infrastructure repairs for DCM Rooms throughout its use
  • Assigning a DCM Facilitator to each DCM Room
  • Ensuring the DCM Facilitator and DCM Users meet compliance deadlines and uphold compliant activities through December 2026

2.5.3 Research Groups using DCM

  • Working proactively to discover alternative solvents and processes to eliminate dependence on DCM
  • Meeting all regulatory requirements and deadlines in a timely manner
  • Providing approved PPE as determined by the PPE Assessment document
  • Ensuring safe, compliant work practices are continued in DCM Rooms in accordance with the USEPA rule
  • Reporting any infrastructure malfunctions, non-permitted DCM use, unauthorized use of DCM Rooms immediately to the DCM Facilitator
  • Planning to discontinue use of DCM by December 2026 or before

2.6 DCM Permitting Timelines

Here are the current deadline dates for the DCM Compliance Program. Any updates or changes will be posted on the  EHS website.  DCM Users and Facilitators will be provided the required templates and documentation directly from EHS in advance of their due date.

January 15, 2025 – Deans, Directors and Chairpersons complete a DCM Infrastructure Survey for laboratory spaces proposed as a DCM Room and submits to MSU EHS for evaluation. DDCs identify (1) DCM Administrator per DCM Room

January 31, 2025: EHS evaluates infrastructure of laboratory spaces identified as proposed DCM Rooms, sends results of DCM Infrastructure Survey back to DDC.

February 1, 2025: DCM Groups complete DCM Task List form; DCM Administrator submits DCM Task Lists per DCM Room to EHS. 

February 15, 2025: EHS reviews DCM Task List forms, identifies common tasks and schedules initial air monitoring of the tasks with DCM Administrators

April 15, 2025: EHS performs air monitoring of the tasks identified by the DCM Task List.  Results from air monitoring are returned back to the DCM Administrator within 15 days of receiving from independent analytical laboratory.  Should any task fall above 1ppm, the task must be eliminated or reworked, and a new air monitoring session scheduled with EHS.  All new or repeat air monitoring must take place before April 15, 2025. EHS will inform the DCM Administrator which tasks fell below 1ppm and are now designated DCM Approved Tasks.

May 1, 2025 – all DCM use on campus is discontinued, except for those DCM Approved Tasks identified on the DCM Task List and approved by EHS.  All DCM Approved Tasks must be moved to the DCM Room.  The DCM Administrator will now prohibit personnel from entry unless identified on the DCM Task List. This will include IPF, Custodial, Support Staff, other researchers and students.

June 15, 2025 – DCM Administrators submit final PPE Assessment forms to EHS

July 15, 2025 – DCM Administrators submit final DCM Standard Operating Procedure to EHS

August 15, 2025 – DCM Users and Facilitators complete the online “Methylene Chloride Safety” training

October 15, 2025 – EHS confirms all required forms and trainings are complete and issues final DCM Permit per DCM Room to the DCM Facilitator

Ongoing until December 2026: EHS will continue quarterly fume hood testing, air monitoring, and DCM Permit compliance inspections

2.7 Glossary of DCM Compliance Program Terms

DDC: Deans, Directors and Chairpersons

DCM Facilitator: the liaison between the DCM Users/Groups and EHS during the permitting process. The DCM Facilitator ensures all engineering controls, administrative controls and personal protective equipment are in use and in compliance.  DCM Facilitator also coordinates entry for people not listed on the DCM Permit.

DCM Room: A research laboratory, evaluated by EHS to meet the requirements for adequate engineering controls for DCM use.  Access to this room is restricted to DCM Users and DCM Facilitator identified on the DCM Permit.

Approved Tasks: Projects, experiments or processes that have been identified by the DCM Facilitator, evaluated by EHS and found to fall below the EPA 1ppm DCM exposure limit

DCM Group: Research Groups who will be using DCM in a DCM Room

DCM User: Individual PI or graduate student identified in the DCM Permit as authorized to work in the DCM Room and listed as a DCM User on the Approved Task List

DCM Permit: Packet which includes completed Infrastructure Survey, DCM Approved Task List, PPE Assessment form, DCM Standard Operating Procedure, training documentation and air monitoring results

Chemical Hygiene