Vertrel Solvents - Frequently Asked Questions

New safety regulations (specifically, 29 CFR Part 1910.1052) involving the use of methylene chloride were proposed by the Occupational Safety and Health Administration (OSHA) in 1998 and became effective as of April 20, 1999.

As of August 1998, the new OSHA regulations reduce the permissible exposure limit (PEL) for methylene chloride by a factor of twenty: from 500 ppm to 25 ppm, eight-hour time-weighted average. In addition to exposure limits, OSHA also established new mandatory air quality rules, new long-term medical monitoring requirements, and restricted the time period which employers had to meet the new exposure criteria.

After intense discussions with a number of industry groups, the final regulations were published with slightly modified enforcement dates. For companies with more than 150 employees, the 8-hour PEL monitoring program becomes effective on April 10, 1999. For companies with fewer than 150 employees, the effective date is one year later, on April 10, 2000.

Here are a few key items from the rules, identified by page number in OSHA Pub. #3144:

Page 2: The employer must ensure that no employee is exposed to an airborne concentration of methylene chloride in excess of 25 ppm (8-hour TWA) or a short-term exposure limit (STEL) in excess of 125 ppm during a sampling period of 15 minutes. The subtlety in this regulation is the use of the word "ensure." In effect, any company using methylene chloride is guilty unless they have a measuring program in place which can prove they are using it safely.
Page 2: For each person entering an area in which methylene chloride is being used, the employer must supply appropriate respiratory protection. On Page 12, this requirement is made even more onerous be declaring that if the exposure levels are unknown (again, no monitoring is in place) then the employee must be equipped with exposure protection gear. This gear must include at least (1) positive-pressure full face self-contained breathing apparatus (SCBA) and (2) full face pressure-demand supplied-air respirator with an auxiliary self-contained air supply.
Page 4: The employer must begin an exposure monitoring program for all tasks where initial monitoring shows employee exposures are above the action level or STEL. If employee exposure is above the action level, but at or below both the PEL and STEL, employers must monitor employees at least every 6 months. If exposure is above the PEL or STEL, employers must monitor employees at least every 3 months.
Page 5: Employers must perform additional monitoring when workplace conditions change-for example, when there is an indication that employee exposures have increased; changes occur in the production, process, control equipment, or work practices that could affect exposure levels; and leaks, ruptures, or other breakdowns occur.
Page 6: Medical surveillance is made mandatory because it is "a comprehensive way to determine if exposure to workplace hazards adversely affects employee health." This process must be made available to the employee at no cost to the employee, without loss of pay, and at a reasonable time and place. OSHA concludes that "Through frequent required medical exams or tests, early detection of occupational diseases is possible and preventive measures can be taken to curtail overexposure."
Pages 9-11: This section specifies a new layer of mandatory controls designed to reduce employee exposure in the workplace. Foremost on the list are "engineering controls" which reduce hazards either by removing or isolating the hazard or isolating the worker from exposure. Local exhaust ventilation, general ventilation systems, and special isolation devices or enclosures are examples of engineering controls. Also required are "work practice controls" reduce the likelihood of exposure by altering the manner in which a task is performed and "administrative controls" which remove workers from exposure by job changes and other managerial processes.
Page 14: Employers with twenty or more employees must keep records of employee exposure measurements for at least thirty years.
Page 15: In addition to current OSHA-required training, employers now must inform and train employees of the quantity, location, manner of use, release, and storage of methylene chloride and the specific nature of operations that could result in methylene chloride exposure, especially for exposures above the PEL or STEL-when employees' exposure to methylene chloride exceeds or can be expected to exceed the action level.

All of the details in this regulation are available from OSHA as follows:

All About OSHA-OSHA# 2056
Chemical Hazard Communication-OSHA #3084
Consultation Services for the Employer-OSHA #3047 Employee Workplace Rights-OSHA #3021
How to Prepare for Workplace Emergencies-OSHA #3088
OSHA Inspections-OSHA #2098
Personal Protective Equipment-OSHA #3077
Respiratory Protection-OSHA #3079

Single free copies of the following publications can be obtained from the U.S. Department of Labor, OSHA/OSHA Publications, P.O. Box 37535, Washington, DC 20013-7535. Send a self-addressed mailing label with your request.


About \| News
	What are the New U.S. Regulations About Methylene Chloride?
		New safety regulations (specifically, 29 CFR Part 1910.1052) involving the use of methylene chloride were proposed by the Occupational Safety and Health Administration (OSHA) in 1998 and became effective as of April 20, 1999. As of August 1998, the new OSHA regulations reduce the permissible exposure limit (PEL) for methylene chloride by a factor of twenty: from 500 ppm to 25 ppm, eight-hour time-weighted average. In addition to exposure limits, OSHA also established new mandatory air quality rules, new long-term medical monitoring requirements, and restricted the time period which employers had to meet the new exposure criteria. After intense discussions with a number of industry groups, the final regulations were published with slightly modified enforcement dates. For companies with more than 150 employees, the 8-hour PEL monitoring program becomes effective on April 10, 1999. For companies with fewer than 150 employees, the effective date is one year later, on April 10, 2000. Here are a few key items from the rules, identified by page number in OSHA Pub. #3144: Page 2: The employer must ensure that no employee is exposed to an airborne concentration of methylene chloride in excess of 25 ppm (8-hour TWA) or a short-term exposure limit (STEL) in excess of 125 ppm during a sampling period of 15 minutes. The subtlety in this regulation is the use of the word "ensure." In effect, any company using methylene chloride is guilty unless they have a measuring program in place which can prove they are using it safely. Page 2: For each person entering an area in which methylene chloride is being used, the employer must supply appropriate respiratory protection. On Page 12, this requirement is made even more onerous be declaring that if the exposure levels are unknown (again, no monitoring is in place) then the employee must be equipped with exposure protection gear. This gear must include at least (1) positive-pressure full face self-contained breathing apparatus (SCBA) and (2) full face pressure-demand supplied-air respirator with an auxiliary self-contained air supply. Page 4: The employer must begin an exposure monitoring program for all tasks where initial monitoring shows employee exposures are above the action level or STEL. If employee exposure is above the action level, but at or below both the PEL and STEL, employers must monitor employees at least every 6 months. If exposure is above the PEL or STEL, employers must monitor employees at least every 3 months. Page 5: Employers must perform additional monitoring when workplace conditions change-for example, when there is an indication that employee exposures have increased; changes occur in the production, process, control equipment, or work practices that could affect exposure levels; and leaks, ruptures, or other breakdowns occur. Page 6: Medical surveillance is made mandatory because it is "a comprehensive way to determine if exposure to workplace hazards adversely affects employee health." This process must be made available to the employee at no cost to the employee, without loss of pay, and at a reasonable time and place. OSHA concludes that "Through frequent required medical exams or tests, early detection of occupational diseases is possible and preventive measures can be taken to curtail overexposure." Pages 9-11: This section specifies a new layer of mandatory controls designed to reduce employee exposure in the workplace. Foremost on the list are "engineering controls" which reduce hazards either by removing or isolating the hazard or isolating the worker from exposure. Local exhaust ventilation, general ventilation systems, and special isolation devices or enclosures are examples of engineering controls. Also required are "work practice controls" reduce the likelihood of exposure by altering the manner in which a task is performed and "administrative controls" which remove workers from exposure by job changes and other managerial processes. Page 14: Employers with twenty or more employees must keep records of employee exposure measurements for at least thirty years. Page 15: In addition to current OSHA-required training, employers now must inform and train employees of the quantity, location, manner of use, release, and storage of methylene chloride and the specific nature of operations that could result in methylene chloride exposure, especially for exposures above the PEL or STEL-when employees' exposure to methylene chloride exceeds or can be expected to exceed the action level. All of the details in this regulation are available from OSHA as follows: All About OSHA-OSHA# 2056 Chemical Hazard Communication-OSHA #3084 Consultation Services for the Employer-OSHA #3047 Employee Workplace Rights-OSHA #3021 How to Prepare for Workplace Emergencies-OSHA #3088 OSHA Inspections-OSHA #2098 Personal Protective Equipment-OSHA #3077 Respiratory Protection-OSHA #3079 Single free copies of the following publications can be obtained from the U.S. Department of Labor, OSHA/OSHA Publications, P.O. Box 37535, Washington, DC 20013-7535. Send a self-addressed mailing label with your request.


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