Methylene Chloride Compliance Plan — 29 CFR 1910.1052
Written compliance plan for methylene chloride (DCM, dichloromethane) exposure. PEL 25 ppm TWA; STEL 125 ppm; Action Level 12.5 ppm. Covers exposure determination, regulated areas, engineering controls, respiratory protection, and the medical surveillance protocol.
When this template is required
Required wherever methylene chloride (dichloromethane, DCM) exposure occurs. PEL: 25 ppm 8-hour TWA; STEL: 125 ppm 15-min; Action Level: 12.5 ppm. EPA banned methylene chloride in consumer paint and coating removal (40 CFR 751.105) and in 2024 prohibited most remaining industrial and commercial uses (40 CFR 751.107). Only the conditions of use listed in 40 CFR 751.109(a) may continue, and then only under a Workplace Chemical Protection Program. Confirm the use is still permitted before relying on this plan.
Why this template
STEL requirement — unique among Subpart Z
Methylene chloride has both an 8-hour TWA PEL (25 ppm) and a 15-minute STEL (125 ppm). The plan includes the STEL monitoring procedure — many compliance programs miss this. For uses that remain permitted under EPA’s TSCA rule, the binding limits are tighter still: an ECEL of 2 ppm as an 8-hour TWA and an EPA STEL of 16 ppm over 15 minutes (40 CFR 751.109(c)).
EPA TSCA restrictions in force
EPA's 2024 final rule under TSCA 6(a) restricts most commercial uses of methylene chloride and requires a Workplace Chemical Protection Program (WCPP) for permitted uses. The plan includes the WCPP crosswalk.
Pharmaceutical solvent — common exposure
DCM is widely used in pharmaceutical manufacturing as an extraction and reaction solvent. Pharma facilities are a primary audience for this plan.
Carbon monoxide metabolite
DCM is metabolised to carbon monoxide in the body; chronic exposure can produce CO-equivalent effects. The medical surveillance focuses on cardiovascular and CO-related effects.
What you receive
- Methylene Chloride Compliance Plan (Word .docx) — written program per (d)-(m)
- Initial exposure determination procedure (PEL: 25 ppm TWA / 125 ppm STEL; Action Level: 12.5 ppm)
- Air monitoring schedule (initial + periodic + change-triggered)
- Methods of compliance — engineering & work practice controls hierarchy
- Respiratory protection program crosswalk (with 1910.134)
- Medical surveillance protocol (PLHCP examination, blood/biological tests as applicable)
- Regulated area designation procedure (exposure that exceeds, or can reasonably be expected to exceed, the PEL or the STEL)
- Housekeeping and hygiene procedures
- Employee training outline (initial training, with retraining as necessary under 29 CFR 1910.1052(l)(5); any annual cycle is company policy)
- Recordkeeping requirements (exposure: 30 years; medical: employment + 30 years)
- STEL (Short-Term Exposure Limit) monitoring procedure
- EPA TSCA 6(a) Workplace Chemical Protection Program crosswalk (commercial restrictions)
How you get it
This document is written and reviewed against the standard it cites, and it is ready now. The download link is emailed as soon as your payment clears.
Revisions included — if something about your operation changes what the document should say, reply to the delivery email and we will amend it.
Who buys this
- Pharmaceutical manufacturing (DCM is a common solvent)
- Plastics manufacturing (polycarbonate production, foam blowing)
- Specialty coating and adhesive manufacturing
- Paint and coating removal from safety-critical, corrosion-sensitive aircraft and spacecraft components (the only paint-removal use EPA still permits)
- Solvent welding / bonding agent operations
- Aerospace manufacturing
Frequently asked
What's the difference between 1910.1052 and EPA's recent rules?
OSHA 1910.1052 has been in place since 1997 and sets workplace exposure limits (PEL, STEL, AL). EPA finalised TSCA 6(a) restrictions in 2024 that BAN most consumer and many commercial uses of methylene chloride, and require a Workplace Chemical Protection Program (WCPP) for the limited permitted commercial uses. The OSHA standard applies to remaining permitted uses; the EPA rule restricts WHICH uses are allowed.
Why does methylene chloride need a STEL?
DCM has acute neurotoxic effects (similar to alcohol intoxication) and metabolises to carbon monoxide. Short high-exposure peaks can cause acute symptoms (dizziness, headache, impaired coordination) that aren't captured by 8-hour TWA monitoring. The 125 ppm STEL (15-minute average) addresses the acute risk.
How does DCM produce carbon monoxide?
DCM is metabolised by cytochrome P450 2E1, producing CO as a metabolite. Exposed workers can have elevated COHb (carboxyhemoglobin) levels even without CO exposure — and the COHb persists longer than typical CO exposure because of ongoing DCM metabolism. Medical surveillance monitors for cardiovascular effects.
What's a WCPP under EPA TSCA?
Workplace Chemical Protection Program — required under EPA's 2024 TSCA 6(a) DCM rule for facilities continuing permitted commercial uses. The WCPP includes hazard communication, exposure limits substantially more stringent than OSHA’s — an ECEL of 2 ppm 8-hour TWA and a 16 ppm 15-minute EPA STEL under 40 CFR 751.109(c), against the OSHA PEL of 25 ppm and STEL of 125 ppm, exposure monitoring, hierarchy of controls, PPE, and recordkeeping. The plan includes the WCPP crosswalk so OSHA and TSCA compliance are aligned.
Is DCM still used in pharmaceutical manufacturing?
Yes — DCM remains a key solvent in pharmaceutical synthesis, extraction, and crystallisation. Pharmaceutical solvent use continues where it falls within a condition of use listed in 40 CFR 751.109(a) — typically processing as a reactant or as a processing aid — and then only under the WCPP. Pharma facilities continue to need 1910.1052 compliance plans, now layered with TSCA WCPP.