ACC Statement on EPA’s Proposed Methylene Chloride Rule
WASHINGTON (April 20, 2023) – Today, the American Chemistry Council (ACC) released the following statement in response to the U.S. Environmental Protection Agency (EPA’s) proposal to restrict uses of methylene chloride:
“Methylene chloride (CH2Cl2) is an essential compound used to produce many products and goods we rely upon every day.
“ACC is concerned that the proposed rule introduces regulatory uncertainty and confusion with existing Occupational Safety and Health Administration (OSHA) methylene chloride exposure limits. For this particular chemistry, EPA has not established the necessity to set an additional, independent, occupational exposure limit in addition to those already in place.
“In addition, we are concerned that EPA has not fully evaluated the supply chain impacts of its proposal. EPA’s website says most of these changes would be fully implemented in 15 months and would amount to a prohibition of an estimated 52% of annual production volume for end uses subject to TSCA. That scale of reduction in production, that rapidly, could have substantial supply chain impacts if manufacturers have contractual obligations they need to follow through on or if manufacturers decide to cease production entirely.
“These sorts of ripple effects could impact critical uses, including pharmaceutical supply chains and the specific safety-critical, corrosion-sensitive critical uses identified by EPA. These unintended but potentially serious consequences should be carefully and thoroughly evaluated by EPA.
“Where occupational exposures presenting unreasonable risk can be appropriately managed with robust workplace safety programs, these are better regulatory options that EPA should reconsider.”
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