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May 1, 2024

Lynn L. Bergeson Quoted in Chemical Processing Article “EPA Finalizes Methylene Chloride Ban”

Bergeson & Campbell, P.C.

On April 30, 2024, comments by Lynn L. Bergeson were featured in Chemical Processing’s article on a recent Methylene Chloride ban.

The public-comment period on the proposed ruling appears to have influenced the EPA’s decision to allow some uses of methylene chloride, including plastics and rubber manufacturing, said CP regulatory columnist Lynn Bergeson, a managing partner with Bergeson & Campbell P.C. 

“The submitted monitoring data demonstrated for several uses that EPA’s proposal to prohibit specific conditions of use was not necessary because the data satisfied EPA’s initial concerns about compliance with its workplace chemical protection program (WCPP, including the existing chemical exposure limit of 2 ppm as an 8-hour time-weighted average),” said Bergeson in an email response to Chemical Processing

The agency also extended the timeframes for initial monitoring and full implementation of the workplace monitoring program for operaitons that received an exemption for some uses, Bergeson noted. 

But the ruling will leave many users of methylene chloride looking for alternatives.

“EPA finalized its proposal to prohibit the manufacture, processing and distribution of methylene chloride for all consumer use,” Bergeson said. “In my view, this was expected and warranted, given the hazard concerns and limited options for controlling consumer exposures. Overall, not all stakeholders will be happy with EPA’s final rule, but it does underscore the importance of providing data/information to EPA as early as possible to avoid or minimize supply chain disruptions.”

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