Download PDF
April 27, 2023

Richard E. Engler, Ph.D., Quoted by Chemical Watch in Article “Mixed reception for workplace requirements in proposed TSCA methylene chloride rule”

Bergeson & Campbell, P.C.

On April 27, 2023, Chemical Watch quoted Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®), regarding the proposed TSCA risk management rule that would ban all consumer uses and most commercial applications of methylene chloride. For ten continuing uses, the agency outlined a new workplace chemical protection programme (WCCP) requiring adherence to exposure limits well below those set by the U.S. Occupational Safety and Health Administration (OSHA) and the EU’s occupational exposure limit values. 

Richard Engler, director of chemistry at law firm Bergeson & Campbell said more “sophisticated facilities that already manage exposures well will probably not have difficulty complying with the existing chemical exposure limits (Ecel)”. But “less sophisticated facilities may struggle” to meet the lower limits, he said. 


The EPA’s proposed rule highlights how workplace requirements could take shape for four other solvents with pending risk management rules. Last year, the agency published Ecels for methylene chloride (2ppm) as well as carbon tetrachloride (0.03ppm); 1-bromopropane (1-BP) (0.05ppm); perchloroethylene (Perc) (0.14 ppm); and trichloroethylene (TCE) (1.1ppb). 

Bergeson & Campbell’s Engler said most of these suggested Ecels are “significantly lower” than other workplace exposure limits. However, he added, “not all are on as solid scientific ground as the methylene chloride Ecel”.  

In a 25 April blog, the law firm encouraged parties to review the methylene chloride proposal even if they do not use the solvent. 

Companies using chemicals that could be subject to TSCA risk management rules in the future “should prepare for forthcoming prohibitions, WCPPs, or time-limited exemptions that require compliance with WCPPs”, Bergson and Campbell said. 

See – (subscription required)