Why Is Methylene Chloride Regulated?
Besway's Step-By-Step Compliance Assessment Process
Why Is Methylene Chloride Regulated?
Needless to say, there has been a great deal of controversy regarding
the use of methylene chloride in industry. The bottom line is
that methylene chloride remains the most effective and efficient
means of commercially removing the widest variety of coatings
from wood and several other substrates. Also, studies of actual
human beings chronically exposed to methylene chloride at 250
ppm for 7.5 hours per day demonstrated no increased risk of cancer
due to exposure to methylene chloride in the workplace. One of
these studies was conducted over a 20 year period. However, a
study of mice conducted over 2 years by the National Toxicology
Program (NTP) showed development of liver and lung tumors at exposures
of 2000 ppm and higher. As a result, OSHA has classified methylene
chloride as a carcinogen.
Methylene chloride has long been known to have negative effects
on the central nervous system and concentrations between 900-1000
ppm can cause dizziness. Concentrations above 2000 ppm can result
in headaches, nausea, and vomiting. Concentrations over 7000 ppm
may result in tingling in arms and legs and rapid heartbeat and
concentrations over 9000 ppm may result in loss of consciouness
or death.
Obviously, methylene chloride is a potentially dangerous chemical
that must be treated with great care and respect as one should
do with any chemical that is used. No doubt about it, methylene
chloride is probably one of the most thoroughly reviewed and researched
chemicals on the market. When we deal with methylene chloride
at least we know what we are dealing with!
OSHA has a published standard for businesses using methylene chloride.
This standard can be found in the Federal Code of Regulations
under 29 CFR 1910.1052 Subpart Z.
Keep in mind that businesses with one or more employees must comply
with OSHA regulations. Sole proprietorships or partnerships with
no employees other than the business owners are not subject
to these regulations.
The OSHA methylene chloride standard has 7 basic provisions (please
review the actual standard to ensure compliance with all of its
provisions):
There are 3 exposure levels that OSHA has determined as limits
for exposures. The above provisions are triggered at different
exposure levels.
The 3 exposure levels are as follows:
Since April 10, 1998, all employers using methylene chloride have
been required to have an exposure monitoring program. This program
is required to determine the level of exposure of employees to
methylene chloride. Employers must monitor for an 8 hour period
and for a 15 minute period. One employee may be monitored and
the results applied to the entire workforce as long as all the
employees work under similar conditions and in the same work area
as the monitored employee.
Depending on the results of the initial monitoring, additional
monitoring may be required on a regular basis of every three or
six months. Monitoring must also be conducted anytime a change
in the workplace or in work practices affects exposure to methylene
chloride.
Besway has a monitoring product that meets the OSHA requirements
for methylene chloride monitoring. Call 1-800-251-4166 for more
information.
Since April 10, 1998, all employers using methylene chloride have
been required to have a medical monitoring program. If a business
has employees that may be exposed to more than 12.5 ppm of methylene
chloride for more than 30 days or more than 25 ppm of methylene
chloride for more than 10 days, then the business must offer those
employees medical monitoring by a licensed health care practitioner.
Monitoring is required annually for employees 45 years or older
and every three years for employees younger than 45 years old.
Since April 10, 1998, employers have been required to provide
respirators to employees who may be exposed to more than 25 ppm.
CARTRIDGE RESPIRATORS MAY NOT BE USED since methylene chloride
breaks through the filters at a very rapid rate. Besway recommends
using a fresh air-supplied respirator. Call for more information
to order one from Besway. Employers who provide any type of respirator
to employees are also required to be in compliance with OSHA's
Respiratory Protection Standard which includes respirator fit
testing and written approval from a licensed health care practitioner.
After April 10, 2000, respirators can only be used after employers
have implemented engineering controls for reducing exposure to
methylene chloride.
As of April 10, 2000, employers are required to control employee
exposure to methylene chloride by using engineering controls.
These may include improved general ventilation of the exposure
area and/or exhaust systems that are mounted on stripping trays
or tanks. Any engineering control may be used that reduces exposure
to 25 ppm or as close to it as possible. OSHA does allow continued
use of respirators for businesses that are unable to meet 25 ppm
even with engineering controls. However, the most economically
feasible engineering controls for the business must be used. Respirators
by themselves will not achieve compliance with this provision
of the standard and may be used only after implementing feasible
and economical engineering controls. Contact Besway for more information
on shop ventilation systems and tray exhaust systems.
Businesses that have exposures to methylene chloride above the
25 ppm PEL and/or the 125 ppm STEL are required to mark the areas
where these exposures occur. Access to these areas must be limited
only to those employees who work in these areas. Proper engineering
controls and respirators must be provided. These areas must be
marked so that all employees recognize them as regulated areas.
Businesses covered by these regulations must train their employees
on the health hazards of methylene chloride and the proper work-practices
and use of safety equipment (such as respirators) to protect themselves.
This training must be conducted in addition to the training required
by the OSHA Hazard Communication Standard.
All documentation relating to methylene chloride exposure monitoring,
employee medical monitoring, and employee training must be maintained
and be available to employees and/or OSHA on request. Documentation
of compliance with these provisions is required.
Besway recommends several different approaches to complying with
this standard. For one thing, compliance can be achieved. There
is no reason to let OSHA intimidate you out of your business.
One approach is to specialize in furniture stripping
as a sole proprietor or partnership business. This means the OSHA
regulation will not apply to your business but it also means that
you will be unable to hire any employees to grow your business
without becoming subject to OSHA regulations.
A second approach if you have employees is to subcontract
your stripping projects to a sole proprietor or partnership that
specializes in furniture stripping. This keeps methylene chloride
out of your shop and away from your employees.
A third approach is to locate your stripping operations
in a location separate from your other work activities. This approach
reduces the number of employees exposed to methylene chloride
and also decreases the amount of space that you may have to ventilate.
All shops are different in how they are set up and the in the
techniques that they use. Therefore what works for one shop to
comply may not work for another one. In most cases, businesses
that are regulated by this rule will have to use a combination
of engineering controls and respirators. Once you have done your
initial monitoring you will know where you need to start.
OSHA has indicated that they do not intend to begin a vast inspection
program of businesses that use methylene chloride. There are normally
only three reasons which may cause your business to be inspected
by OSHA. One reason may be by random selection. This is highly
unlikely for most small businesses but not impossible. A second
reason may be for an unusually high rate of accidents at your
shop. If you run a safe operation you shouldn't have to worry
about this. The third, and most likely reason for an OSHA
inspection, is when OSHA has received a complaint directly against
your business.
Besway continues to be very active in keeping up with changes
in regulations which effect our industry and in developing solutions
to help our customers comply with these regulations. The methylene
chloride rules are not the only OSHA rules that apply to your
business but they are among the most important. Besway cannot
guarantee your compliance with these regulations but we commit
to do our best to assist you. Please call us at 1-800-251-4166
for more information.
Besway's Step-By-Step Compliance Assessment Process
Without a doubt this is a lot to consider! Just remember that
you are not alone - Besway can and is willing to help. Call us
at 1-800-251-4166 or email Ray or John.