Business News

The IH Blog: Extended Deadlines for EPA’s Methylene Chloride (MeCl₂) ECEL

Posted on by Maria Villamizar
20
Nov

Key Considerations for Industrial Hygienists

Earlier this year, we outlined the significant changes introduced by the Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA) for methylene chloride (MeCl₂). The reduction of the 8-hour exposure limit from OSHA’s 25 PPM permissible exposure limit (PEL) to the EPA’s 2 PPM Existing Chemical Exposure Limit (ECEL) remains one of the most substantial regulatory shifts affecting solvent-handling industries.

In response to stakeholder feedback, the EPA has now issued extended compliance deadlines. These extensions provide additional time for planning, but the analytical and operational challenges of meeting the 2 PPM ECEL remain significant. Facilities that use MeCl₂ will need strong monitoring programs, validated test methods, and reliable laboratory support to achieve and maintain compliance.

Revised MeCl₂ Compliance Timeline

Initial Monitoring: Extended to November 2026
Regulated Areas + ECEL Compliance: Extended to February 2027
Full EPA Compliance (including exposure control plans): Extended to May 2027

Although the timing is more flexible, the technical bar has not changed. The EPA’s 2 PPM ECEL is more than 2x lower than OSHA’s PEL, and the short-term exposure limit (STEL) of 16 PPM is far below OSHA’s 125 PPM STEL. As a result, previously compliant processes may now require new engineering controls, task modifications, or enhanced monitoring.

Industrial Hygiene Considerations

Even with extended deadlines, it is essential for IH teams to begin planning:

  • Evaluate high-exposure tasks such as stripping, cleaning, and solvent transfers
  • Verify sampling plans meet EPA’s minimum volume requirements, including collecting at least 2.5 L of air for 8-hour TWAs
  • Prepare for iterative monitoring, as many facilities will require multiple rounds of sampling to achieve the 2 PPM limit
  • Plan ahead for analytical capacity, especially as 2026 approaches and demand increases

How SGS Can Help

The reduction in exposure limits represents a significant challenge for industries using MeCl₂ but SGS is positioned to support every stage of the compliance process.

With decades of experience in occupational air monitoring and one of the largest networks of industrial hygiene laboratories in North America, SGS provides:

Validated Analytical Methods

We use NIOSH 1005, a proven and EPA-aligned method for MeCl₂ monitoring. This method supports the required sample volumes and detection limits necessary to demonstrate compliance with the 2 PPM ECEL and 16 PPM STEL.

Expert Guidance on Sampling Strategy

Our experts can help you:

  • Select appropriate media and flow rates
  • Plan for long-term TWA and short-term (STEL) sampling
  • Ensure proper handling, documentation, and chain-of-custody procedures

We regularly support complex sampling programs for facilities with variable tasks, multi-shift operations, and high-traffic production areas.

Reliable, High-Confidence Data

Achieving compliance with the 2 PPM ECEL requires laboratory precision and low reporting limits. SGS provides:

  • Sensitive detection capabilities
  • Consistent turnaround times
  • Support for large-scale, multi-site monitoring campaigns

Our technical teams are available to interpret results and help IH professionals understand trends, data variability, and potential control needs.

Support From Planning Through Compliance

From initial monitoring to post-control verification, SGS can assist in evaluating whether implemented engineering or administrative changes are effectively reducing exposure. Many clients rely on SGS to conduct repeat sampling as controls mature or work practices evolve.

Moving Forward

The EPA’s extended deadlines provide valuable breathing room, but they also underscore the need for proactive planning. The 2 PPM ECEL is achievable, but not without careful sampling strategy, high-quality analytical support, and close coordination between industrial hygienists and their laboratories.

SGS is ready to support your compliance efforts with the technical depth, sensitivity, and experience needed to confidently meet the updated TSCA requirements.

Contact our award-winning Client Service Representatives in a number of different ways: