The Environmental Protection Agency (EPA) issued a final rule on May 15, 2019 that prohibits the manufacture (including import), processing, and distribution of methylene chloride in all paint and coating removers for consumer use. The rule also requires manufacturers (including importers), processors, and distributors, except for retailers, of methylene chloride for any use to provide downstream notification of the prohibitions throughout the supply chain; and requires limited recordkeeping.

These requirements for downstream notification and recordkeeping went into effect on August 26, 2019. The requirements that prohibit the manufacturing (including importing), processing, or distributing methylene chloride for use in consumer paints and coating removal become effective on November 22, 2019.

To help methylene chloride processors and distributors comply with the requirements, EPA has issued a compliance guide that includes:

  • A summary of the requirements of the final rule meant to address unreasonable risks from use of methylene chloride,
  • Definition of key terms,
  • Identification of regulated entities,
  • Description of required and/or prohibited activities, and
  • Summary of downstream notification and recordkeeping requirements.

Notification requirements include exact means of notification and text that must be provided to downstream entities. Recordkeeping requirements include records related to the downstream notifications provided, amounts of methylene chloride shipped and to whom the methylene chloride was shipped.

VBA Compliance can assist your facility in identifying the applicable requirements of the methylene chloride rule and developing or updating environmental management systems to address these new requirements. If you need assistance with EHS compliance assessments, determining EHS applicability or implementing EHS compliance programs, contact VBA today.