HAZMAT Safety Information

In 2024, The Environmental Protection Agency (EPA) finalized a rule under the Toxic Substances Control Act (TSCA) to mitigate the "unreasonable risk of injury to health" of methylene chloride (also known as methylene dichloride, methane dichloride, dichloromethane, and DCM; CAS # 75-09-2), a hazardous chemical known to cause several kinds of cancer as well as other health hazards. 

This EPA ruling does not ban the use of DCM in research labs, but will have impose stricter guidelines for labs that will continue their work with the material.

The following form is required for any NMT researcher/ lab personnel or employee who has used DCM in the past two years in a NMT facility, is currently using DCM, or is planning on using DCM. It is imperative that any laboratory containing this chemical reports it to Research Compliance and Safety no later than December 20, 2024 using the form available here: Dichloromethane Usage Survey.

While this rule will not completely ban the use of methylene chloride in research settings, and labs will still be permitted to use methylene chloride, any lab on campus that will continue using this chemical will be required to have a Workplace Chemical Protection Program (WCPP) in place. Research Compliance and Safety will work with labs and/or facilities using DCM to develop a WCPP document in order to comply with the new EPA regulations. One important mandate of any WCPP is that it requires exposure threshold monitoring for any "potentially exposed persons". Research Compliance and Safety will guide NMT researchers to ensure that monitoring is performed as required by this rule. To put this change into perspective, the OSHA 8-hour Time Weighted Average exposure limit for DCM was 25ppm, while the new EPA rule has a exposure limit of 2ppm. The odor threshold for DCM is between 25ppm and 320ppm, meaning if you can smell it, you are well above the exposure limit of the new EPA rule.

In the heirarchy of controls, the two most effective means of reducing hazards in the workplace by far are Elimination and Substitution. 

• Elimination is the most effective method, which completely removes the hazard.
• Substitution is less effective than elimination, but can increase overall safety by using less harmful substances in its place.

In order to protect NMT students and employees, it is the official recommendation of NMT Research Compliance and Safety that NMT labs that currently utilize DCM in their labs plan on either eliminating the use of DCM in their research where possible, or substituting DCM for other less harmful chemicals wherever possible.

Below is the current timeline for this new rule. I will provide further updates on timelines, monitoring, and other requirements as more information is available in this rapidly developing situation. 

 

Required Actions	EPA Deadline	Target Dates for NMT Research Compliance
Submit Dichloromethane Usage Survey	N/A	December 20, 2025
Initial Exposure Control Monitoring	May 5th, 2025	January 2025 to April 1st, 2025
NMT Determines PPE and Provides Training	August 1st, 2025 (or within 3 months of Initial Monitoring results)	January 2025 to August 1st 2025
NMT Updates Chemical Hygiene Plan with WCPP inclusion	October 30th, 2025	January 2025 to October 2025

New Mexico Tech Research Compliance and Safety needs your help to ensure compliance with this new ruling! 

1. If your lab has DCM that is no longer in use, please submit a Chemical Hazardous Waste Pick Up Request form (below) to hazmat@nmt.edu at your earliest convenience. When the pick up is completed, please remove the DCM from your chemical inventory to reflect its disposal. 

2. If your lab or facility has any paint removers, paint strippers, spray paints, automotive cleaners, adhesives, and varnish removers, you will need to check any of these items in their inventory list DCM is an ingredient, as DCM is commonly used in these types of products. Please submit a Chemical Hazardous Waste Pick Up Request form (below) to hazmat@nmt.edu for any of these products that contain DCM. 

3. If your lab is currently using DCM for the following applications, you need to know that these applications are prohibited under the TSCA final ruling: paint, paint strippers in arts, coating removers, metal aerosols, and aerosol degreasing. Please note that the use of DCM in facilities for non-laboratory purposes is prohibited unless the use is specifically exempted by the EPA final rule. 

Thank you for your cooperation and your attention to the safety of students, staff and faculty at NMT. Please ensure prompt reporting using the DCM Usage Survey to avoid violating the EPA rule and any associated corrective action.

The following links provide information on methylene chloride and how research and academic laboratories will be affected by the new ruling. This information is also available in Appendix M of the most recent NMT Lab Safety Manual. 

• New Jersey Department of Health Right to Know Hazardous Substance Fact Sheet

• NIOSH Methylene Chloride Hazards for Bathtub Refinishers

• A Guide to Complying With the 2024 Methylene Chloride Regulation Under the Toxic Substances Control Act (TSCA)

• Methylene Chloride Safety Data Sheet (SDS)

• How the EPA Ban of Methylene Chloride Will Impact Laboratories

• What the Dichloromethane Ban Might Mean for University Labs in the US

• Federal Register Methylene Chloride; Regulation Under the Toxic Substances Control Act (TSCA)

• Final Risk Evaluation for Methylene Chloride

• What Does the New EPA Methylene Chloride Rule Mean for Academic Labs?

• Biden-Harris Administration Finalizes Ban on Most Uses of Methylene Chloride, Protecting Workers and Communities from Fatal Exposure

 

NMT Laboratory Safety Manual (2024 Update)

NMT 2024-2025 Chemical Hygiene Plan

Risk Assessment: Recognize, Assess, Minimize, Prepare (RAMP)

Electrical Safety

Building a Safety Culture at NMT

Laboratory Safety Review Checklist 

Laboratory Self Evaluation Checklist

Laboratory Safety Review Scheduling Form

List of Particularly Hazardous Substances

List of Peroxide Forming Chemicals

NMT Laboratory Close-Out Procedures 

NMT Laboratory Close-Out Survey

NMT Laboratory Close-Out Checklist

Hazardous waste is any waste with properties that can be harmful to human health or the environment. These can include materials that are ignitable, corrosive, reactive, and/or toxic.

Hazardous Wastes can be in solid, liquid, or gaseous states. 

Importantly, there are many federal and state regulations that apply to the handling and disposal of any waste that is considered hazardous. Hazardous waste is prohibited from final disposal at a Landfill.

There are several types of Hazardous Waste, including:

• Unregulated household hazardous waste
• Resource Conservation And Recovery Act (RCRA) regulated hazardous waste
  • Listed Waste:
    • F & K Listed Waste
    • P & U Listed Waste
  • Characteristic Waste
    • Ignitability 
    • Corrosivity
    • Reactivity
    • Toxicity
  • Mixed Radiological Wastes

More information about Listed, Characteristic, and Mixed Radiological Wastes are available here: https://www.epa.gov/hw/defining-hazardous-waste-listed-characteristic-and-mixed-radiological-wastes 

"Universal waste" is a term for hazardous waste that are widely produced both in residences and in industries. Universal Wastes have more relaxed rules and regulations than other hazardous waste streams, but special care is still required for disposal, as these materials cannot be discarded as regular trash in which the final disposal is at a landfill.

Universal Waste only requires having a date and the words "Universal Waste" on the item. They also need to be stored in such a manner that will prevent breakage and leaking of the hazardous materials inside of them. If a universal waste item breaks or leaks, it becomes regular hazardous waste, and must be labeled, handled, and treated as hazardous waste. 

Common materials that are considered Universal Waste are: 

• Batteries
• Florescent Lamps
• Mercury Thermostats and other Mercury Containing Equipment (MCEs)
• Electronic Devices
• Cathode Ray Tubes (CRTs)
• CRT Glass
• Aerosol Cans
• Pesticides
• Used Oil (Please note: if Used Oil is contaminated with any amount of other hazardous chemical, it becomes regular hazardous waste).

For more information on Universal Waste, please visit the EPA's Universal Waste Webpage.

From the EPA's Radioactive Waste Webpage:

"Radioactive waste is generated as a by-product of producing or using radioactive materials by industries such as mining, nuclear power generation, defense, medicine, and certain types of scientific research."

As defined in the United States, there are five general categories of radioactive waste:

High-level waste: High-level waste includes used nuclear fuel from nuclear reactors and waste generated from the reprocessing of spent nuclear fuel. Although defense-related activities generate most of the United States’ liquid high-level waste, the majority of spent nuclear fuel is from commercial nuclear power plant reactors. Currently, most high-level waste is stored at the site where the waste was generated.

Transuranic waste: Transuranic wastes refer to man-made radioactive elements that have an atomic number of 92 (uranium) or higher. Most of the transuranic waste in the United States is from nuclear weapons production facilities. This waste includes common items such as rags, tools, and laboratory equipment contaminated during the early age of nuclear weapons research and development. Transuranic waste is currently being stored at several federal facilities across the country. Transuranic waste created as part of a defense program will ultimately be disposed of at the Waste Isolation Pilot Plant (WIPP) in New Mexico, which began accepting waste in 1999.

Uranium or thorium mill tailings: Mill tailings are radioactive wastes that remain after the mining and milling of uranium or thorium ore. Mill tailings are stored at the production-sites in specially designed ponds called impoundments.

Low-level waste: Low-level waste is radioactively contaminated industrial or research waste that is not high-level waste, transuranic waste,  or uranium or thorium mill tailings. Much of this waste looks like common items such as paper, rags, plastic bags, protective clothing, cardboard, and packaging material. These items are considered waste once they come into contact with radioactive materials. Low-level waste can be generated by any industry using radioactive material, including government, utility, manufacture, medical and research facilities. There are disposal facilities that specialize in the near-surface disposal of low-level waste.

Hazardous Waste Pick Up & Hazardous Waste Label Instructions 

Chemical Waste Pick Up Request Form (Form Fillable PDF)

Universal Waste Pick Up Request Form (Form Fillable PDF)

Radioactive Waste Pick up Request Form (Form Fillable PDF)

Satellite Accumulation Areas are areas designated where hazardous waste can be temporarilly stored.

Important Storage requirements include: 

• Location: The SAA must be at or near the point of generation (i.e. it has to be in the same lab space that the waste is first generated). 
  • Please note: Hazardous Waste in one SAA cannot be relocated to another SAA.
• Access: General access to the hazardous waste must be restricted.
• Waste Control: Hazardous waste within the SAA must be properly capped, labeled, and remain under the control of the generator at all times.

Satellite Accumulation Area Regulations 

Printable Satellite Accumulation Area Signage for Accumulation Sites (Updated 2024)

While most empty chemical containers can go in the regular trash, it is generally the best practice to avoid disposing empty containers as regular trash. As such, Research Compliance will take in empty containers as part of our regular hazardous waste pick up services.

If you choose not to use Research Compliance's services for empty containers, the following guidelines MUST BE implemented to prevent placing prohibited items in garbage destined for disposal at a landfill.

Ask the following questions to determine if your container can be discarded in regular waste streams:

1. Did the container hold any P-Listed Waste (click here and scroll down to find the P-List)? 
   • YES: Do not discard. Submit a Hazardous Chemical Pick Up Request Form to hazmat@nmt.edu 
   • NO: Continue to question 2.
2. Can you reuse the container for a compatible waste stream?
   
   • YES: Do not discard, reuse container for hazardous waste that shares the same characteristics. Please note that an incompatible material cannot be placed in the empty container. For example, an empty Hydrochloric Acid container should not be used to store Ammonium Hydroxide waste.
   • NO: continue to question 3.
3. Is the container "RCRA Empty" (see below for a definition of "RCRA Empty")?
   
   • YES: You may discard the container in the regular trash. Remove the cap and discard seperately. If the container is glass, place in a cardboard box and label the box "Broken Glass" before discarding.
   • NO: Do not discard. Submit a Hazardous Chemical Pick Up Request Form to hazmat@nmt.edu

* A container or an inner liner removed from a container holding nonacute hazardous waste as identified in Part 261, Subpart D, is empty when:

• all wastes have been removed using practices commonly employed industry-wide to remove wastes from containers or liners, such as pouring, pumping, aspirating, and draining
  (§261.7(b)(1)(i)), and
• no more than 2.5 centimeters (1 inch) of material remains in the container or liner (§261.7(b)(1)(ii)), or
• no more than 3 percent by weight of the container remains for containers with a capacity of 110 gallons or less, and no more than 0.3 percent by weight remains for containers with a
  capacity greater than 110 gallons (§261.7(b)(1)(iii)). 
• See https://www.epa.gov/sites/default/files/2015-07/documents/cont05.pdf (p. 12) for more information on "RCRA Empty" containers.

Information on NFPA 704 Hazard Identification System 

Printable NFPA Diamond For Lab Door Exteriors

Hazard Assessment Signage (HAS) for Laboratory Door Exteriors