Hazard Communication & Methylene Chloride

By Rennee Karlik, Regulatory Compliance Specialist

Methylene chloride is used in a variety of industrial processes and present in a wide range of products including paint strippers/removers, adhesives, lubricants, cleaners, degreasers, sealants, automotive care and welding aids.  The dangers of methylene chloride have garnered a lot of attention due to fatalities resulting from both consumer and occupational use of products containing the substance.  The high number of acute fatalities due to methylene chloride exposure led to action by the U.S. Environmental Protection Agency (EPA) to ban the manufacture, processing and distribution of methylene chloride in consumer products after November of 2019.

Methylene Chloride Exposure

Methylene chloride exposure can result in both acute and chronic health effects as described in the following excerpt from the NIOSH overview.

Methylene chloride (CH2Cl2) is a colorless liquid that can harm the eyes, skin, liver, and heart. Exposure can cause drowsiness, dizziness, numbness and tingling limbs, and nausea. It may cause cancer. Severe exposure can cause loss of consciousness and death.” 

The dangers of acute exposure to methylene chloride are amplified due to the volatility and metabolism of the substance.  Methylene chloride readily vaporizes to reach toxic levels.  In confined spaces or without adequate ventilation, rapid asphyxiation is a real danger as fumes displace oxygen.  The metabolism of methylene chloride to carbon monoxide results in an elevation of carboxyhemoglobin levels and a decrease in the oxygen-carrying capacity of the blood. The Carboxyhemoglobin levels may continue to rise for several hours after exposure has ceased, resulting in a delay of symptoms.

Preventing Exposure Risks

Most occupational and consumer fatalities due to methylene chloride exposure are a result of use in confined spaces or without adequate ventilation. The failure to adequately convey the hazards of methylene chloride exposure is partially responsible for this tragic loss of life.  Often, the user was not equipped with knowledge of the hazards, the absolute need for ventilation and the use of personal protective equipment to prevent exposure.

Most Safety Data Sheets for products containing methylene chloride still fail to fully disclose the hazards of methylene chloride, signs and symptoms of exposure, appropriate first aid measures and ventilation and personal protection requirements.

Hazard Communication Requirements for Methylene Chloride

Many manufacturers, suppliers, and distributors are not aware of the requirements set forth in OSHA’s methylene chloride standard (29 CFR 1910.1052(k)) for labels and safety data sheets.  Specifically, “In classifying the hazards of methylene chloride at least the following hazards are to be addressed: Cancer, cardiac effects (including elevation of carboxyhemoglobin), central nervous system effects, liver effects, and skin and eye irritation.” 1910.1052(k)(1)(ii)

Manufacturers, suppliers and distributors of products containing methylene chloride should ensure that product safety data sheets contain all pertinent hazard information and how to prevent exposure through ventilation and personal protective equipment.  They should also warn of delayed symptoms of exposure and protection of the first aid provider.

Rebranded Methylene Chloride Products

Many products containing methylene chloride are rebranded for sale or distribution in the US.  The practice of using the original manufacturer’s safety data sheet for the newly branded products is also common, but particularly risky for such products.  If the SDS is recycled in this way, the new supplier is now responsible for the accuracy of the SDS and any product hazard classifications.

The heavy burden of protecting the worker is placed on the company with their name on the SDS.  It is definitely “risky business” to assume the accuracy of such a document that serves as the first line of defense in the protection of workers. The consequences of not fact-checking a manufacturer’s safety data sheet before adopting it as your own may result in the failure to inform and protect workers from significant adverse health effects and even the loss of life.

If your products contain Methylene Chloride, it’s time to double-check your hazard communication to ensure you are classifying correctly and protecting your workers. Let GSM take the burden off of your team. Our compliance experts can help ensure your safety data sheets and labels are up to date and compliant.