According to the company’s website press release on April 20, 2023, the American Chemistry Council (ACC) released the following statement in response to the U.S. Environmental Protection Agency (EPA’s) proposal to restrict uses of methylene chloride:
“Methylene chloride (CH2Cl2) is an essential compound used to produce many products and goods we rely upon every day.
“ACC is concerned that the proposed rule introduces regulatory uncertainty and confusion with existing Occupational Safety and Health Administration (OSHA) methylene chloride exposure limits. For this particular chemistry, EPA has not established the necessity to set an additional, independent, occupational exposure limit in addition to those already in place.
“In addition, we are concerned that EPA has not fully evaluated the supply chain impacts of its proposal. EPA’s website says most of these changes would be fully implemented in 15 months and would amount to a prohibition of an estimated 52% of annual production volume for end uses subject to TSCA. That scale of reduction in production, that rapidly, could have substantial supply chain impacts if manufacturers have contractual obligations they need to follow through on or if manufacturers decide to cease production entirely.
“These sorts of ripple effects could impact critical uses, including pharmaceutical supply chains and the specific safety-critical, corrosion-sensitive critical uses identified by EPA. These unintended but potentially serious consequences should be carefully and thoroughly evaluated by EPA.
“Where occupational exposures presenting unreasonable risk can be appropriately managed with robust workplace safety programs, these are better regulatory options that EPA should reconsider.”
American Chemistry Council
The American Chemistry Council (ACC) represents the leading companies engaged in the multibillion-dollar business of chemistry. ACC members apply the science of chemistry to make innovative products, technologies and services that make people's lives better, healthier and safer. ACC is committed to improved environmental, health, safety and security performance through Responsible Care®; common sense advocacy addressing major public policy issues; and health and environmental research and product testing. ACC members and chemistry companies are among the largest investors in research and development, and are advancing products, processes and technologies to address climate change, enhance air and water quality, and progress toward a more sustainable, circular economy.
