The DCM regulation mandates all groups that use DCM shall develop and implement an ECP. For consistency with existing documentation, the University will refer to the ECP as a Standard Operating Procedure (SOP) throughout this document. The SOP documents the approved tasks, exposure controls and how they are applied to reduce inhalation exposures of DCM at or below the ECEL and EPA STEL. The group supervisor (PI or Manager) is responsible for the development, implementation, compliance, and maintenance of the SOP. Supervisors shall use the Methylene Chloride SOP template developed by HSRM. 

The SOP shall describe what procedures are performed in the work area and constructed to show how the hierarchy of controls are applied to reduce inhalation exposure at or below the ECEL and EPA STEL, as well as preventing dermal exposure. The hierarchy of controls is a method of determining which actions should be taken to effectively reduce or remove workplace hazards by identifying the preferred order of exposure controls. These controls in order of most effective to least effective are Elimination, Substitution, Engineering Controls, Administrative Controls, and PPE. Describe the regulated area (if applicable) and how access is controlled. Procedures for spill response and waste disposal should also be included.   

Describe any efforts to eliminate DCM used and justify why it could not be substituted by a less hazardous solvent (e.g. polarity, density, established protocol, etc.). A list of less hazardous solvents that were considered may be included. 

Appropriate engineering control may include, but are not limited to: 

• Work with open containers of methylene chloride should be conducted only in a fume hood, glovebox, or other containment device.
• Operations outside the fume hood or glove box must be vetted through exposure monitoring. 
• Installing localized ventilation for equipment that cannot be moved into the fume hood (automated chromatography machines or rotovap). 
• Vent vacuum pump exhaust into the fume hood. 

Administrative controls may include, but are not limited to: 

• Designate and label areas where DCM may be used.
• Keep containers closed as much as possible, especially during transport outside of engineering controls (e.g. stopper round-bottom flasks during transport to rotovap). 
• Use the smallest possible quantities for the task. 
• Purchase smaller containers (e.g. substitute kegs for 4 L or 1 L bottles).
• Do not store squeeze bottles on the benchtop or consider eliminating them all together.
• Include SOP in annual lab-specific training.