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Case Study 5: Regulating methylene chloride: a cautionary tale about setting health standards one chemical at a time

By Molly M. Jacobs, Joel Tickner, and David Kriebel

[Download PDF] 19 pages

OSHA’s chemical-by-chemical risk-based standard setting process is so slow that years can go by between the time that it is clear that workers are being dangerously over-exposed and the time that effective controls are put into place.

The tortured path to OSHA’s methylene chloride standard is a potent illustration of the limits of the current standard-setting process.

NIOSH estimates 20,000 cancer deaths and 40,000 new cases of cancer per year can be attributed to exposures at work.

By focusing the debate on the narrow question of exactly how risky a specific exposure level might be, OSHA and its risk-based standard setting process distracts attention from the more important questions: do we need this chemical at all? Are there alternatives that are safer?

In the case of methylene chloride, the risk debate allowed some employers to shift from methylene chloride to an untested, unregulated substitute chemical—1-bromopropane—which turned out to be a neurotoxicant, a reproductive toxicant, and possibly a more potent carcinogen than methylene chloride. 

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