Amalawa Aiwekhoe

Title: Responding to the EPA's Final ruling on methylene chloride in the aerospace industry

Abstract:

Starting July 8th, 2024, the Environmental Protection Agency (EPA) implemented a finalruling to mitigate the unreasonable risk of injury associated with methylene chloride throughseveral key measures. The aerospace industry, which utilizes this chemical for various processes,has been granted conditional allowed uses. Among the 13 permitted uses, one includes theindustrial and commercial application as a paint and coating remover for safety-critical,corrosion-sensitive components of aircraft and spacecraft. Aerospace companies that continue touse methylene chloride in an approved manner will be required to develop a WorkplaceChemical Protection Program (WCPP). This review provides a comprehensive approach for theaerospace industry to comply with the regulatory requirements, leveraging my experience in thefield. It involves analyzing the aspects of meeting the EPA requirements and creating a WCPPtailored to the aerospace industry. The review details the specific characteristics and applicationsof methylene chloride within the aerospace industry. It outlines the plan to develop a WCPP formy workplace, incorporating both quantitative and qualitative analyses of methods and specifictasks. By integrating these elements, a compliance plan for the EPA’s final ruling on methylenechloride is formulated, ensuring that the WCPP framework meets all regulatory requirements.