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On September 15, 2026, the Fifth Circuit vacated EPA's 2024 methylene chloride rule and its 2 ppm workplace limit. What remains for employers is OSHA's standard, in force since 1997: 25 ppm over 8 hours and 125 ppm over 15 minutes. HazComFast read every methylene chloride result OSHA's laboratory has published since 1984 and every citation under the standard since 1997. Since the standard took effect, OSHA took 5,883 personal samples in 955 inspections. Of those, 309 prove on their own an 8-hour exposure above 25 ppm, and 634 a 15-minute exposure above 125 ppm.
Samples reported through August 25, 2026 · citations extracted October 14, 2026 · by HazComFast · method and limits below
Have lab results in hand? The calculator on this page gives the 8-hour TWA, the worst 15 minutes the samples prove, the Table 1 monitoring row and what follows from it.
In East Fork Enterprises, Inc. v. EPA, Nos. 24-60227 and 24-60256, a Fifth Circuit panel ruled on the petitions against EPA's May 2024 methylene chloride rule, 89 FR 39254. The rule had banned most uses and put the uses it kept under a Workplace Chemical Protection Program with its own exposure limits. Three passages of the opinion matter on the shop floor.
"For the foregoing reasons, we GRANT the Industry's Petitioners' petition for review, VACATE the challenged rule and associated risk determination, DENY the Sierra Club's petition for review, and REMAND to EPA for proceedings consistent with this opinion." Opinion, p. 44
"EPA published a final rule (not challenged here) in March 2019 that prohibited the manufacturing, processing, and distribution of MC solely for purposes of consumer paint and coating removal." Opinion, p. 6
"In contrast, since 1997, OSHA has enforced MC exposure limits almost ten times greater: 125 ppm for "acute" exposure and 25 ppm for "chronic" exposure." Opinion, p. 9
The court also faulted EPA for assuming that workers wear no protective equipment "despite OSHA requirements" (p. 43). This page leaves the ruling to the lawyers. It shows what OSHA's own records say about those requirements in practice: the samples its compliance officers took, and what they cited.
The OSHA standard covers general industry in 1910.1052. Construction (1926.1152) and shipyards (1915.1052) adopt the same text: each section is a one-line note saying its requirements are identical to 1910.1052. The EPA column shows what the vacated rule had added.
| Measure | OSHA, 1910.1052 (in force) | EPA 2024 rule (vacated) | OSHA before April 10, 1997 |
|---|---|---|---|
| 8-hour average | 25 ppm PEL, (c)(1) | 2 ppm ECEL | 500 ppm |
| 15 minutes | 125 ppm STEL, (c)(2) | 16 ppm EPA STEL | 2,000 ppm over 5 minutes in any 2 hours, 1,000 ppm ceiling |
| Action level, 8 hours | 12.5 ppm, (b) | 1 ppm ECEL action level | none |
Read the words in the standard: the PEL is an 8-hour time-weighted average, the STEL is "determined over a sampling period of fifteen minutes", and the action level triggers periodic monitoring and, on 30 days a year, medical surveillance. Going over it is not a violation. NIOSH lists methylene chloride as a potential occupational carcinogen with an IDLH of 2,300 ppm, and IARC classifies it in Group 2A, probably carcinogenic to humans. OSHA's standard tells classifiers to address at least these hazards:
"Cancer, cardiac effects (including elevation of carboxyhemoglobin), central nervous system effects, liver effects, and skin and eye irritation." 29 CFR 1910.1052(k)(1)(ii)
OSHA's laboratory publishes every result it analyzes once the inspection is closed: 13,829 methylene chloride results since 1984, personal, area and bulk. A personal sample is one sampler worn by one worker for a number of minutes. Since April 10, 1997, 5,927 personal results were published, and 5,883 carry the minutes and a result in ppm that the comparison needs.
"Please note that these results represent individual samplers that may be changed several times during the work shift. As a result, these values may not be directly comparable to levels listed in OSHA's Permissible Exposure Limits (PEL)." OSHA, Chemical Exposure Health Data
This study asks what one sample proves on its own, counting every minute without a sample as zero. For the 8-hour limit, that is the concentration times the minutes, over 480: a 60-minute sample at 250 ppm proves at least 31.25 ppm over 8 hours. For the STEL, a 15-minute sample is the 15-minute average, and a longer one proves at least its own average spread over the 15-minute windows that cover it. These are floors. The real exposure was the same or higher.
309
samples prove an 8-hour TWA above 25 ppm
126 inspections
634
samples prove 15 minutes above 125 ppm
214 inspections
2,043
samples were above 25 ppm while the sampler ran
35% of 5,883
| Category | personal samples |
|---|---|
| 1997 to 2001 | 1,871 |
| 2002 to 2006 | 1,852 |
| 2007 to 2011 | 757 |
| 2012 to 2016 | 738 |
| 2017 to 2021 | 341 |
| 2022 to 2026 | 324 |
| Years | Personal samples | Inspections | Prove 8 h above 25 ppm | Prove 15 min above 125 ppm | Not detected | Highest, ppm |
|---|---|---|---|---|---|---|
| 1997 to 2001 | 1,871 | 260 | 127 | 256 | 293 | 6,682.6 |
| 2002 to 2006 | 1,852 | 273 | 96 | 198 | 285 | 5,300.3 |
| 2007 to 2011 | 757 | 149 | 41 | 70 | 322 | 4,581.5 |
| 2012 to 2016 | 738 | 176 | 27 | 65 | 175 | 3,198.2 |
| 2017 to 2021 | 341 | 70 | 8 | 21 | 107 | 719.6 |
| 2022 to 2026 | 324 | 29 | 10 | 24 | 104 | 1,487.1 |
The years before 1997 are in the download. The limit was then 500 ppm, so those samples are counted but not compared with today's limits. 2026 is partial: the laboratory file runs through August 25, 2026.
OSHA records the industry of each inspection: an SIC code before the early 2000s, a NAICS code since. We grouped both into the industries below. The code-by-code table, with each official title, is in the download.
| Industry group | Samples | Inspections | Prove 8 h above 25 ppm | Prove 15 min above 125 ppm | Inspections with a 15-minute proof | Median minutes | Highest, ppm |
|---|---|---|---|---|---|---|---|
| Furniture repair and refinishing | 432 | 82 | 55 | 152 | 41 | 18 | 1,756.7 |
| Furniture manufacturing | 916 | 122 | 55 | 102 | 30 | 60 | 968.1 |
| Wood products | 408 | 48 | 31 | 70 | 13 | 59 | 1,313.1 |
| Plastics, foam and rubber products | 566 | 63 | 18 | 34 | 15 | 60 | 2,075.7 |
| Chemical manufacturing | 508 | 69 | 23 | 49 | 17 | 53.5 | 6,682.6 |
| Aircraft and air transportation | 72 | 16 | 16 | 19 | 6 | 31 | 2,973.7 |
| Construction | 93 | 29 | 17 | 23 | 11 | 24 | 4,581.5 |
| Metal products and machinery | 715 | 119 | 27 | 42 | 21 | 48 | 1,793.2 |
| Other manufacturing | 1,129 | 199 | 34 | 65 | 29 | 60 | 2,451.1 |
| Other repair and maintenance | 84 | 22 | 9 | 18 | 10 | 60 | 5,300.3 |
| Testing and research laboratories | 270 | 33 | 6 | 10 | 5 | 60 | 470.5 |
| Other industries | 625 | 142 | 15 | 46 | 18 | 58 | 1,130.2 |
| Industry not coded | 65 | 18 | 3 | 4 | 2 | 62 | 305.1 |
OSHA sampled 82 furniture repair and refinishing shops under the standard. In 41 of them, at least one sample proves a 15-minute exposure above 125 ppm. The median sample ran 18 minutes, the time it takes to brush stripper on a dresser and scrape it off. The court noted that EPA itself expected its rule to hit commercial furniture refinishing hard (opinion, p. 9). The samples show why the work drew attention.
Industry as OSHA coded it. No establishment is named.
Take a worker who strips a tub surround for 12 minutes at 400 ppm, then works the rest of the shift at 1 ppm. The 8-hour average is 10.98 ppm, under the 12.5 ppm action level. Those 12 minutes alone put the 15-minute average at 320 ppm or more, 2.56 times the STEL. A full-shift sample would have come back under every 8-hour line.
OSHA's compliance officers sample the task. 1,758 of the 5,883 personal samples since 1997 lasted 15 minutes or less, and the median lasted 59 minutes. In the same data, 698 samples were above 125 ppm while the sampler ran, against 309 that prove the 8-hour limit.
1,758
15 minutes or less
1,666
16 to 60 minutes
2,237
61 to 240 minutes
222
More than 240 minutes
Enter the lab results for one worker on one shift. The calculator applies 1910.1052 as written: the 8-hour TWA, the 15-minute floor of each sample, the row of Table 1 in (d)(3), and what the standard requires next. It refuses entries it cannot check, such as more than 480 minutes or a concentration air cannot hold.
Loaded with the example below: a 12-minute strip job at 400 ppm, then 1 ppm for the rest of the shift. Replace it with your own lab results.
8-hour TWA
10.98 ppm
Below the 12.5 ppm action level
Highest 15 minutes, at least
320 ppm
Above the 125 ppm STEL
A 15-minute sample gives the 15-minute average. A longer or shorter one only gives a floor.
Table 1 of 1910.1052(d)(3)
Below the action level and above the STEL: No 8-hour TWA monitoring required; monitor STEL exposures every three months.
Rules applied: samples of one worker taken one after another within one 8-hour period. TWA = sum of concentration x minutes / 480. mg/m3 converted at 25 °C, 1 ppm = 3.47 mg/m3. Construction (1926.1152) and shipyards (1915.1052) use the same text.
Table 1 has six rows, from "Below the action level and at or below the STEL" to "Above the TWA and above the STEL". The calculator quotes the row your result falls in, word for word.
From August 15, 1997 to August 28, 2026, OSHA and the State Plans issued 10,383 citation items under the methylene chloride standard, in 3,556 inspections. 75% were serious. 5,143 came from State Plan offices, including 376 under California's own rule, T8 section 5202. Another 401 items were deleted after issuance and are left out.
| Category | citation items |
|---|---|
| FY 1997 to 2001 | 2,585 |
| FY 2002 to 2006 | 3,210 |
| FY 2007 to 2011 | 1,986 |
| FY 2012 to 2016 | 1,451 |
| FY 2017 to 2021 | 745 |
| FY 2022 to 2026 | 406 |
| Paragraph | What it covers | Citation items | Inspections |
|---|---|---|---|
| (d) | Exposure monitoring | 3,131 | 2,988 |
| (l) | Information and training | 2,358 | 2,044 |
| (i) | Hygiene facilities | 894 | 778 |
| (h) | Protective clothing and equipment | 748 | 737 |
| (g) | Respiratory protection | 570 | 380 |
| (c) | Exposure limits | 541 | 397 |
| (f) | Engineering and work practice controls | 505 | 437 |
| (k) | Hazard communication | 418 | 408 |
| (j) | Medical surveillance | 417 | 381 |
| (e) | Regulated areas | 364 | 303 |
| (m) | Recordkeeping | 61 | 45 |
(d)(2) is the initial exposure determination, (l)(1) training at first assignment, (h)(1) protective clothing, (d)(1)(i) how each exposure is characterized, (i)(2) the eyewash.
1910.1200 is HazCom, 1910.134 respiratory protection, 1910.132 protective equipment, 1910.151 first aid and the eyewash.
| Industry group | Inspections with a citation | Citation items | Inspections since FY2020 |
|---|---|---|---|
| Other manufacturing | 787 | 2,206 | 39 |
| Metal products and machinery | 629 | 1,534 | 41 |
| Other industries | 578 | 1,328 | 18 |
| Furniture manufacturing | 310 | 1,123 | 21 |
| Other repair and maintenance | 223 | 540 | 11 |
| Plastics, foam and rubber products | 220 | 731 | 14 |
| Construction | 185 | 637 | 11 |
| Chemical manufacturing | 179 | 521 | 17 |
| Furniture repair and refinishing | 172 | 843 | 4 |
| Wood products | 115 | 444 | 5 |
| Testing and research laboratories | 87 | 253 | 12 |
| Aircraft and air transportation | 71 | 223 | 1 |
Penalties are in dollars of their year, as OSHA's data holds them after settlements and court decisions. 75 items were repeat and 44 willful. See how the same pattern plays out under HazCom in our study of seven years of HazCom citations.
The 2019 rule put a notice on the safety data sheet. Each person who manufactures, processes or distributes methylene chloride for any use after August 26, 2019 notifies its customers in writing, before or with the shipment, by inserting the same sentence in section 1(c) and section 15. Retailers are left out of this notice by definition.
"This chemical/product is not and cannot be distributed in commerce (as defined in TSCA section 3(5)) or processed (as defined in TSCA section 3(13)) for consumer paint or coating removal." 40 CFR 751.107(a) and (b), 2019 text (84 FR 11420)
The same rule asked for a file kept 3 years from each shipment: the customer's name, address, contact and telephone number, a copy of the notice and the amount shipped (751.109, 2019 text). Sheets rewritten for the 2024 rule may also list its prohibitions, its compliance dates and its limits. Here is what to check on the methylene chloride sheets you hold today:
In HazComFast
Drop in the supplier's PDF, scanned or not, in English or Spanish. HazComFast reads every page, fills in the hazards, the H and P statements, first aid and PPE, and shows where each value came from. Anything the AI isn't sure about waits for a person to confirm it.
The ruling was about TSCA. A paint stripping operation that is an affected area source under 40 CFR part 63, subpart HHHHHH, keeps the management practices of 63.11173(a): check whether the piece needs stripping at all, look for a stripping method without methylene chloride, keep the stripper covered, keep the temperature low, store it in closed containers. Above one ton of methylene chloride a year, (b) adds a written minimization plan and a posted sign, and (c) asks every shop to keep its annual usage on site.
For laboratory use of hazardous chemicals, 1910.1450(a)(2) replaces most of 1910.1052. The PEL still applies, eye and skin contact rules still apply, and when the action level is routinely exceeded, the monitoring and medical rules of 1910.1450 apply. A production step done in a room called a lab is not laboratory use, under (a)(3)(i). Read 1910.1450 paragraph by paragraph.
A case series in JAMA Internal Medicine (Hoang and colleagues, 2021) found 85 deaths linked to methylene chloride in the United States from 1980 to 2018. Of those, 74 happened at work, and 60 involved paint strippers. Before 2000, two of the work deaths happened while stripping a bathtub or a bathroom. After 2000, 21 did. The authors concluded that prevention should emphasize safer substitutes over hazard warnings or reliance on protective equipment.
A bathroom is small, closed and badly ventilated, and the vapor is heavier than air. It settles in the tub where the worker kneels. That is the task to sample for 15 minutes, with the worker in the tub.
Nothing in the ruling changed what OSHA asks of an employer with methylene chloride on site. The citations above show where employers fall short most often.
Paragraph (d)(2) is the one OSHA cites most under this standard: the initial determination of each employee's exposure. Sample the worker closest to the stripper or the tank, during the task, with at least one 15-minute sample at the worst moment. Then run the results through the calculator above.
Methylene chloride calculatorWhere a respirator is required, (g)(3)(i) allows an atmosphere-supplying respirator and rules out half masks of any type. An organic vapor cartridge is for emergency escape only, in a gas mask. A program under 1910.134 comes with it.
Respiratory protection program builderSuppliers that rewrote their sheets for the 2024 rule may revise them again. File the new revision, keep the old one, and check sections 2, 8, 11 and 15 against the list below.
In HazComFast
A worker can confirm an SDS only after reaching the end of Section 4, first aid. The proof keeps the version, the time and the device. When the supplier sends a new version, everyone who read the old one gets it back to read.
Self-audit your SDS libraryEach measurement goes into a record kept at least 30 years under (m)(2)(iv), with the operation, the method, the duration of each sample and the protective equipment worn, for employers with 20 or more employees.
In HazComFast
When someone leaves, their end date is recorded, and that's the date the 30-year clock for their exposure and medical records starts from. Nothing they completed is erased.
Record retention calculatorIf a substitute replaces the methylene chloride stripper, the old product still needs a record of what it was, where it was used and when, for 30 years under 1910.1020(d)(1)(ii)(B).
In HazComFast
Scan the QR on a product you stopped using and the page says it was removed from inventory, with the archived SDS one tap away.
Chemical inventory templateTraining under (l)(1) comes before the first job with methylene chloride. Above the action level, (l)(3)(ii) adds where it is used, stored and released, and which operations can go over the limits. It is the second most cited paragraph of the standard.
In HazComFast
In HazComFast, the training center handles assignments, quizzes, certificates and expiration alerts, and SDS read proof shows who read which sheet, when, and in which language.
HazCom training record generatorFree to reuse with a link to this page, under the Creative Commons Attribution 4.0 license.
HazComFast. (2026). Methylene chloride after EPA's rule was vacated: what OSHA's own samples and citations show. https://hazcomfast.com/osha-data-research/methylene-chloride-study. Samples reported through August 25, 2026, citations extracted October 14, 2026.
The 2024 EPA rule that prohibited most uses and set a 2 ppm workplace limit was vacated by the Fifth Circuit on September 15, 2026. EPA's 2019 rule on consumer paint and coating removal was not part of the case. At work, OSHA's standard, 29 CFR 1910.1052, still applies in general industry, and the same text applies in construction (1926.1152) and shipyards (1915.1052). State rules can add to these.
25 ppm as an 8-hour time-weighted average and 125 ppm over 15 minutes, under 1910.1052(c). The action level is 12.5 ppm as an 8-hour average. These limits took effect on April 10, 1997, replacing 500 ppm over 8 hours, a 1,000 ppm ceiling and a 2,000 ppm peak.
The 2 ppm ECEL, the 1 ppm ECEL action level and the 16 ppm EPA STEL came from the Workplace Chemical Protection Program of the 2024 rule, which the court vacated. Until EPA updates the CFR, the eCFR still prints that text. An employer can keep a lower internal target. OSHA does not require one.
It depends on the initial determination, under Table 1 of 1910.1052(d)(3). Below the action level and the STEL, no periodic monitoring. At or above the action level and at or below 25 ppm, every six months. Above 25 ppm, every three months. Above 125 ppm over 15 minutes, STEL monitoring every three months. The note to (d)(3) lets you slow down or stop after two consecutive results at least seven days apart.
An atmosphere-supplying respirator, under 1910.1052(g)(3)(i), and no half masks of any type, because methylene chloride can irritate or damage the eyes. For emergency escape, (g)(3)(ii) allows a self-contained breathing apparatus or a gas mask with an organic vapor canister.
Under 1910.1052(j)(1)(i), for employees at or above the action level on 30 or more days a year, or above the 8-hour limit or the STEL on 10 or more days a year. It also applies in an emergency, and above a limit for any period when a physician or other licensed health care professional has identified the employee as at risk from heart disease or another serious methylene chloride-related condition, and the employee asks for it.
EPA's 2019 rule required the supplier to insert this sentence in section 1(c) and section 15 of the SDS: "This chemical/product is not and cannot be distributed in commerce (as defined in TSCA section 3(5)) or processed (as defined in TSCA section 3(13)) for consumer paint or coating removal." The 2024 rule moved and widened that notice. The court vacated the 2024 rule and called the 2019 rule "not challenged here".
Yes. Twelve minutes at 400 ppm, then 1 ppm for the rest of the shift, gives an 8-hour average of 10.98 ppm, below the 12.5 ppm action level. The same twelve minutes put the 15-minute average at 320 ppm or more, above the 125 ppm STEL.
From OSHA's own published data: the sampling results of OSHA's laboratory since 1984 (the Chemical Exposure Health Data, reported through August 25, 2026), and the inspection and violation tables of the Department of Labor's open data, extracted October 14, 2026. HazComFast counted them. No establishment is named on this page or in the downloads.
Yes. The counts by year, by industry group, by industry code and by paragraph are free to download and reuse with a link to this page, under the Creative Commons Attribution 4.0 license (CC BY 4.0).
Written and maintained by HazComFast. Regulatory text quoted from the eCFR, the Federal Register and the court's opinion. Counts built from OSHA's published data.
General information, not legal advice. For a question about your own operation, the eCFR text and the court's docket are the references.
OSHA inspections come unannounced, apart from the few exceptions listed in 29 CFR 1903.6. Get the binder in order before the opening conference, not during it.
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