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Monday March 19, 2018

CPSC Near to Publishing Updated Methylene Chloride Guide

Commissioners were slated to vote as PSL went to press on publishing an updated guidance on labeling paint stripper products containing methylene chloride (dichloromethane or DCM). It would be effective upon appearing in the Federal Register.


Commissioners voted 5-0 last year (PSL, 6/12/17) to grant a 2016 petition that sought an update to better address acute inhalation risks associated with use in enclosed spaces like bathtubs, sinks, or closets. The existing guidance came out in 1987.


The briefing package ( includes assessments by various CPSC offices:

  • Health Sciences: An additional death became known since the vote. Staffers agreed that ventilation is difficult in the targeted scenarios, so supported the update.

  • Epidemiology: The data were too small to estimate injury and health incidents nationally. There were 30 DCM incidents from January 1, 2000 to November 30, 2017. Most (28) did involve paint stripper, including six deaths. There was difficulty telling consumer from occupational events.

  • Economic: Label changes would be amortized over the "entire production run of the product," making the per-unit cost small. Thus, staffers deemed effects minimal.

  • Compliance/Regulatory: Staffers are supporting EPA work to address the risks. The updated guidance would aid consumer clarity in the meantime.

  • Human Factors: The risks of indoor use should be emphasized to avoid consumer confusion. Staffers worried that warning about enclosed spaces might lead some users to think that other indoor use lacked risk. They also urged "vivid and relatable" phrases to increase user compliance.

When urging commissioners to grant the petition last year (PSL, 6/5/17), staffers rejected calls for delayed action despite related work at EPA as well as efforts in California and by the ASTM D01.42 subcommittee. Similar to the regulatory assessment above, staffers saw the update – at least with EPA – as being complementary not conflicting.


Meanwhile, since then, California's DTSC sought input on declaring strippers with DCM to be priority products (PSL, 11/27/17).