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Methylene chloride stay and use as a medical-device bonding solvent

Summary A medical device manufacturer asked whether its use of methylene chloride as a bonding solvent qualified for a 1997 compliance-date stay covering product formulation. OSHA's regional office answered no for the described assembly process. The stay was time limited, so this letter is historical guidance.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1998-02-06-0
Date issued
February 6, 1998
Status
Unknown
This regional letter applies a December 1997 partial stay of compliance dates, a time-limited rulemaking event; current applicability requires checking the final standard.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Methylene Chloride Chemical Exposure
Source
View the official document

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The current status of this document is unclear
This regional letter applies a December 1997 partial stay of compliance dates, a time-limited rulemaking event; current applicability requires checking the final standard. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

February 6, 1998

Lisa Millington
Environmental Affairs Assistant
Braun Medical Inc.
[Recipient address omitted]
Dear Ms. Millington;

This is in reply to your letter, dated January 22, 1998, concerning whether methylene chloride used as a solvent or bonding agent is covered by the "formulation of products" stay for the methylene chloride standard listed in the Federal Register of December 18, 1997. As confirmed with our national office, the December 18, 1997 stay would not cover this usage of methylene chloride.

OSHA standards and policies are accessible on the Internet. OSHA's web site address is "www.osha.gov." Please contact this office if we may be of further assistance.

Sincerely,

KENNETH W. GERECKE
Assistant Regional Administrator

[Requester letter reproduced on OSHA page; omitted here.]

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