The impacts of the new EPA rule on methylene chloride to laboratories in the United States

I have been making nervous noises about the EPA ban on methylene chloride, and I believe that my thoughts are confirmed (unbeknownst to me) by the American Chemical Society's comment on the (then proposed) rule (opens PDF, via ACS' Will Hartwig):

ACS appreciates the current proposed rule’s goal of protecting public health. However, ACS is concerned that the current proposal to regulate methylene chloride, also known as dichloromethane (DCM), fails to account for its use in small scale and particularly academic teaching and research laboratories.

Both the EPA (with 40 CFR 262 Subpart K) and OSHA (with 29 CFR 1910.1450) have recognized that regulations aimed at protecting workers in industry do not translate to academic laboratories. As currently structured, the rule would be extremely challenging for academic institutions to implement and would negatively impact research and teaching. The proposed rule is not appropriate for academic laboratories because exposures are low, infrequent, and well managed using existing regulations and engineering controls (e.g. chemical fume hoods)

From my analysis of the new rule, any workplace that uses methylene chloride must:

1. determine and document who uses DCM
2. document and monitor the exposure during usage, which
3. means getting a monitoring device (likely a PID, is my guess, which is a $4000 instrument)*
4. determining and documenting TWAs for each usage and user

(I've read enough comments from industry to understand that the PIDs that are available aren't particularly well suited for this usage, so that's another problem. (page 6, PDF)

I'm not a chemical safety professional, so I could be wrong. But that's my basic read of the new rule, and I think it is matched by the ACS. No professor is going to this - instead, they're going to either 1) ignore the new rule or 2) ban the use of DCM in their labs. Hard to know which one they will choose.

I'd love people's opinions.