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June 12, 2015

EPA Issues Proposed SNUR for Functionalized Carbon Nanotubes

Lynn L. Bergeson Carla N. Hutton

On June 10, 2015, the U.S. Environmental Protection Agency (EPA) issued proposed significant new use rules (SNUR) for 30 chemical substances that were the subject of premanufacture notices (PMN), including functionalized carbon nanotubes (generic) (PMN Number P-13-793). On October 27, 2014, EPA promulgated a SNUR for this PMN substance through a direct final rule. EPA withdrew the SNUR on December 23, 2014, after receiving notice of intent to submit adverse comments. According to the June 10, 2015, Federal Register notice, EPA has not determined that the proposed manufacturing, processing, or use of the substance may present an unreasonable risk to human health or the environment. The notice states:

EPA has determined, however, that any use of the substance without the use of impervious gloves, where there is a potential for dermal exposure; manufacturing the PMN substance for use other than as a thin film for electronic device applications; manufacturing, processing, or using the PMN substance in a form other than a liquid; use of the PMN substance involving an application method that generates a mist, vapor, or aerosol; or any release of the PMN substance into surface waters may cause serious health effects or significant adverse environmental effects.

EPA notes that a notice of intent to comment adversely has been submitted. EPA “awaits the adverse comment during the open comment period.” Comments on the proposed SNUR are due July 10, 2015.