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September 12, 2011

Lisa R. Burchi, Charles M. Auer, and Lynn L. Bergeson, “EPA’s SNUR Authority and Key Points Regarding SNURs for Former New Chemicals,” BNA Daily Environment Report, September 12, 2011.

Bergeson & Campbell, P.C.

The U.S. Environmental Protection Agency’s use of its authority under the Toxic Substances Control Act is expanding. Its use of TSCA Section 5 ‘‘significant new use rule’’ (SNUR) authority is clearly on the increase, as most recently demonstrated by the important role that significant new use rules have in Chemical Action Plans. This article describes SNURs, their issuance and legal background, and a few key issues of which regulated entities need to be aware in responding to a proposed or promulgated SNUR.