March 10, 2010

Senate Subcommittee Holds Hearing to Obtain Business Perspectives on TSCA Reform

On March 9, 2010, the Senate Committee on Environment and Public Works Subcommittee on Superfund, Toxics, and Environmental Health held a hearing entitled “Business Perspectives on Reforming U.S. Chemical Safety Laws.” Senator Frank R. Lautenberg (D-NJ), Chair of the Subcommittee, convened the hearing with leaders of businesses that manufacture or use chemicals to examine their business perspectives on reforming the Toxic Substances Control Act (TSCA). Only two other Senators...
March 9, 2010

ECHA Announces New Public Consultation on Eight Potential Substances of Very High Concern

Today the European Chemicals Agency (ECHA) proposed to identify eight chemicals as substances of very high concern (SVHC) and possible candidates for authorization under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation. The detailed proposals are available on the ECHA website online. Comments are due April 22, 2010. Potential Additions to the SVHC Listing Denmark, France, and Germany proposed identifying eight substances as SVHCs. ECHA...
March 9, 2010

DOT Eases Requirements for Security Plans

Today the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule narrowing the list of hazardous materials (hazmats) that require security plans when transported in commerce. 75 Fed. Reg. 10974. The rule is effective on October 1, 2010, although voluntary compliance is authorized as of April 8, 2010. The final rule also revises the regulations applicable to the content of and training associated with security...
March 4, 2010

House Subcommittee Holds Hearing on TSCA and PBTs

On March 4, 2010, the House Committee on Energy and Commerce Subcommittee on Commerce, Trade, and Consumer Protection held a hearing entitled “TSCA and Persistent, Bioaccumulative, and Toxic Chemicals: Examining Domestic and International Actions.” The Subcommittee held the hearing to examine U.S. and international efforts to protect public health and the environment from persistent, bioaccumulative, and toxic (PBT) chemicals, how the Toxic Substances Control Act (TSCA) is currently...
March 3, 2010

Health Canada Adopts Interim Policy Statement on Health Canada’s Working Definition for Nanomaterials

On March 1, 2010, Health Canada began a public consultation on its adoption of the Interim Policy Statement on Health Canada’s Working Definition for Nanomaterials (Interim Policy). Although Health Canada is accepting comments, it states that the Interim Policy “is effective immediately.” In preparing the Interim Policy, Health Canada states that it sought the informal feedback of some international stakeholders, industry trade groups, standards associations, and...
March 1, 2010

House Subcommittee Holds Hearing on Endocrine Disrupting Chemicals in Drinking Water

On February 25, 2010, the House Committee on Energy and Commerce Subcommittee on Energy and Environment held a hearing entitled “Endocrine Disrupting Chemicals in Drinking Water: Risks to Human Health and the Environment.” The Subcommittee intended the hearing to examine the science and regulation of endocrine disruptors that may be found in sources of drinking water. Witnesses included: The witness testimony is available online. Subcommittee members criticized the slow pace of...
February 24, 2010

EPA Publishes Final Clarification for Chemical Identification Describing Activated Phosphors for TSCA Inventory Purposes

Today the U.S. Environmental Protection Agency (EPA) published its final clarification under which certain activated phosphors that are not on the Toxic Substances Control Act (TSCA) Section 8(b) Chemical Substance Inventory (TSCA Inventory) will be considered to be “new” chemical substances under TSCA Section 5, and thus will be subject to applicable notification requirements under TSCA Section 5. According to EPA, the clarification is necessary because EPA’s statements in...
February 23, 2010

OIG Report Concludes EPA Needs Coordinated Plan to Oversee Its TSCA Responsibilities

On February 18, 2010, the U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG) released a report entitled EPA Needs a Coordinated Plan to Oversee Its Toxic Substances Control Act Responsibilities, urging EPA to coordinate better risk assessment and oversight activities by establishing a management plan that contains new goals and measures that demonstrate the results of Office of Pollution Prevention and Toxics (OPPT) and Office of Enforcement and Compliance...
February 22, 2010

EPA Proposes Amendments to TSCA Section 4 Enforceable Consent Agreement Procedures

On February 19, 2010, the U.S. Environmental Protection Agency (EPA) proposed important revisions to the procedures for development of enforceable consent agreements (ECA) to generate test data under Section 4 of the Toxic Substances Control Act (TSCA). 75 Fed. Reg. 7428 (Feb. 19, 2010). The proposed rule includes some sweeping changes for when and how negotiations will be initiated, conducted, and concluded, and limits the timeframe within which these activities will take place. Companies that...
February 17, 2010

New York Advisory Council Green Procurement Chemical Avoidance List Released Publicly

As we reported last month, the Sustainability and Green Procurement Advisory Council (Advisory Council) of the New York Interagency Committee on Sustainability and Green Procurement (Interagency Committee) voted 9-1 to recommend creating a “chemical avoidance list” that would be a list of chemicals that New York government agencies should avoid buying. The list would comply with Governor David Paterson’s 2008 Executive Order directing state agencies, public authorities, and...
February 8, 2010

EPA SAP Releases Report on Nanosilver and Other Nanometal Pesticide Products

The U.S. Environmental Protection Agency (EPA) Scientific Advisory Panel (SAP) has released the minutes of its November 3-5, 2009, meeting regarding evaluation of the hazard and exposure associated with nanosilver and other nanometal pesticide products. Before summarizing the SAP’s primary conclusions and recommendations, we note a few general observations. First, the SAP final recommendations address nanosilver almost entirely, and little or no mention is made of “nanometal...
February 4, 2010

Senate Subcommittee Holds Hearing Regarding Current Science on Public Exposure to Toxic Chemicals

Today the Senate Committee on Environment and Public Works Subcommittee on Superfund, Toxics and Environmental Health held a hearing entitled “Current Science on Public Exposures to Toxic Chemicals.” Senator Frank R. Lautenberg (D-NJ), Chair of the Subcommittee, criticized the Toxic Substances Control Act (TSCA) for failing to provide the U.S. Environmental Protection Agency (EPA) the necessary authority to protect the public from unsafe chemicals. Lautenberg stated that he intends...
January 28, 2010

EPA Announces Intent to Issue Cancellation Order for Spirotetramat

On January 26, 2010, the U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs (OPP) announced that it intends to issue a cancellation order for the pesticide spirotetramat pursuant to Section 6(a)(1) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). A comment period is now open on the existing stocks provisions of the planned cancellation order. Comments are due February 8, 2010. EPA states that, on December 23, 2009, the U.S. District Court for the...
January 27, 2010

Final Rule Amends PMN Exemption for Polymers

Today the U.S. Environmental Protection Agency (EPA) promulgated a final rule amending the polymer exemption rule, which provides an exemption from the premanufacture notification (PMN) requirements of the Toxic Substances Control Act (TSCA). The amendment excludes from eligibility polymers containing as an integral part of their composition, except as impurities, certain perfluoroalkyl moieties consisting of a CF3- or longer chain length. This exclusion includes polymers that contain any one or...
January 25, 2010

EPA Revises TSCA Section 8(e) CBI Policy and Holds ePMN CDX Registration Webinar

EPA Limits CBI Claims in TSCA Section 8(e) Submissions On January 21, 2010, the U.S. Environmental Protection Agency (EPA) announced a new practice concerning confidential business information (CBI) claims for substantial risk information submitted to EPA under Toxic Substances Control Act (TSCA) Section 8(e). 75 Fed. Reg. 3462. According to EPA’s announcement, if a chemical substance is listed on the public portion of the TSCA Inventory, EPA expects a company submitting a health and...
January 22, 2010

Senate Expected to Schedule TSCA Hearing

Bergeson & Campbell, P.C. (B&C) has learned that the Senate is preparing to schedule a hearing on the Toxic Substances Control Act (TSCA) in early February, most likely on February 4, 2010. As noted in our 2010 Predictions memorandum, a new and significantly revised Kid-Safe Chemicals Act (KSCA) has not yet surfaced. The fact that the Senate is scheduling a hearing indicates that a revised Senate proposal is expected soon. There are also indications that if new...
January 13, 2010

EPA Revises TSCA Section 5 PMN and SNUN Electronic Reporting Requirements

On January 6, 2010, the U.S. Environmental Protection Agency (EPA) promulgated a final rule amending the electronic reporting requirements under Section 5 of the Toxic Substances Control Act (TSCA) (available online). According to EPA, the amendments are intended to streamline and reduce the administrative costs and burdens of TSCA Section 5 notifications for both industry and EPA by establishing standards and requirements for the use of EPA’s Central Data Exchange (CDX) to encrypt and...
January 12, 2010

Additional Information on New York “Chemical Avoidance List”

In our memorandum dated January 6, 2010, we alerted you to a recent activity in New York in connection with the development of a “chemical avoidance list.” The list, which reportedly consists of approximately 85 chemicals, would include chemicals that New York government agencies should avoid buying. By way of background, last May the Advisory Council of the New York Interagency Committee on Sustainability and Green Procurement voted 9-1 to recommend adoption of the not-yet...
January 7, 2010

2010 Predictions

As is our custom, Bergeson & Campbell, P.C. is pleased to forward our thoughts on what may be in store this year from the U.S. Environmental Protection Agency’s Office of Prevention, Pesticides, and Toxic Substances. In light of the significant chemical management developments underway in the European Union, we are pleased that Ruxandra Cana and Koen Van Maldegem from the Brussels office of Field Fisher Waterhouse LLP have contributed their thoughts on what may be...
January 6, 2010

New York Considers Listing Chemicals that Agencies Should Avoid Buying

The New York Interagency Committee on Sustainability and Green Procurement has voted 9-1 to recommend a “chemical avoidance list,” which would be a list of 85 chemicals that New York government agencies should avoid buying. Listed chemicals would not be banned, but industry representatives have criticized the proposal, noting that the list would not address the actual risk from exposure. The Committee intends the list to comply with Governor David Paterson’s 2008 Executive...
December 31, 2009

EPA Announces Action Plans For Existing Chemicals

True to her word, yesterday U.S. Environmental Protection Agency (EPA) Administrator Lisa P. Jackson announced action plans on phthalates, long-chain perfluorinated chemicals (PFC), polybrominated diphenyl ethers (PBDE) in products, and short-chain chlorinated paraffins (SCCP).  This EPA initiative announces actions that are almost breathtaking in scope, and its development and implementation of the action plan items will set a number of new precedents — and possibly shape future...
December 10, 2009

CDC Releases Fourth National Report on Human Exposure to Environmental Chemicals

Today the Centers for Disease Control and Prevention (CDC) released the Fourth National Report on Human Exposure to Environmental Chemicals (Fourth Report), which provides an ongoing assessment of the exposure of the U.S. population to environmental chemicals using biomonitoring.  The Fourth Report presents data for the U.S. population for 212 environmental chemicals over the period 2003-2004, updating CDC’s 2005 Third National Report on Human Exposure to Environmental...
December 9, 2009

EPA Announces Development of Voluntary Pilot Programs for Antimicrobial Pesticide Products

Today the U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs (OPP) announced the development of two voluntary pilot programs for antimicrobial pesticide products.  Working collaboratively with the Pesticide Program Dialogue Committee (PPDC), OPP explored the different types of label statements and logos for antimicrobial pesticide product labels.  OPP developed the Factual Label Statement Pilot Program and the OPP-Design for the Environment (DfE) Logo Pilot...
December 8, 2009

EPA Announces Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticides with No Food Uses

Earlier today the U.S. Environmental Protection Agency (EPA) announced the availability of a policy paper entitled Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticides with No Food Uses, which describes how EPA plans to use revised methods in conducting risk assessments for pesticide uses and exposures not governed by the Federal Food, Drug, and Cosmetic Act (FFDCA).  According to EPA, implementing this policy will increase...
December 7, 2009

ECHA Member State Committee Agrees on New SVHCs to Be Added to the Candidate List and First REACH Testing Decision

During the European Chemicals Agency (ECHA) Member State Committee’s December 2-4, 2009, meeting, the Committee unanimously agreed that 15 new substances of very high concern (SVHC) would be added to the Candidate List.  The Committee also unanimously agreed on a testing proposal from ECHA that was submitted under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation.  More information on these actions is provided below. 15 SVHCs to Be Added to...
December 2, 2009

Senate Committee and Subcommittee Hold Oversight Hearing on TSCA

Today the full Senate Committee on Environment and Public Works and Subcommittee on Superfund, Toxics and Environmental Health held a joint hearing entitled “Oversight Hearing on the Federal Toxic Substances Control Act.”  During the hearing, Senator Frank R. Lautenberg (D-NJ), Chair of the Subcommittee, stated that he is preparing legislation to reform the Toxic Substances Control Act (TSCA).  In 2005 and 2008, Lautenberg introduced the Kid-Safe Chemicals Act, which...
November 30, 2009

EU Council Adopts Updated Cosmetics Regulation Requiring Labeling of Nanoscale Ingredients

On November 20, 2009, the European Union (EU) Council approved an updated cosmetics regulation that would require cosmetic products that contain nanoscale ingredients to be labeled as such.  The regulation would also require the manufacturers of new cosmetic products containing nanomaterials to notify the European Commission (EC) and provide certain information six months before the product is placed on the European market.  If the EC has concerns regarding the safety of the...
November 25, 2009

EPA Seeks Comment on a Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species in Climate Change

Today, the U.S. Environmental Protection Agency (EPA) released and requested comment on a draft document titled, “A Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change” (EPA/600/R-09/011).  74 Fed. Reg. 61671.  The document was prepared by the National Center for Environmental Assessment within EPA’s Office of Research and Development.  The draft document describes an evaluative framework to categorize the relative...
November 18, 2009

First Appeal Filed with ECHA Board of Appeal Results in Rectification of ECHA Decision

On September 16, 2009, Field Fisher Waterhouse (FFW), with and relying on the advice and assistance of The Acta Group EU, Ltd (Acta EU), an affiliate of Bergeson & Campbell, P.C., submitted the first appeal against a decision of the European Chemicals Agency (ECHA or the Agency) with the ECHA Board of Appeal, on behalf of the registrant. On the basis of this submission, on October 14, 2009, the Executive Director of ECHA rectified the...
November 17, 2009

House Subcommittee Holds Hearing on Prioritizing Chemicals for Safety Determination

Today the House Committee on Energy and Commerce Subcommittee on Commerce, Trade and Consumer Protection held a hearing entitled “Prioritizing Chemicals for Safety Determination.”  The hearing was intended to examine the options for prioritizing chemicals for safety determinations in the event that Congress passes legislation amending the Toxic Substances Control Act (TSCA) and reflects Congress’s sustained interest in chemical management reform legislation. The hearing, which was...
November 13, 2009

ECHA Posts Webinar Online

Today the European Chemicals Agency (ECHA) announced the online availability of a webinar regarding preparing and submitting a registration dossier.  ECHA held the webinar on November 4, 2009, for lead registrants.  The objective of the webinar was to provide lead registrants with an understanding of the main technical concepts required to be able to prepare and submit a registration dossier.  ECHA covered the following topics:  exporting information as an IUCLID 5...
November 10, 2009

EC Adopts 2007-2009 Nanotechnology Implementation Report

On October 29, 2009, the European Commission (EC) adopted a Communication entitled Nanosciences and Nanotechnologies: An Action Plan for Europe 2005-2009. Second Implementation Report 2007-2009. The Communication outlines the key developments during 2007-2009 in each policy area of the Nanotechnology Action Plan 2005-2009, identifies current challenges, and draws conclusions relevant to the future European nanotechnology policy. According to the Communication, the EC has made significant...
November 6, 2009

EPA Proposes SNURs for Carbon Nanotubes

Today the U.S. Environmental Protection Agency (EPA) proposed significant new use rules (SNUR) under Section 5(a)(2) of the Toxic Substances Control Act (TSCA) for two chemical substances that were the subject of premanufacture notices (PMN). EPA identified the substances generically as multi-walled carbon nanotubes and single-walled carbon nanotubes. According to the notice, these substances are subject to TSCA Section 5(e) consent orders issued by EPA. The consent orders require protective...
November 5, 2009

Summary of Ninth Antimicrobial Workshop

On October 27-28, 2009, the Ninth Antimicrobial Workshop was held in Arlington, Virginia. The American Chemistry Council (ACC) Biocides Panel, the Consumer Specialty Products Association (CSPA), and ISSA sponsored the Workshop, which was conducted in coordination with the U.S. Environmental Protection Agency (EPA) Antimicrobials Division. The Workshop included presentations on the following topics: According to the Workshop organizers, the presentations will be available by the end of this week...
November 4, 2009

EPA Announces Draft Pesticide Registration Notice Concerning Drift Labeling and Petition Regarding Children’s Exposures to Pesticide Drift

Today the U.S. Environmental Protection Agency (EPA) announced the availability of a Pesticide Registration (PR) Notice entitled “Pesticide Drift Labeling” (2009-X) and a draft explanatory document entitled “Pesticide Drift Labeling Interpretation.”  In a separate Federal Register notice, EPA announced that, on October 13, 2009, Earthjustice and Farmworker Justice, on behalf of several other organizations, filed a petition requesting that EPA...
November 3, 2009

ECHA Publishes Concise Guidance on Chemical Safety Assessment

Today the European Chemicals Agency (ECHA) announced the availability of its Guidance in a Nutshell:  Chemical Safety Assessment, which is intended to assist industry in understanding the general provisions for conducting a Chemical Safety Assessment (CSA).  ECHA states that the Guidance is aimed at non-experts who would like to understand the legal requirements under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation regarding substance...
October 31, 2009

Pesticide Program Dialogue Committee Holds Semi-Annual Meeting

On October 14 and 15, 2009, the Pesticide Program Dialogue Committee (PPDC) held its semiannual meeting in the U.S. Environmental Protection Agency (EPA) offices in Arlington, Virginia.  This memorandum summarizes the presentations and topics discussed during the meeting, which were organized into seven sessions: Copies of the slides and handouts from the meeting are available at http://www.epa.gov/pesticides/ppdc/2009/october/october09.html. In his introductory remarks, Steve Owens,...
October 23, 2009

FDA Research Involving Nanoscale Materials

This memorandum outlines research being sponsored, conducted, or planned by the U.S. Food and Drug Administration (FDA) regarding nanoscale materials. FDA has indicated repeatedly that it needs additional information on the characterization of such materials to make informal decisions regarding the safety of regulated products that incorporate nanotechnology.1 While those decisions are for the most part in the future, there is at least one use of nanotechnology in drug and cosmetic products...
October 20, 2009

EPA Posts Prepublication EDSP Federal Register Notices

The U.S. Environmental Protection Agency (EPA) has posted two prepublication Federal Register notices concerning its Endocrine Disruptor Screening Program (EDSP).  In the first notice, EPA announces the EDSP Tier 1 battery of assays and availability of test guidelines for conducting the assays included in the battery.  In the second notice, EPA announces the issuance of the initial EDSP screening orders and the schedule of issuance.  EPA expects both notices to be...
October 16, 2009

USDA Proposes Voluntary Labeling Program for Biobased Products

Earlier this year, the United States Department of Agriculture (USDA) proposed a voluntary labeling program for biobased products and solicited comment on its approach.  Under the proposed labeling program, manufacturers and vendors could, after obtaining certification from USDA, market the certified biobased product using the “USDA Certified Biobased Product” label.  The proposed program would also apply to other entities, such as trade associations, that wish to use the label to...
October 15, 2009

Signs Federal Register Notice Concerning EDSP Test Orders

At yesterday’s Pesticide Program Dialogue Committee meeting, Steven Bradbury, Deputy Office Director for Programs, U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs, announced that Steve Owens, Assistant Administrator of the EPA Office of Prevention, Pesticides and Toxic Substances, would be signing later in the day the Federal Register notice concerning the schedule for sending out test orders for the final list of chemicals for initial Tier 1 Screening...
October 7, 2009

Groups Sponsor Conference on the Future of U.S. Chemicals Policy

On October 6, 2009, environmental, consumer, and industry associations hosted a conference entitled “The Future of U.S. Chemicals Policy.”  Sponsors included the Environmental Working Group, Rachel’s Network, The Pew Health Group, Community Against Pollution, The Louisiana Bucket Brigade, American Chemistry Council, Grocery Manufacturers Association (GMA), Turner Foundation, Soap and Detergent Association (SDA), and Consumer Specialty Products Association (CSPA).  U.S....
October 5, 2009

EPA Announces Public Role in Pesticide Registration Process

On October 1, 2009, the U.S. Environmental Protection Agency (EPA) announced the establishment of “a new transparent process” intended to allow the public to review and comment on risk assessments and proposed registration decisions for pesticides.  According to EPA, this expanded process will apply to all new pesticide active ingredients and first food uses, first outdoor uses, and first residential uses.  Starting October 1, 2009, for certain registration actions, EPA will add...
October 2, 2009

EPA Announces Research Strategy to Study Nanomaterials

On September 30, 2009, the U.S. Environmental Protection Agency (EPA) announced the availability of the Nanomaterial Research Strategy (Strategy), which EPA describes as its new research strategy to understand better how manufactured nanomaterials may harm human health and the environment. The Strategy outlines what research EPA intends to support over the next several years to generate information about the safe use of nanotechnology and products that contain nanoscale materials. The...
October 1, 2009

OSHA Issues Proposed Rule to Align the Hazard Communication Standard with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals

Yesterday the Occupational Safety and Health Administration (OSHA) issued a proposed rule that would align the Hazard Communication Standard (HCS) with provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS).  The HCS requires chemical manufacturers and importers to evaluate chemical hazards and provide information to subsequent users.  According to OSHA, it made a preliminary determination that the proposed HCS modifications...
September 30, 2009

EPA Announces Principles for TSCA Reform

Last night, in a speech at the Commonwealth Club in San Francisco, U.S. Environmental Protection Agency (EPA) Administrator Lisa Jackson announced the Obama Administration’s core principles for legislative reform of the Toxic Substances Control Act (TSCA).  In parallel with the legislative initiative, Jackson also announced EPA’s plans to strengthen its current chemical management program and increase the pace of its efforts to address chemicals that pose a risk to the public. ...
September 29, 2009

ACS Holds Briefing on TSCA Reform

Today the American Chemical Society (ACS) held a briefing intended to provide a forum to explore the perspectives, roles, and activities of various stakeholders regarding reform of the Toxic Substances Control Act (TSCA).  E. Donald Elliott, Willkie Farr & Gallagher LLP, moderated the panel, which included Andy Ingrejas, Safer Chemicals, Healthy Families; Sarah Brozena, American Chemistry Council (ACC); Roger McFadden, Staples; Kenneth Zarker, Washington State Department of Ecology; and...
September 24, 2009

PEN Holds Meeting on Transatlantic Regulatory Cooperation

Yesterday the Woodrow Wilson International Center for Scholars Project on Emerging Technologies (PEN) hosted a meeting on “Transatlantic Regulatory Cooperation: Securing the Promise of Nanotechnologies.” The program is part of a collaborative research project involving experts from the London School of Economics (LSE), Chatham House, the Environmental Law Institute (ELI), and PEN. The project is funded by a grant from the European Commission to support pilot projects on “Transatlantic...
September 22, 2009

EPA Signs Final Rule Requiring Greenhouse Gas Emissions Reporting

Today the U.S. Environmental Protection Agency (EPA) announced that EPA Administrator Lisa Jackson signed a final rule that would require reporting of greenhouse gas (GHG) emissions from all sectors of the economy.  The prepublication version of the final rule states that it applies to fossil fuel suppliers and industrial gas suppliers, direct GHG emitters, and manufacturers of heavy-duty and off-road vehicles and engines.  The rule does not require control of GHG, “rather it...
September 21, 2009

EPA Issues Direct Final SNURs for 12 Substances

On September 18, 2009, the United States Environmental Protection Agency (EPA) issued a Federal Register notice promulgating direct final significant new use rules (SNUR) for 12 chemical substances under Section 5(a)(2) of the Toxic Substances Control Act (TSCA).1 For two of the 12 substances, EPA issued final SNURs that set forth the same exposure controls that were negotiated with the initial premanufacture notice (PMN) submitter through “risk-based” TSCA Section 5(e)...