The U.S. Environmental Protection Agency (EPA) has released a pre-publication version of its direct final rule signed on April 5, 2017, which states that EPA will be promulgating significant new use rules (SNUR) under the Toxic Substances Control Act (TSCA) for 37 chemical substances which were the subject of premanufacture notices (PMN). This action will require persons who intend to manufacture or process any of these 37 chemical substances for an activity that is designated as...
Archives
The attorneys, scientists, policy experts, and regulatory advisors of Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) endeavor year-round to keep you informed on key developments as they happen, and prepared for looming changes and deadlines, to help you maintain compliance and competitive advantage as you market your products throughout the world. As the new year begins, we offer you this look back at the top stories of...
October 28, 2016
EPA Proposes SNUR for Functionalized Carbon Nanotubes (Generic)
On October 27, 2016, the U.S. Environmental Protection Agency (EPA) proposed significant new use rules (SNUR) for three chemical substances that were the subject of premanufacture notices (PMN), including functionalized carbon nanotubes (generic). According to the notice, the PMN states that the substance will be used as a thin film for electronic device applications. Based on structure-activity relationship (SAR) analysis of test data on analogous carbon nanotubes and other...
On July 28, 2016, the U.S. Environmental Protection Agency (EPA) proposed to update the Toxic Substances Control Act (TSCA) Significant New Use Rule (SNUR) procedures. 81 Fed. Reg. 49598. As discussed in our previous memorandum on this proposed rule, Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards, while some of the proposed changes are not consequential, other changes, such as those related to workplace protections, are more clearly...
On July 28, 2016, the U.S. Environmental Protection Agency (EPA) proposed changes to the existing regulations governing significant new uses of chemical substances under the Toxic Substances Control Act (TSCA) to align these regulations with revisions to the Occupational Safety and Health Administration’s (OSHA) Hazard Communications Standard (HCS), as well as changes to the OSHA Respiratory Protection Standard and the National Institute for Occupational Safety and Health (NIOSH) respirator...
On July 26, 2016, the U.S. Environmental Protection Agency (EPA) issued a notice in the Federal Register soliciting a second round of comments on the burdens and value of information it periodically collects addressing significant new use rules (SNUR) for existing chemicals. Specifically, EPA submitted a request to renew the approval of an existing information collection request (ICR), Toxic Substances Control Act (TSCA) Section 5(a)(2) SNURs for Existing Chemicals, to...
On May 16, 2016, the U.S. Environmental Protection Agency (EPA) promulgated, through a direct final rule, significant new use rules (SNUR) for 55 chemical substances that were the subject of premanufacture notices (PMN), including functionalized carbon nanotubes (CNT) (generic). EPA states that it determined that any use of the functionalized CNTs without the use of impervious gloves, where there is potential for dermal exposure; manufacturing the PMN substance for use other than as a thin...
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...
June 11, 2015
EPA Promulgates SNUR for Graphene Nanoplatelets
On June 5, 2015, the U.S. Environmental Protection Agency (EPA) promulgated through a direct final rule significant new use rules (SNUR) for 22 chemical substances that were the subject of premanufacture notices (PMN), including graphene nanoplatelets having a predominant thickness of 1-10 layers with lateral dimension predominantly less than 2 microns (PMN Number P-14-763). This substance is subject to a Toxic Substances Control Act (TSCA) Section 5(e) consent order that includes the following...
May 15, 2015
EPA Issues SNURs For Several Biobased Chemicals
On May 8, 2015, the U.S. Environmental Protection Agency (EPA) issued a direct final rule for 25 chemical substances that were the subject of premanufacture notices (PMN), including several biobased chemical substances. The rulemaking under Section 5, known as a significant new use rule or SNUR, requires persons who intend to manufacture (including import) or process any of these 25 chemical substances for an activity that is designated in the SNUR as a significant new...