New Significant New Use Rules for Twenty Chemicals
On Friday, November 2, 2012, the Environmental Protection Agency promulgated Significant New Use Rules (SNURs) for twenty chemicals which had previously been subject to the Pre-Manufacture Notification (PMN) rules under TSCA. Anyone who intends to manufacture, import, or process any of the twenty chemicals for any activity that is deemed a “significant new use” is required to notify EPA 90 days prior to beginning the activity.
The Difference Between a SNUR and a Consent Order
During the new chemical review (PMN, or Pre-Manufacture Notification) process, the EPA has the option of establishing a TSCA Section 5(e) consent order restricting the manufacture/import, process, use, and/or disposal of a substance that is determined to pose unreasonable risk of injury to human health and/or the environment. However, a Section 5(e) order is only binding on the initial manufacturer or importer (i.e., the person who submitted the PMN to EPA for review). The SNUR allows EPA to apply those same restrictions set out in the 5(e) rule to subsequent manufacturers, importers, and processors.
EPA Definition of “Significant New Use”
For each chemical listed in a significant new use rule, EPA establishes criteria for what constitutes a “significant new use” of that chemical. Typically, these criteria include, but are not limited to, any uses:
•That require specified personal protection;
- Where a specified hazard communication program has not already been developed;
- Resulting in incineration or land disposal; and/or
- Resulting in release to the water.
What Is a Significant New Use Notification (SNUN)?
After the Agency has promulgated a SNUR for a chemical, each person who intends to use that chemical in a significant new way covered by the SNUR must submit a Significant New Use Notification (SNUN) to the EPA at least 90 days prior to beginning the activity. The SNUN must be submitted on EPA Form 7710-25 (which is also the PMN form).
Since April 6, 2011, the EPA no longer accepts paper submissions. As of April 6, 2012, the EPA also stopped accepting submissions on CD-ROM. All SNUNs must be submitting using the EPA’s Central Data Exchange (CDX).
The full November 2 rule, which lists all twenty chemicals and gives the SNUR criteria for each, can be found here.
Have you found the EPA’s new Central Data Exchange (CDX) to be helpful? Share below.
Get expert training on SNUR, PMNs, and more TSCA topics at Lion’s TSCA Regulations Online Course. This comprehensive online course will help you better understand how the TSCA chemical reporting system works.
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