Importers of these compounds now must also certify compliance with SNUR requirements.
EPA is promulgating these SNUR requirements through use of direct final procedures that require at least 90 days' notice to the Agency before ".
When it comes to potential challenges, however, some of the chemical compounds included in EPA's SNUR list include:
While these SNUR factors are the same for any chemical, the question being raised by the regulators and other interested parties is when to apply SNUR to a nanoscale version of a chemical already listed in the TSCA Inventory.
Other parties believe that at the molecular level, silver is silver and carbon is carbon, making the application of SNUR inappropriate.
Risk managers must also be cognizant that chemicals or substances that do not qualify under TSCA as hazardous in the normal scale may well be classed as a SNUR or a new chemical in the nanoscale.
EPA Issues Final SNURs
for Carbon Nanotubes [weblog entry], Nanotechnology Law Blog (17 Sep 2010).
EPA is also proposing that the general SNUR article exemption for persons who import or process chemical substances as part of an article would not apply because TDI and related compounds are volatile and could migrate out of articles that contain them.
EPA is particularly interested if there are any uses of these seven TDI compounds currently ongoing that are not exempted in the proposed SNUR.
This is, in part, due to the fact that the proposed SNUR only requires importers to notify EPA when chemicals on the TSCA registry are brought into the U.
This issue is something that EPA is specifically seeking public comment on as part of the SNUR development process, and the agency will accept comments until February 4, 2005.
establish a notice requirement for manufacturers that want to produce the chemicals in ways that differ from terms set forth in the consent orders and notices and also adopt those conditions so they apply to other manufacturers that want to make the same substances.