Posts Tagged ‘SNURs’


EPA has published another batch of 37 Significant New Use Rules (SNURs) on chemicals that had been premanufacture noticed (PMN’d).  Only 17 of them had consent orders.  Isocyanates, siloxanes, nanocarbons predominate.

Make sure you are reviewing these for possible applicability – especially if the use is not “new” to you.

Also make sure your vendors are notifying you if there are restrictions on the use of their products.  TSCA compliance is not only an issue of being listed on the Inventory.


Contact EHS Strategies, Inc. for help.


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SNURs: TSCA Notifications Multiply

EPA is on a tear issuing Significant New Use Rules (SNURs) under TSCA.  Mostly for new chemicals that hit triggers under PMN reviews.  Make sure you are reading notifications from suppliers – often on MSDS – that may affect how you can use the chemical (e.g., workplace protections and disposal restrictions) and trigger export notifications to EPA under section 12.

Watch the Federal Register! Recent notices here and here

Contact EHS Strategies, Inc. for help with SNURs

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March 20, 2012, has issued it’s first set of proposed SNURs and a testing rule on articles.  [See box on right for your favorite chemical]

Nobody is making these chemicals in the US (“voluntary” ban), but they could come in with imported articles: polybrominated diphenylethers (PBDEs and adding decabrom to the current SNUR on PBDEs), benzidine dyes, a short chain chlorinated paraffin, hexabromocyclododecane (HBCD use in consumer textiles only), and phthalate di-n-pentyl phthalate (DnPP).

The agency is also proposing additional testing on the health and environmental effects of PBDEs if you have existing “ongoing” uses – threatening for the first time that testing will apply to article importers (and anyone still processing inventories of PBDE) as of the date of the final test rule.  Yet another incentive to stop using PBDEs.

And don’t forget a proposed SNUR triggers export notice under TSCA 12(b).

NEW 6/15/12: The Chemical Users Coalition (CUC) has submitted comments on the need for a framework on covering articles under SNURs, recommending much more targeted approach in rare cases of concern.  I agree, but think this should be even broader (especially given TSCA Reform proposals) on how TSCA in general should tackle articles.  It’s a logistical nightmare of companies who have never dreamed they could be impacted by TSCA and fraught with communication difficulties now surfacing with REACH SVHC and Conflict Minerals.  We need a multi-stakeholder discussion of the issues.

Comments are accepted until July 31, 2012.

Contact EHS Strategies, Inc. for help.

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Attention Chemical Manufacturers, Importers and Exporters!

EPA has issued a final test rule on the third batch of HPV (High Production Volume) that are still “orphans” not picked up in the voluntary testing program.

In addition, the agency has gotten creative on the last batch of 45 HPV orphans using the 2006 IUR data and authority to do either test rules or Significant New Use Rules (SNUR) : (a) 23 chemicals are proposed for testing, considering a proposed alternative of a Significant New Use Rule (SNUR) as a back up if it turns out they don’t appear to yet exceed the high exposure threshold for supporting a test rule – defined as no ongoing use in a consumer product and no ongoing use reasonably likely to expose 1,000 or more workers ; (b) 22 chemicals are proposed for a SNUR because they don’t think there is sufficient exposure, but considering a proposed test rule as an alternative back up if comments show there is sufficient exposure. Presumably, EPA would propose  a separate notice if they decide to go with the alternatives for either set of chemicals after reviewing comments on this proposal, rather than do a direct final, since they haven’t published proposed rule language, but you never know….

Check to see if your chemical is listed and figure out what you’ve got to do.  EHS Strategies, Inc. can help.

Final Test Rule Batch 3 HPV   See October 21, 2011, FR notice for details on the testing required of manufacturers and importers here. Remember this triggers 12(b) export notice. The chemicals:

98–09–9  Benzenesulfonyl chloride
98–56–6 Benzene, 1-chloro-4-(trifluoromethyl)-
111–44–4  Ethane, 1,1′-oxybis[2-chloro-
127–68–4  Benzenesulfonic acid, 3-nitro-, sodium salt (1:1)
515–40–2  Benzene, (2-chloro-1,1-dimethylethyl)
2494–89–5  Ethanol, 2-[(4-aminophenyl)sulfonyl]-, 1-(hydrogen sulfate)
5026–74–4  2-Oxiranemethanamine, N-[4-(2-oxiranylmethoxy)phenyl]-N-(2- oxiranylmethyl)
22527–63–5  Propanoic acid, 2-methyl-, 3-(benzoyloxy)-2,2,4-trimethylpentyl ester
25321–41–9  Benzenesulfonic acid, dimethyl-
52556–42–0  1-Propanesulfonic acid, 2-hydroxy-3-(2-propen-1-yloxy)-, sodium salt (1:1).
68082–78–0  Lard, oil, Me esters
68442–60–4 Acetaldehyde, reaction products with formaldehyde, by-products from
68610–90–2  2-Butenedioic acid (2E)-, di-C8-18-alkyl esters
70693–50–4  Phenol, 2,4-bis(1-methyl-1-phenylethyl)-6-[2-(2-nitrophenyl)diazenyl]
72162–15–3 1-Decene, sulfurized

Proposed Test Rule/Back up SNUR: October 21, 2011 FR notice here. Chemicals:

56-40-6 Glycine
67-72-1 Ethane, 1,1,1,2,2,2-hexachloro-
78-00-2 Plumbane, tetraethyl-
95-14-7 1H-Benzotriazole
118-48-9 2H-3,1-Benzoxazine-2,4(1H)-dione 128-44-9 1,2-Benzisothiazol-3(2H)-one,1,1-dioxide, sodium salt (1:1)
928-72-3 Glycine, N-(carboxymethyl)-, sodium salt (1:2)
1809-19-4 Phosphonic acid, dibutyl ester
25377-73-5 2,5-Furandione, 3-(dodecen-1-yl)dihydro-
26544-38-7 2,5-Furandione, dihydro-3-(tetrapropenyl)-
27859-58-1 Butanedioic acid, 2-(tetrapropenyl)-
28777-98-2 2,5-Furandione, dihydro-3-(octadecen-1-yl)-.
29385-43-1 1H-Benzotriazole, 6(or 7)-methyl-
32072-96-1 2,5-Furandione, 3-(hexadecen-1-yl)dihydro-
61789-73-9 Quaternary ammonium compounds,benzylbis(hydrogenated tallow alkyl)methyl,chlorides
64665-57-2 1H-Benzotriazole, 6(or 7)-methyl-, sodium salt
68131-13-5 Naphthenic acids, reaction products with diethylenetriamine 68153-60-6 Fatty acids, tall-oil, reaction products with diethylenetriamine, acetates
68424-85-1 Quaternary ammonium compounds,benzyl-C12-16-alkyldimethyl,chlorides
68442-77-3 2-Butenediamide, (2E)-, N1,N4-bis[2-(4,5-dihydro-2-nortall-oil alkyl-1H-imidazol-1-yl)ethyl] derivs
68607-28-3 Quaternary ammonium compounds,(oxydi-2,1-ethanediyl)bis[cocoalkyldimethyl, dichlorides
68909-18-2 Pyridinium, 1-(phenylmethyl)-, Et Me derivs., chlorides
69834-17-9 Benzene, decylphenoxy-

Proposed SNUR/Back up Test Rule: October 21, 2011 FR notice here. The Significant New Uses are: (i) Use in a consumer product. (ii) Any use, or combination of uses, that is reasonably likely to expose 1,000 or more workers at a single corporate entity (defined as the aggregate of all of the domestic facilities owned or operated by an individual corporation). Reminder: proposed SNURs trigger 12(b) export notices. Chemicals:

98-16-8 Benzenamine, 3- (trifluoromethyl)-
100-53-8 Benzenemethanethiol 104-91-6 Phenol, 4-nitroso-
110-03-2 2,5-Hexanediol, 2,5-dimethyl-
124-63-0 Methanesulfonyl chloride. 142-30-3 3-Hexyne-2,5-diol, 2,5- dimethyl-
460-00-4 Benzene, 1-bromo-4-fluoro-
542-92-7 1,3-Cyclopentadiene 553-26-4 4,4′-Bipyridine
8007-45-2 Tar, coal
28106-30-1 Benzene, ethenylethyl-
35203-06-6 Benzenamine, 2-ethyl-6-methyl-N-methylene-
35203-08-8 Benzenamine, 2,6-diethyl-N-methylene-
37734-45-5 Carbonochloridothioic acid, S-(phenylmethyl) ester
37764-25-3 Acetamide, 2,2-dichloro-N,N-di-2-propen-1-yl-
61789-72-8 Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl, chlorides
61790-13-4 Naphthenic acids, sodium salts
65996-91-0 Distillates (coal tar), upper
68308-01-0 Tail gas (petroleum), cracked distillate hydrotreater stripper
68478-20-6 Residues (petroleum), steam-cracked petroleum distillates cyclopentadiene conc., C4-cyclopentadiene-free
68526-82-9 Alkenes, C6-10, hydroformylation products, high-boiling
68909-77-3 Ethanol, 2,2′-oxybis-, reaction products with ammonia, morpholine derivs residues

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Flexing TSCA muscles:  EPA is proposing a Significant New Use Rule (SNUR) on a set of 14 “glymes” of concern for reproductive effects.  SNURs offer EPA an opportunity to review proposed new uses and deny or restrict future specific commercial applications.  One of the problems with SNURs to control chemical exposure is that these rules do not apply to existing uses, of which there apparently are some, although not in high volumes.  Users are able to notify EPA of their current use to get exempt from the SNUR.  The focus is mostly on preventing new consumer uses.

Published 7/12/11 here

Reminder – proposed SNURs trigger export notification under TSCA 12(b) for the listed chemicals, whether or not your use is exempt.

Contact EHS Strategies, Inc. if you need help.

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