ACI Comments on Chemicals Review Program
• The American Cleaning Institute recently commented to
EPA on the agency’s implementation of the New Chemicals
Review Program under the amended TSCA law:
• In implementing the 2016 TSCA amendments, EPA has
considerably slowed the Pre-Manufacture Notice (PMN) and
Significant New Use Notice (SNUN) review processes.
• The PMN and SNUN review processes now result in an
exceptional number of Notice submitters being asked to“volun-tarily” suspend the review process to respond to EPA information
and data requests, often times seeking information heretofore
not necessary for the Agency to conduct its assessment under
Section 5 of TSCA.
• Such delays have made the review process unpredictable,
untimely, and unnecessarily restrictive, yet without clearly enhancing public safety nor reducing environmental risk.
• With time, the unpredictable and unnecessarily restrictive
nature of EPA’s New Chemicals Program review process will
inhibit chemical innovation in the US and encourage offshore
manufacturing and processing, depriving American citizens of
important new technologies and eventually jobs.
• Newer chemical specialty products often represent in-
novative new chemistries that are produced using improved
manufacturing and processing techniques that reduce risks, ex-
posures and energy use. Discouraging the introduction of these
new products by delaying market entry and imposing unneces-
sary testing costs will impede commercial use of such risk-reduc-
ing products and their methods of manufacture and processing
in the US.
EPA can implement changes to its New Chemicals Program
review process that will avoid delays resulting from its implementation of the program while still permitting EPA to meet
deadlines and the requirement to make a finding pursuant to
Section 5(a)( 3) with respect to a PMN or a SNUN which is under
review. The changes would involve: a) encouraging PMN submitters to use the“Binding Option” box on the PMN Form, and b)
EPA timely issuing“short form” Section 5(e) Consent Orders if
necessary, which can be enhanced through the use of“follow-on
Significant New Use Rules” (SNURs).
ACI supports the Agency’s efforts to review new chemical
substances and significant new uses in accordance with the
amended Section 5 of TSCA. To address delays, ACI recommends the Agency commits the focus of the statutory 90-day
review period to assessing and reaching a determination based
on the intended conditions of use described in the Section 5
Notice EPA receives.•
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