| Learning to Live with Revised TSCA: Navigating Significant New Use Rules (SNURs) (PSX 2019 On Demand) | |
| The main driver for amending the United States Toxic Substances Control Act (TSCA) was the perception that little was known about the risk to human health and the environment from the majority of chemicals in commerce. While it underestimates the actual extent of knowledge about chemicals, that perception was based on the fact that ~62,000 of the greater than 85,000 substances on the TSCA inventory were added during the original inventory compilation in 1978 - 79 without a risk evaluation (known as 'existing substances'). A major flaw in 'old TSCA' was that it was extremely difficult for the US Environmental Protection Agency (USEPA, the Agency) to take substantive action on existing substances, even those with well-known risks (e.g., asbestos). The Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) corrected this deficiency, directing the Agency to systematically prioritize existing chemicals for evaluation and, if necessary, apply risk management measures up to and including an outright ban. Initially it seemed that this component of LCSA would have the most significant effect on the chemical industry. It turns out that changes to the Premanufacture Notice (PMN) program for introduction of 'new' substances has had a much larger impact. This talk will focus on these changes, specifically what a finding of 'Not Likely to Present Unreasonable Risk' looks like, the increased use of the Significant New Use Rule (SNUR) to address risk and the components of a SNUR, and strategies to predict the likelihood of a SNUR in the Premanufacture Notice process.
Presenter(s): Jeffrey Hafer, Knoell USA, LLC |
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