Biobased Chemical Manufactures Subject to Significant New Use Rules
Chemical manufacturers — including those that make several biobased chemicals — will soon be required to notify the EPA at least 90 days before manufacturing, importing or processing 25 chemical substances, according to an EPA rule that will go into effect July 7.
The EPA’s new rule covers significant new use rules (SNURs) for 25 chemical substances that were the subject of premanufacture notices (PMN).
The SNURs require companies that plan to manufacture, import or process any of these 25 chemical substances for an activity that is designated in the SNUR as a significant new use to notify the EPA at least 90 days in advance. This allows the agency to evaluate the intended use and, if necessary, to prohibit or limit it.
The draft final rule includes SNURs for several biobased chemicals. The SNURs for fatty acids, satd. and unsatd alkyl-, esters with polyol (generic) (PMN Number P-13-139) and fatty acids reaction products with polyethylenepolyamine and naphthenic acids (generic) (PMN Numbers P-14-616 and P-14-617) limit uses of those substances to those in the PMNs, but that aquatic toxicity testing could demonstrate lower hazard and obviate the need for the SNUR. A SNUR for 1,2,3-propanetriol, homopolymer, dodecanoate (PMN Number P-14-395), which could be a biobased chemical, limits “use of the substance that results in releases to surface waters exceeding 18 ppb.”
The Biobased and Renewable Products Advocacy Group says when submitting PMNs to the EPA for new biobased chemicals, companies should keep in mind that robust pollution prevention statements can offset possible concerns by putting the new biobased substance in a risk context with incumbent technologies that it may replace.
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