EPA has published a direct final rule on a set of 10 new chemicals for Significant New Use reporting (SNURs). [And another set of 43 chemicals published the next day.] Some are on new chemicals that received consent orders under the PMN program, others because of potential risks if used other than described in their PMN. SNURs are worth a look because they indicate what EPA is worried about and how they respond to those worries for classes of chemicals.
Of note:
mono and multi-walled carbon nanotubes: restrictions include full face respirators, <1 ppb release in waste water, limits on volumes manufactured and uses other than what was in the PMN. To maybe get out of the SNUR, the following testing might work:
a 90-day inhalation toxicity study in rats (OPPTS Test Guideline 870.3465 or Organisation for Economic Co-operation and Development (OECD) Test Guideline 413) with a post-exposure observation period of up to 3 months, including bronchoalveolar lavage fluid (BALF) analysis, a determination of cardiovascular toxicity (clinically-based blood/plasma protein analyses), and histopathology of the heart; and certain physical/chemical properties, would help characterize possible effects of the substance.MDI polymer: where EPA is concerned about sensitization so requires a respirator and dermal protection and no consumer use. Doing a sensitization study and a 90 day inhalation might void the SNUR.
A couple fatty acid compounds: where EPA is worried about aquatic toxicity and discharge to water.