EPA effectively has banned the use of the following chemicals by requiring Significant New Use Notifications 90 days prior to resumption or new use via a Significant New Use Rule (SNUR). Such notices will likely be reviewed and rejected by EPA.
Bezidine-based dyes: adds 9 chemicals to an existing SNUR that applies to imported articles, which are normally exempt from PMN/SNURs. This means you better have some mechanism in place to make sure they aren't present in imported goods, such as textiles - testing, certification and indemnification by suppliers or crossed fingers.
DnPP (a phthalate used in PVC): Articles are exempt as usual
Alkanes C 12-13, chloro, a short-chain chlorinated paraffin (SCCP): subject to an earlier enforcement case when EPA broke up the category of chlorinated paraffins to short, medium and long chain versions. The short-chain was imported illegally according to EPA. No one is using the medium and the long chains remain under investigation for future action by EPA.
EHS Strategies, Inc. can help you figure out your responsibilities and responses to this final rule.
- Tags:
- SNURs
- TSCA
- tsca work plans