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EPA Invites Small Businesses to Review NMP Risk Management Rulemakings

Friday, January 8, 2021 The U.S. Environmental Protection Agency (EPA) announced on January 5, 2021, that it is inviting small businesses, governments, and not-for-profit organizations to participate as Small Entity Representatives (SER) to provide advice and recommendations to two Small Business Advocacy Review (SBAR) Panels. One Panel will focus on EPA’s development of a proposed rule to address unreasonable risks identified in EPA’s recently completed Toxic Substances Control Act (TSCA) risk evaluation for perchloroethylene.  As reported in our December 17, 2020, memorandum, of the 61 conditions of use that EPA reviewed for perchloroethylene, EPA found that 59 present unreasonable risks to workers, occupational non-users (ONU), consumers, and bystanders.  The conditions of use that EPA determined do not present an unreasonable risk are distribution in commerce and industrial and commercial use in lubricants and greases for penetrating lubricants and cutting to

Regulatory Developments Update: December 2020

TSCA/ FIFRA/ TRI, RCRA/ CERCLA/ CWA/ CAA/ PHMSA/ SDWA, COVID-19, FDA, NANOTECHNOLOGY and more: Recent Regulatory Developments Wednesday, December 16, 2020 TSCA/FIFRA/TRI EPA Proposes SNURs For Certain Chemical Substances: On November 16, 2020, the U.S. Environmental Protection Agency (EPA) published proposed significant new use rules (SNUR) for certain chemical substances that are the subject of premanufacture notices (PMN). 85 Fed. Reg. 73007. The proposed SNURs would require persons to notify EPA at least 90 days before commencing manufacture (defined by statute to include import) or processing of any of these chemical substances for an activity that is designated as a significant new use. The proposed SNURs would further require that persons not commence manufacture or processing for the significant new use until they have submitted a significant new use notice (SNUN), and EPA has conducted a review of the notice, made an appropriate determination on the notice unde

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