EPA Pauses Enforcement of PIP (3:1) Ban for Six Months

EPA Pauses Enforcement of PIP (3:1) Ban for Six Months – With a Catch | Alston & Bird


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The Environmental Protection Agency has pipped enforcement of a ban on phenol, isopropylated, phosphate (3:1). Our Environment, Land Use & Natural Resources Group discusses why companies must still comply with much of the rule despite a 180-day no-action assurance.
What does the no-action assurance cover?
What other requirements will companies need to comply with?
What is the EPA doing next?
The U.S. Environmental Protection Agency (EPA) has granted temporary partial relief to companies subject to its recent rulemaking that prohibits, with a few exceptions, the processing and distribution of PIP (3:1) and PIP (3:1)-containing articles after March 8, 2021. The move comes after contributions from numerous industry stakeholders in recent days. “PIP” is short for phenol, isopropylated, phosphate (3:1), a chemical used as a flame retardant, plasticizer, and an anti-wear or anti-compressibility additive in coatings, adhesives, sealants, and plastics. PIP is frequently used in the manufacture of products that range from cars to aerospace vehicles to at-home electronics. The PIP rule was published in January 2021 as part of a group of final rules designed to reduce exposure to five persistent, bioaccumulative, and toxic (PBT) chemicals under Section 6(h) of the Toxic Substances Control Act (TSCA).

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