Significant New Use Rules on Certain Chemical Substances (25-3.5e)

The Environmental Defense Fund (EDF) argues that the proposed Significant New Use Rules (SNURs) are inconsistent with the EPA's own rationale and existing consent orders. They request that the EPA update the final rule to include a requirement for chemical goggles or equivalent eye protection to ensure all manufacturers and processors are held to the same safety standards.

Cnano Technology USA, Inc. expresses strong support for the proposed Significant New Use Rule (SNUR) for its multi-walled carbon nanotube substance (P-22-163). The company requests that the EPA expedite the finalization and publication of the rule, noting that the proposed language aligns with existing precedents and allows for responsible commercialization.

Michael Ravnitzky requests specific clarifications and revisions to the proposed Significant New Use Rules to ensure regulatory clarity and enforceability. He argues for more precise chemical identity blocks, clearer reporting bases for weight limits, defined analytical methods for low toxicity thresholds, and more flexible engineering control maintenance schedules.