EPA Promulgates SNURs for Two CNT Substances

On July 8, 2014, the U.S. Environmental Protection Agency (EPA) promulgated significant new use rules (SNUR) under the Toxic Substances Control Act (TSCA) for 13 chemical substances that were the subject of premanufacture notices (PMN). The rule includes two PMN substances, P-10-5 and P-11-339, that were the subject of TSCA Section 5(e) consent orders and whose reported chemical names include the term “carbon nanotube” (CNT) or “CNT.” EPA states that, because of a lack of established nomenclature for CNTs, the TSCA Inventory names for CNTs are currently in generic form, e.g., CNT, multi-walled carbon nanotube (MWCNT), double-walled carbon nanotube (DWCNT), or single-walled carbon nanotube (SWCNT).

PMN Number P-10-5

Chemical Name:  Single-walled carbon nanotubes (generic)

CAS Number:  Claimed confidential

The PMN states that the uses of the substance will be as a component for a conductive coating using the PMN substance in a dispersion or ink, and as an additive in resins/thermoplastics/elastomers for mechanical reinforcement.  The consent order requires:

  1. Use of personal protective equipment (PPE);
  2. Use of the substance only as a component for a conductive coating using the PMN substance in a dispersion or ink or as an additive in resins/thermoplastics/elastomers for mechanical reinforcement;
  3. Manufacture of the substance at a volume not to exceed a confidential volume specified in the consent order unless the company has submitted the results of certain health studies and physical/chemical properties data; and
  4. No surface water releases of the PMN substance, except for limited water releases resulting in no more than one part per billion (ppb) waste water effluent concentration determined by monitoring.  The company shall analyze the concentration of the PMN substance in waste water discharged to the city sewer from the facility every year and adhere to the monitoring procedure referenced in the consent order.

The SNUR designates as a “significant new use” the absence of these protective measures.

PMN Number P-11-339

Chemical Name:  Multi-walled carbon nanotubes (generic)

CAS Number:  Claimed confidential

The PMN states that the use of the substance will be as an additive in resins, thermoplastics, and elastomers for mechanical reinforcement and enhanced electrical performance, as a coating on metallic foils for battery applications, or in the manufacture of fabric composites.  The consent order requires:

  1. Use of PPE;
  2. Use of the substance only as an additive in resins, thermoplastics, and elastomers for mechanical reinforcement and enhanced electrical performance, as a coating on metallic foils for battery applications, or in the manufacture of fabric composites;
  3. Manufacture of the substance at a volume not to exceed a confidential volume specified in the consent order unless the company has submitted the results of certain health studies and physical/chemical properties data; and
  4. No surface water releases of the PMN substance, except for limited water releases resulting in no more than one ppb waste water effluent concentration determined by monitoring.  The company shall analyze the concentration of the PMN substance in waste water discharged to the city sewer from the facility every year and adhere to the monitoring procedure referenced in the consent order.

The SNUR designates as a “significant new use” the absence of these protective measures.

The SNURs are effective on September 8, 2014. Written adverse or critical comments or notice of intent to submit adverse or critical comments, on one or more of these SNURs is due August 7, 2014. If EPA receives written adverse or critical comments, or notice of intent to submit adverse or critical comments, on one or more of these SNURs, EPA will withdraw the relevant sections of the direct final rule before its effective date.

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