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April 6, 2015

Comments Due July 6 on Proposed Reporting and Recordkeeping Requirements for Nanoscale Materials

Lynn L. Bergeson

The U.S. Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA) Section 8(a) proposed rule concerning reporting and recordkeeping requirements for certain chemical substances when manufactured or processed at the nanoscale was published in the April 6, 2015, Federal Register.  EPA proposes to require persons that manufacture or process these chemical substances to report electronically to EPA certain information, including the specific chemical identity, production volume, methods of manufacture and processing, exposure and release information, and existing data concerning environmental and health effects.  EPA also proposes to require any persons who intend to manufacture or process chemical substances as discrete nanoscale materials after the effective date of the final rule to notify EPA of the same information at least 135 days before the intended date of commencement of manufacture or processing.  Comments on the proposed rule are due July 6, 2015.  More information is available in Bergeson & Campbell, P.C.’s March 25, 2015, memorandum.