Chemical Users Protest EPA's Broadening Inclusion Of Articles In SNURs

摘要

A coalition of large companies that use chemicals to make their products are raising concerns about what they see as EPA's broad use of a provision to regulate products that are normally exempt from agency regulation, and are questioning the new criteria EPA has introduced for using the provision as well as the agency's economic analysis of the exemption's costs. The Chemical Users Coalition (CUC) raises these issues in April 30 comments on EPA's proposed significant new use rule (SNUR) on toluene diisocyanates (TDI), one of several SNURs EPA has proposed in the past year that remove the Toxic Substances Control Act's (TSCA) usual regulatory exemption for chemicals in articles, or products. The CUC argues that the proposed TDI rule "raises important precedential issues for the TSCA program."See page 2 for details. (Doc. ID: 181299) CUC argues that EPA, in its response to CUC's and other stakeholders' comments regarding its similar decision to add articles to its proposed SNUR on benzidene dyes, lays out new criteria for when it will remove the usual articles exemption, and when it won't, that are extraordinarily broad.