Regulatory Impacts: SNURs and CPs

摘要

The issue of government regulation is discussed briefly in the main article,but the potential regulation by the U.S.Environmental Protection Agency(EPA)around chlorinated paraffins(CPs)deserves special attention.The EPA regularly creates significant new use rules(SNURs),which”can be used to require notice to EPA before chemical substances and mixtures are used in new ways that might create concerns.” Jeffrey Leiter is an attorney with Bassman,Mitchell,Alfano & Leiter Chtd.,in Washington,D.C.,who represents ILMA.He explained that”EPA's proposed 2018 SNUR would allow medium- and long-chain CPs to be used in metalworking and other listed applications forfive years.Atthe end of this period,users would have to submit a notice to EPA.The agency would then decide whetherto continue to allow the use of the substances.”