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Developments in the Regulation of Carbon Nanotubes Under TSCA

Beveridge & Diamond, P.C., December 14, 2010

Carbon nanotubes (CNTs) promise a myriad of advantages over traditional materials due to their strength, electrical conductivity, and other remarkable properties.  Yet preliminary studies have already identified CNTs as potentially posing health risks.  The attached article reviews the multiple activities that the Environmental Protection Agency has taken and plans to take to regulate CNTs under the Toxic Substances Control Act (TSCA) in light of those potential risks.

EPA’s primary tool in regulating CNTs has been premanufacture review of individual CNTs and subsequent imposition of testing and work practice controls through consent orders, in some cases followed by adoption of a significant new use rule (SNUR) applying those controls to all who may manufacture or process the CNT.  The article examines the nomenclature issues underlying the premanufacture notification (PMN) requirement for CNTs and identifies PMNs known to have been submitted for CNTs and their resulting consent orders and SNURs.

In addition, EPA has required the submission of toxicological information on CNTs through consent orders and through section 8(e) of TSCA.  The article identifies the CNT submissions under section 8(e) to date.  It also reviews the test rule, categorical SNUR, and reporting rule for various nanomaterials, including CNTs, that EPA plans to propose in 2011. 

To read the full article, please click here

For more information, please contact Mark Duvall at mduvall@bdlaw.com or Andie Wyatt at awyatt@bdlaw.com.

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