James Votaw Quoted in Inside TSCA Article, "EPA Decouples Fate of SNUR ‘Framework' Rule from Upcoming PMN Reforms"

Date: Oct 22, 2020

Keller and Heckman Partner James Votaw was quoted in the Inside TSCA article, “EPA Decouples Fate of SNUR ‘Framework’ Rule from Upcoming PMN Reforms.” The article discusses how EPA says it is planning to align two upcoming rules governing its new chemicals program under TSCA section 5 even though release of a long-overdue “framework” regulation for significant new use rules (SNURs) will happen independently of its proposed revisions to the premanufacture notification (PMN) process for new chemicals.

The Obama administration proposed the SNUR “framework” rule in July 2016, one month after enactment of the Launtenberg amendments to the Toxic Substances Control Act. But it has stalled at EPA even while the agency earlier this year announced plans for proposed revisions to the PMN process to help meet its 90-day deadline for action on submissions established by the revised toxics law.

Because both the stalled proposed and final rules are focused on revisions to the TSCA new chemicals program, some industry sources have questioned whether the final SNUR rule is being held up to allow time for the proposed PMN revisions to be developed. EPA rejects that linkage while asserting the rules will be aligned.

Mr. Votaw noted, “They want to move this quickly, and they want to meet their 90 day” deadline for reviewing PMN submissions under TSCA section 5.”

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