EPA Proposes New Use Rule for Multi-walled Carbon Nanotubes

Anyone intending to manufacture, import, or process them for an activity that is designated as a significant new use would have to notify EPA at least 90 days in advance, giving the agency time to evaluate the intended use and bar it, if necessary.

The Environmental Protection Agency has proposed a significant new use rule, called a SNUR, under section 5(a)(2) of the Toxic Substances Control Act for multi-walled carbon nanotubes. The proposed rule does not identify all types of companies or organizations that would be affected, but it does say manufacturers, importers, or processors of the tubes (NAICS codes 325 and 324110), such as chemical manufacturing and petroleum refineries, could be.

If the rule is finalized, anyone intending to manufacture, import, or process multi-walled carbon nanotubes for an activity that is designated as a significant new use would have to notify EPA at least 90 days in advance, giving the agency time to evaluate the intended use and prohibit it, if necessary.

EPA is accepting comments until March 5, 2010 (citing docket ID number EPA-HQ-OPPT-2009-0686) via www.regulations.gov.

Section 5(a)(2) of act says EPA must consider all relevant factors before determining a use of a chemical substance is a significant new use, including:

  • projected volume of manufacturing and processing of the substance
  • extent to which a use changes the type or form of exposure of human beings or the environment to the substance
  • extent to which a use increases the magnitude and duration of exposure of human beings or the environment to the substance
  • reasonably anticipated manner and methods of manufacturing, processing, distribution in commerce, and disposal of the substance

EPA said it also considered relevant information about toxicity, likely human exposures, and environmental releases associated with possible uses in this case.

This SNUR applies only to the multi-walled carbon nanotubes described in P-08-199 as generic multi-walled carbon nanotubes (no CAS number available) that will be used as an additive/filler for polymer composites and support media for industrial catalysts. "Based on test data on analogous respirable, poorly soluble particulates and on other carbon nanotubes (CNTs), EPA identified concerns for lung effects, immunotoxicity, and mutagenicity from exposure to the . . . substance," the proposed rule states. "For the uses described. . . , worker inhalation and dermal exposures are minimal due to the use of adequate personal protective equipment. Therefore, EPA has not determined that the proposed manufacturing, processing, or use of the substance may present an unreasonable risk. EPA has determined, however, that use of the substance without the use of gloves and protective clothing, where there is a potential for dermal exposure; use of the substance without a National Institute for Occupational Safety and Health (NIOSH)-approved full-face respirator with an N100 cartridge, where there is a potential for inhalation exposure; or use other than as described . . . may cause serious health effects."

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