This is the third and final segment in a series about the commercial impact of EPA’s program for reviewing and approving new chemicals. Why Are SNURs a Big Deal? A frequent retort to a submitter’s objection to a significant new use rule (SNUR) is, “Why is a SNUR a big deal?” Returning to the previous example, if gloves are routinely worn, why would a submitter object to a SNUR (consent orders under the Toxic Substances Control Act have the same effects) requiring glove use? The fact is that SNURs trigger several new recordkeeping requirements. Even if a SNUR duplicates otherwise applicable Occupational Safety and Health Administration requirements, SNURs impose additional supply chain communication, in addition to standard Safety Data Sheet requirements, and additional explanation to downstream customers, especially when those customers are unfamiliar with TSCA requirements.
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