March 25, 2015 — As part of the Agency’s effort to ensure a more comprehensive understanding of nanoscale materials in commerce, EPA proposed one-time reporting and recordkeeping requirements under TSCA section 8(a). This proposed rule would require that companies that manufacture certain chemical substances already in commerce as nanoscale materials notify EPA of information including production volume, methods of manufacture and processing, exposure and release information, and available health and safety data… EPA would use information gathered through this reporting rule to determine if any further action under TSCA, including additional information collection, is needed. EPA will accept comments on the proposed rule for 90 days after the date of publication in the Federal Register.
Comment
The proposal would be more useful if the burden of reporting was risk based. In our view, the great majority of nano materials could reasonably be regarded as general dust when present in breathable air at less than 0.1 mg.m-3. Those that should not automatically be regarded as general dust can be identified using the APA scale developed by Re: Liability (Oxford) Ltd.
The APA scale makes use of what little generalisable knowledge there is to date and will be revised as further data is published. It has been validated against leading judgments. EPA’s scheme will cause a flood of uninteresting data.
The APA scale will be made available for general use by means of this web site.
