TSCA Advisory 03 - III

Effective July 11, 2003

On June 11, 2003, EPA published a direct final rule adding 47 chemicals to the Preliminary Assessment Information Rule (PAIR) in response to requests made by the Toxic Substances Control Act Interagency Testing Committee (ITC). (68 Fed. Reg. 34,832). Chemical manufacturers will be required to submit to EPA by September 9, 2003 basic production, importation, use and exposure information on 43 vanadium chemicals, 1 tin compound, 1 triazine compound, 1 tribromobenzene compound and 1 nitroaniline compound.

TSCA Section 8(a) governs the PAIR, which requires chemical manufacturers, including importers, to submit a one-time report describing general production/importation volumes, end uses and exposure estimates whenever a new chemical is added to the PAIR list of reportable substances.

The ITC initiated these additions because of concerns that the chemicals may persist and bioconcentrate in the environment. Bioconcentration involves the uptake and concentration of a chemical from water. Little toxicity or exposure information is available about the compounds, but there are reports that long-term inhalation exposure to vanadium pentoxide increased the incidence of lung tumors in laboratory mice. Because of this, the ITC concluded that vanadium pentoxide and related compounds may potentially be carcinogenic to humans and thus current worker protection standards might not be sufficiently protective. Anyone who believes the rule is not warranted may submit comments to EPA by June 25, 2003.

If you would like a copy of the document, or need further information about this or other TSCA matters, please contact one of the professionals below:

McKenna Long & Aldridge, L.L.P., distributes its Advisories to clients and friends of the firm free of charge. If you would like to request additions (or deletions) to our distribution list, please call Nina MacLeay at 213-243-6063 or send email to nmacleay@mckennalong.com.