Consolidated PMNs

There are two situations in which the EPA will review several new chemicals together. The first is when up to six substances have similar chemistry, toxicology, uses, and expected manufacturing or importation quantities. The EPA will accept a single consohdated PMN that covers all of the substances, provided a Prenotice Coordinator has eigreed that the substances are sufficiently similar. There are reduced filing fees for consolidated PMNs. Consolidated PMNs can be filed on two related polymers, one with a specific monomer or other reactant above the two percent rule level so that monomer or reactant is part of the polymer s chemical identity and the other with the same monomer or other reactant below the two percent rule level so that monomer or reactant is excluded from the polymer s chemical identity. 

If a Prenotice Coordinator has preapproved a consolidated PMN the total fee for up to six new substances described in a single consolidated PMN is 8100 for a small business and S2500 for all others. 

PMN Instruction Manual, 14-15. Note that this is primarily an issue of applying the fee for intermediate PMNs instead of consolidated PMNs. 

Step 11. The MRC shall contact an EPA Prenotice Coordinator prior to filing the PMN if the PMN is a consolidated PMN or an intermediate PMN. 

Estimates of production volume, use, exposure, and fate All test data and other data on health and environmental effects Update data during the PMN period A U.S. company must search for relevant data from affiliates Can file consolidated PMNs for similar chemicals... 

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