Octanoic acid, hydrazide

An example of a SNUR is the one for octanoic acid, hydrazide, in 721.5385. That SNUR says in full ... 

The cross-reference to 721.63(a)(3) adds that it would be a significant new use to manufacture, import, or process a substance without demonstrating that the personal protective equipment used provides an impervious barrier to prevent dermal exposure under normal and expected working conditions. It adds that the only acceptable demonstrations that the personal protective equipment is impervious to the SNUR substance, in combination with other chemicals in the work area, are specific types of testing, or an evaluation of the manufacturer s specifications or a sample of the materials used in the personal protective equipment. Therefore, anyone who intends to manufacture, import, or process octanoic acid, hydrazide must be able to demonstrate either through testing or evaluation of specifications or a sample, that the personal protective equipment to be used is impervious to the SNUR substance. If the prospective manufacturer, importer, or processor cannot make that demonstration, it must submit a SNUN at least ninety days prior to engaging in that activity. 

To make SNURs such as the one appUcable to octanoic acid, hydrazide even more difficult to interpret, the procedure describing the bona fide letter is in another SNUR instead of one of the subparts of the SNUR regulations that have general applicability. The reference in the octanoic acid, hydrazide SNUR to determining if a use of the substance is a significant new use by following the provisions of 40 C.F.R. 721.1725(b)(1) is in fact a reference to the bona fide letter procedure set out in the SNUR for benzoic acid, 3,3 -methylenebis [6 amino-, di-2-propenyl ester]. ... 

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