Optional Pollution Prevention Information

PMN submitters have the option of submitting information on the pollution prevention benefits of the PMN substance with the PMN form. This is an opportunity to tell the EPA about the environmental benefits expected from the new chemical. These could be more efficient use of natural resources, reductions in the amount of waste generated by use of the substance, whether it can be used instead of a more toxic substance, and any other environmental advantages from use of the PMN substance. 

Very confusingly, the regulations define known to or reasonably ascertainable by the submitter to be known to any of its employees or other agents who are associated with the research and development, test marketing, or commercial marketing of the substance for the purposes of this section only. 

The EPA strongly encourages submitters to include the optional pollution prevention information so that it can balance the benefits of using a substance against the potential risksT  

---

Step 3. If the decision in Step 2 is to proceed with fifing an application for an LVE or LoREX exemption, the MRC shall gather information sufficient to describe the substance s chemical identity, physicochemical properties, manufacturing, processing and use information, test data, other data, and optional pollution prevention information. The MRC shall request information from the Product Manager, Production Manager, suppliers in the case of LVE or LoREX substances to be imported, suppliers and manufacturers of precursors and in-house or external chemists as necessary to conclusively determine... 

To characterize the potential for human exposure and environmental release, the PMN submitter must describe occupational exposure, including the estimated number of workers exposed to the substance, the activities during which they would be exposed, and any protective equipment or engineering controls that would reduce exposure. Estimates of environmental release and exposme must include estimates of releases to air, surface water, land, incineration, or other media. The PMN form also requests optional pollution prevention information. The submitter may provide information on how the proposed manufacturing process or use of the new chemical substance contributes to source reduction, recycling achvities, and safer products or processes. The US EPA takes this informahon into account when assessing potential risks. 

POLLUTION PREVENTION OPTIONAL INFORMATION ON WASTE MINIMIZATION... 

POLLUTION PREVENTION OPTIONAL INFORMATION ON WASTE MINIMIZATION (Indicate actions taken to reduce the amount of the chemical being released from the facility. See the instructions for coded items and an explanation of what Information to Include.) ... 

There are currently no published environmental risk criteria for Great Britain with the same status as those for safety in Reducing n sks, protecting people. Information on tolerability of environmental risk has also been produced for options assessment in section 3.7 of Integrated Pollution Prevention and Control (IPPC) and Environmental Assessment and Appraisal of BAT... 

---