Premanufacture Notifications Resources

48 Fed. Reg. 21722 (May 13, 1983) Premanufacture Notification Premanufacture Notice Requirements and Review Procedures 48 FR 21722 PMNs 5-13-83 

51 Fed. Reg. 15096 (Apr. 22, 1986) Toxic Substances Revisions of Premanufacture Notification Regulations 51 FR 15096 PMN Revisions 4-22-86 

60 Fed. Reg. 16298 (Mar. 29, 1995) Premanufacture Notification Revisions of Premanufacture Notification Regulations Final Rule 60 FR 16298 PMN Revisions 3-29-95 

65 Fed. Reg. 19618 (Apr. 11,2000) Incentives for Self-Policing Discovery, Disclosure, Correction and Prevention of Violations 65 FR 16298 Audit 

67 Fed. Reg. 76282 (Dec. 11, 2002) Sustainable Futures—Voluntary Pilot Project Under the TSCA New Chemicals Program Notice 67 FR 

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Where in a product s life a regulation such as TSCA is imposed becomes important in terms of resource diversion. Ideally, imposition of Premanufacture Notification after scale-up and successful line trials would necessitate filing notifications only for those products that actually become commercial. In the usually compressed Coatings and Resins lifeline, this is not always, and in fact very seldom, possible. 

Chemical manufacturers submitted 1,031 Premanufacture Notifications in 1980 and 1981. In the same time period, they submitted 290 notifications of commencement of commercial manufacture. In other words, only 28)1 of the substances for which Premanufacturing notices were filed in the past two years of compliance have become commercial. Specifically, for the reactive polymer segment, about 29% of the reported substances have become commercial. These percentages indicate that much of what has constituted the impacts of TSCA has been "protective" filing of notifications. The length and complexity of the process mandated by TSCA has led to unnecessary resource diversion. A more liberal definition of what constitutes a commercial event could have significantly increased the percentages and reduced this type of impact, at least since July, 1979. 

Wastes are chemical substances subject to TSCA, and each import of waste into the country requires a positive certification, even if the wastes are accompanied by a manifest as required under the Resource Conservation and Recovery Act or consist entirely of byproducts, which are not subject to the premanufacturing notification requirements. ... 

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