Nanotechnology and TSCA Reporting

(Resisting the urge to make an obscure Mork and Mindy reference – or an even more obscure mention of Fantastic Voyage…)

EPA has issued guidance on complying with the new Nanotechnology Reporting and Recordkeeping Rule, published in January with an effective date that has been extended to August 14, 2017. The rule establishes one-time reporting and recordkeeping requirements for certain chemical substances when they are manufactured or processed at the nanoscale (i.e., materials that are solids at standard temperature and pressure; that are manufactured or processed in a form where any particles, including aggregates and agglomerates, are in the size range of 1-100 nanometers – that’s one to one hundred billionths of a meter – in at least one dimension) for the purpose of demonstrating one or more unique, size-dependent properties that would not be present in larger materials. Reporting for existing nanomaterials that have been manufactured or processed in the three years prior to the effective date will be due by August 14, 2018.

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