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The Constantly Pending PMN: Low Volume Exemption Applications Are Living Documents

When available, a Low Volume Exemption ("LVE") is an attractive and quicker path to commercial marketing than filing a full premanufacture notification ("PMN") pursuant to the Toxic Substances Control Act ("TSCA"). Specifically, because LVE substances are never listed on...

Year End Nanotechnology Developments

By William J. Walsh, Of Counsel, Pepper Hamilton LLP The Environmental Protection Agency's Inspector General (IG) issued a report, EPA Needs to Manage Nanomaterial Risks More Effectively , December 29, 2011 critiquing EPA's regulation of nanomaterials (i.e., particles or fibers with a diameter...

Upcoming Deadline for TSCA "Polymer Exemption" Notification

An important deadline is approaching for companies that manufacture or import polymers under the Toxic Substances Control Act (TSCA) "polymer exemption".[1] The one-time notification to the U.S. Environmental Protection Agency (EPA) that identifies the number of polymers first manufactured...