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Submitting a Significant New Use Notice (SNUN)

Under section 5(a) of TSCA and 40 CFR part 721, if EPA promulgates a Significant New Use Rule (SNUR), a manufacturer or processor wishing to engage in a designated significant new use must submit a Significant New Use Notice (or "SNUN") to EPA at least 90 days before engaging in the new use. In many cases, EPA will need to respond to a SNUN by amending the SNUR to allow companies other than the SNUN submitter (such as the submitter's processor customers) to engage in the newly approved use(s). Note that before EPA amends the SNUR, even after a manufacturer submits a SNUN and the review period expires, processors (and other manufacturers) of the substance are still legally required to submit their own SNUN before engaging in the significant new use. Therefore, potential SNUN submitters should be aware of 40 CFR 721.25(b), which authorizes joint SNUNs by two or more persons -- for example, a manufacturer and several processors.

EPA recommends that submitters consult with the Agency prior to submitting a SNUN to discuss what data may be useful in evaluating a significant new use. Discussions with the Agency prior to submission can afford ample time to conduct any tests that might be helpful in evaluating risks posed by the substance.

SNUNs are reported using the standard PMN form and are subject to a 90-day review process similar to that for a PMN. When submitting a SNUN, the submitter should include a cover letter that provides the CFR citation of the SNUR and identifies the specific significant new use(s) for which the SNUN is being submitted.

If you submit a SNUN to EPA, you are required to use the electronic-PMN ("e-PMN") software as discussed in the "e-PMN" final rule (75 FR 773) (PDF) (18 pp, 110K, about PDF). You must use the PMN module within the e-PMN software to submit your SNUN. On page 1 of the PMN module, be sure to check the box stating the type of notice you are submitting is a SNUN.

As of April 6, 2012, all new SNUN submissions and support documents must be submitted electronically to EPA using the e-PMN software via the Central Data Exchange (CDX). All support documents associated with SNUN submissions submitted on or after April 6, 2010 must also be submitted electronically using the e-PMN software via CDX. As of March 4, 2014, all support documents for SNUNs submitted before April 6, 2010, must also be submitted electronically using the e-PMN software via CDX. Refer to www.epa.gov/cdx, the CDX Registration Guide (PDF) (44 pp, 8.6MB, about PDF), or the CDX Helpful Hints (PDF) (10 pp, 41K, about PDF) for directions on how to register and submit notices via CDX.

 


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