Course Overview

This two-day course is intended for those who need to learn how to prepare Premanufacture Notices (PMNs), Significant New Use Notices (SNUNs), and PMN Exemption Applications.  It assumes that attendees are already acquainted with the U.S. Environmental Protection Agency's (EPA's) new chemicals program and with the corresponding regulations promulgated by EPA under Section 5 of the Toxic Substances Control Act (TSCA).

Thus, the course begins with a brief review of the TSCA Inventory, Premanufacture Notification (PMN) requirements, PMN exemption eligibility criteria, and Significant New Use Rules (SNURs).  It continues with an introduction to the e-PMN final rule and the eTSCA/e-PMN software.  Then, the course moves on to a detailed discussion of the PMN preparation process using the software, including general instructions for completing the PMN form, as well as step-by-step instructions for each of the three parts of the form.  That's followed by a discussion of EPA's PMN Review Process.  Finally, the course concludes by discussing the possible outcomes of the review process, the means by which a submitter can track the status of a PMN as it moves through the process, and the Sustainable Futures Initiative, under which chemical manufacturers and importers can access the same risk-screening models that EPA uses to evaluate new chemicals before they enter into commerce.

Regulatory Coverage

This course is based primarily upon EPA regulations regarding:

• Premanufacture Notification at 40 CFR Part 720;
• Significant New Uses of Chemical Substances at 40 CFR Part 721; and
• Premanufacture Notification Exemptions at 40 CFR Part 723.

Course Agenda

The course material is divided into nine modules, as shown below.

1. Review of the TSCA Inventory
2. Review of Section 5 Requirements
3. The e-PMN Final Rule
4. General Instructions for Reporting
5. Part I - General Information
6. Part II - Human Exposure and Environmental Release
7. Part III - List of Attachments
8. EPA's PMN Review Process
9. Course Wrap-Up

Prerequisites

Completion of ChemADVISOR's TSCA Essentials course or equivalent knowledge.

Upcoming Course Dates