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ASDWA TSCA SNUR Comments Emphasize the Need for a Holistic Federal Approach on Chemicals

On July 15, ASDWA submitted comments on the most recent EPA Significant New Use Rule (SNUR) on Certain Chemical Substances under the Toxic Substances Control Act (TSCA) – Significant New Uses of Certain Chemical Substances (20-6.B). This is the third letter of comment that ASDWA has submitted urging EPA to use TSCA authorities as part of a holistic approach to ensure complete consideration of a substance’s lifecycle in the environment, and preventing them from impacting drinking water sources and human health. This includes recommending that EPA’s Office of Pollution Prevention and Toxics (OPPT) coordinate closely with the Office of Ground Water and Drinking Water (OGWDW) to consider additional data and information on analogous chemicals and inform decision-making processes.

ASDWA’s comments also highlight particular concern for five of the chemicals in this SNUR because of their potential impacts to drinking water and human health from releases to surface water; the use and disposal of these chemicals where they can rapidly migrate into ground water and where they are difficult to remove with wastewater treatment; and where EPA has not evaluated risks or assessed exposure for the general population via drinking water ingestion. More data and information about these chemicals in advance of the SNURs would also help ensure that harmful impacts are not found in the future due to the lack of data and information to prevent contamination now. Read ASDWA’s comments here.