Global Automakers

Global Automakers and Auto Alliance Joint Comments to EPA on Proposed Nanoscale Materials Rulemaking

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August 5, 2015

Global Automakers submitted joint comments with the Auto Alliance on EPA's proposed rulemaking on nanoscale materials, originally released on April 6, 2015. The comment period was extended to August 5, 2015. The comments addressed the following concerns:

  • EPA should reconsider the extent to which its authority under section 8(a) of TSCA authorizes it to require reporting of information on nanoscale forms of macroscale materials.
  • The Auto Alliance and Global Automakers support EPA’s proposal to exclude nanoscale materials in articles from the scope of the rule.
  • The proposal appropriately avoids a definition of “nanoscale material,” but instead describes the kinds of nanomaterials in which EPA has a current interest.
  • EPA should clarify that the rule would apply only to information, including health and safety information, which is known to, or reasonably ascertainable by, a manufacturer or processor.
  • EPA should limit the scope of the final rule to engineered nanomaterials.
  • EPA should add titanium dioxide to the list of excluded nanoscale materials.
  • The 135-day reporting period would exceed EPA’s statutory authority.
  • The U.S. and Canada should work together on regulation of nanoscale materials.

For more details, see the full text of the comments attached. 


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