The Backstory
Carbon nanotubes (CNT) are used to increase the strength and rigidity of composite materials in a variety of applications, from ice hockey sticks to boat hulls. Burgeoning new uses, such as the creation of electrically conducting CNT fibers and supercapacitors could change the way we transfer and store energy—that is, if these new materials can be manufactured and used safely, without risk to human health or the environment. Unfortunately, CNT dust can pack quite a punch to your lungs, causing pulmonary toxicity and tumor formation when inhaled in doses likely to be encountered during manufacturing and processing.
What’s Changing
Enter EPA, who recently proposed a Significant New Use Rule (SNUR), under the Toxic Substances Control Act, Section 5(a), on June 8, 2017, which would require manufacturers of “multi-walled carbon nanotubes and other classes of carbon nanotubes” to mitigate inhalation risks by using respirators, monitoring dust levels, and prohibiting applications that involve the generation of a vapor, mist or aerosol, to name a few of the stipulations. Any uses of CNT that do not comply with these requirements would be deemed a new “use,” and that new use would require official notification to EPA at least 90 days prior to manufacturing, so that EPA can properly evaluate the new use and assign appropriate risk management measures; manufacturing cannot commence until EPA has completed this evaluation.
Implications
If you’re a manufacturer or processor of multi-walled or other CNT, now is the time to recognize that changes are likely coming. If the proposed new rule is adopted without amendment, those changes will not only include mandatory use of appropriate personal protective equipment, but also the more laborious tasks of dust testing, per European Standard EU 15051; generation of extensive physical and chemical property data; along with the standard substance identity data requirements accompanying regulatory filings under TSCA. Anticipating these additional regulatory burdens, planning accordingly and budgeting for the additional resources needed, are all wise strategies to ensure the continuity of your operation.
