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Californian regulator finalise formal information request letter to carbon nanotube producers and importers
Published: Tuesday 23 December 2008
Following an initial announcement in November 2008, in which the California Department of Toxic Substance Control (DTSC) published a notice of intend for a ‘Chemical Information Call-in on Carbon Nanotubes’, the DTSC has reviewed the comments it received in response to the initial questions it posed to the producers of carbon nanotubes, and has updated its website with a list of next steps:
- What is the value chain for your company? For example, in what products are your carbon nanotubes used by others? In what quantities? Who are your major customers (e.g., polymer industry, electronics industry, etc.)?
- What sampling, detection and measurement methods are you using to monitor (detect and measure) the presence of your carbon nanotubes in the workplace and the environment? Provide a full description of all required sampling, detection, measurement and verification methodologies. Provide full QA/QC protocol.
- What is your knowledge about the current and projected presence of your carbon nanotubes in the environment that results from manufacturing, distribution, use, and end-of-life disposal?
- What is your knowledge about the safety of your carbon nanotubes in terms of occupational safety, public health and the environment?
- What methods are you using to protect workers in the research, development and manufacturing environment?
- When released, do your carbon nanotubes constitute a Hazardous Waste under California Health & Safety Code provisions? Are discarded off-spec carbon nanotubes a hazardous waste? Once discarded are the carbon nanotubes you produce a hazardous waste? What are your waste handling practices for carbon nanotubes?
The DTSC continues to inform it producers and importers of carbon nanotubes that ‘a formal information request letter will be sent in January 2009 to manufacturers who produce or import carbon nanotubes in California in January 2009. The letter will also outline the time frame that manufacturers are required to respond under the law.’
Follow these links to find out more about the DTSC’s request information on carbon nanotubes, or to read the latest DTSC website update.
Registered NIA Members can download additional legal comment and background information on the DTSC’s Information Call-In from the ‘Members only’-area on the NIA website by following the respective link under ‘Topical Briefings’.