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Regulatory Information

Stop 08: Reactor

Highlighted Topic:  Regulations on the Manufacture or Importation of Chemicals

Tour Stop 08This chemical reactor is formulating a new chemical product.  There are certain environmental regulations that involve assessing or reviewing chemical products. These regulations may directly affect the kinds of chemicals you manufacture and import, or how they are formulated.

Two key laws that govern the manufacture or importing of  new chemicals are: TSCA (for general chemicals) and FIFRA (for pesticides).  TSCA stands for the Toxic Substances Control Act, while FIFRA stands for the Federal Insecticide, Fungicide, and Rodenticide Act. Both of these laws focus on  screening chemicals for environmental and health effects before they are manufactured or used.

Under TSCA, EPA can require companies to provide health and other data in a "premanufacture notice" prior to manufacturing or importing a chemical.  EPA can restrict or even ban the substance based on risks to humans or the environment. TSCA also has special provisions for the management of PCBs, asbestos, and CFCs.

FIFRA complements TSCA by covering pesticides.  FIFRA focuses on registration and classification of pesticides, as well as application and use requirements.

Another requirement that affects the manufacture or importing of chemicals is the Clean Air Act's consumer products rule (known as the "Section 183(e) rule").  This rule is aimed at limiting the emissions of  volatile organic compounds (VOCs) from several different types of consumer products, including various home beauty products, household cleaners, adhesives, and insecticides.  In the aggregate, these VOC emissions contribute to the formation of ozone, which at ground level is a health hazard, even though in the stratosphere it is a valuable shield against the sun's uv rays.  Manufacturers, importers, and/or distributors must insure their products are in compliance with the VOC limitations.

Other Regulatory Issues:

Process tanks themselves are likely to be subject to direct emissions limits under the Clean Air Act.  For example, certain types of process tanks (e.g., distillation tanks, reactor tanks) are automatically covered by Clean Air Act  New Source Performance Standards (Part 60 of the regulations).  In addition, process tanks and process lines may be sources of both controlled vents and fugitive emissions, and would be covered by one of several hazardous air standards that apply to reactors and equipment (National Emissions Standards for Hazardous Air Pollutants or NESHAPS, at Parts 61 and 63).

Process tanks can also be sources of hazardous waste generation, and process wastewaters.