Comment submitted by James Scarborough

I support EPA’s use of the TSCA significant-new-use mechanism to preserve review of activities that do not conform to the restrictions in the underlying TSCA Orders. Before finalizing this rule, however, EPA should strengthen the public record by adding a nonconfidential, substance-by-substance implementation appendix. The appendix should map each relevant TSCA Order restriction to the corresponding proposed SNUR requirement or threshold, including any applicable use restrictions, concentration thresholds, sealed-container provisions, workplace-protection requirements, disposal limits, and release-to-water provisions. For each substance, EPA should identify which requirements are carried forward from the underlying Order and which, if any, reflect additional line-drawing in this rulemaking. Because several chemical identities and supporting PMN materials are confidential or sanitized, EPA need not disclose confidential business information to improve the record. A CBI-safe public table would still help commenters, regulated entities, downstream processors, importers, exporters, and EPA itself apply the rule consistently. EPA should also provide, or clearly identify in the docket, the assumptions behind the SNUN and export-notification burden estimates, including whether the estimates account for variation across substances, firm size, export scenarios, and chemical-specific compliance steps. These additions would not undermine the proposed SNURs. They would make the final rule easier to understand, easier to administer, and more defensible as a public rulemaking record.