Comment submitted by Steven Singleton

I write in support of addressing the nineteen SNURs the Agency proposes, and to ask that they be placed inside a durable structure. The rule as filed is defensible chemical-by-chemical but structurally leaky as an ensemble, an opportunity to more fully mediate the regulatory infrastructure. Read against the Agency's own thirty-year practice, this proposal is the first 2026 installment ("26–1") of an open-ended series of per-chemical rulemakings. Viewed as an ensemble, the nineteen sections leave four protective mechanisms loosened at once: 1. The data gap that justified each §5(e) order is never compelled to close (the preamble states the "potentially useful information" is not required); 2. No provision triggers reassessment, so each listing is frozen at its issuance-day knowledge; 3. Chemical identity is property-ized through CBI, constraining the public participation this comment period exists to invite; and 4. Article exemptions leave the substance free to be exported, embedded abroad, and re-imported. The water-release ceilings in Unit III span more than four orders of magnitude (0.7 to 3,143 ppb), each hand-negotiated — evidence that protection here is set by negotiation rather than by rule. Three substances are flagged as potential PBTs yet regulated with the same tool, and on the same indefinite timeline, as a lubricant. The attached comment proposes a hazard-tiered schedule that can close those four gaps — built entirely from authorities Congress already granted in 2016 (§§5(a)(3), 5(e), 5(f), and 4), executed through batched notice-and-comment, with self-executing reassessment and a data-escrow mechanism. The proposal is designed to survive a multi-dimensional test of administrative-law durability, WTO/trade enforceability, regulatory economics, and internal gaming. My specific requests for the record appear in Part VII of the attachment. Thank you for your service to the People of the United States.