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The Environmental Health Network of California
Files Petition With the FDA




A picture is worth a thousand words

toxic irritant bad for the environment.

From the Official Journal of the European Communities, Annex to Commission Directives 93/72/EEC of 1 September 1993, Volumes I and II. These icons and more can be viewed on Fisher's site at
http://www.fishersci.com/support/chemicals.jhtml;$sessionid$XJX034AAAAF4WCWIZABAAAA

Also available from that same page:

    " New Substances and Toxic Substances Control Act
    "Section 5 of the Toxic Substances Control Act (or TSCA) requires any person who intends to manufacture or import a new chemical substance for a commercial purpose to submit a premanufacture notification at least 90 days before manufacture and/or importation. A "new" chemical substance is any substance not on the inventory of existing substances compiled by the United States Environmental Protection Agency (EPA) under section 8(b) of TSCA.

    "Chemical substances not on the TSCA Inventory are considered "new" by the EPA and should be used only for research and development activities. If you purchase Fisher material for use in R&D work and that material is not listed in the TSCA inventory, you may be exempt from application requirements if certain steps are taken to minimize health risks. This exemption (40CFR ~720.36) requires that "new chemical substances" manufactured or imported "only in small quantities solely for research and development purposes" are used by, or directly under the supervision of, a "technically qualified individual" and to notify all persons engaged in working with the new substances of any known or reasonably suspected health risks.

    "Such individuals include those involved in the manufacture, import, processing, use, transport, storage, and disposal of the substance. Companies must also notify customers that the substance is to be used solely for R&D purposes, as substances produced for R&D cannot subsequently be sold or used for non-R&D purposes.

    "In summary, the R&D exemption procedures must be followed explicitly, according to 40CFR~720.36. These substances can be used only in small quantities for R&D, by or under the supervision of technically qualified individuals. All persons handling the new substances must be adequately warned of any known or reasonably suspected risks associated with them, and documentation of all these activities made.

    "Fisher products that are not on the TSCA Inventory are indicated on each listing and on each container label as follows: "Not on TSCA Inventory: for research and development use only; not for manufacuring or commercial purposes."




Please write to the FDA in support of this petition.
Copy, if you'd care to have your letter posted on EHN and FPIN:
Betty Bridges, FPIN bcb56@ix.netcom.com
Barbara Wilkie, EHN (Barb's email is no longer valid, please contact EHN)

Please put FDA Letter in subject line. Thanks .

To view a sample letter, visit:
http://www.ehnca.org/www/FDApetition/sampletr.htm#SAMPLE


Return to Index of Letters in Support of Petition

Return to EHN Petitions the FDA


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rev. 3/14/00

The Environmental Health Network (EHN) [of California] is a 501 (c) (3) non profit agency and offers support and information for the chemically injured. EHN brings you topics on this page that need your immediate attention The URL for EHN's HomePage is www.ehnca.org