By Martha Marrapese (October 27, 2017, 12:07 PM EDT) -- Following the 2016 changes to the Toxic Substances Control Act, the new chemical notification program is no longer the exclusive domain of the manufacturer. Downstream processors and users of new chemicals are being drawn into premanufacture notification (PMN) reviews due to three of the key changes in the law. The new safety standard language requires the U.S. Environmental Protection Agency to pay closer attention than ever before to the conditions under which a new chemical is used. The EPA also must issue the decision outcomes of new chemical reviews before manufacture can begin.  However, the real "game-changer" for new chemicals occurred when Congress changed an "and" to an "or." As a result, the EPA now must regulate new chemicals based on insufficient information in the submission alone. With increasing frequency, we are seeing cases in which the exposure information for the downstream processing and use of new chemicals is often what is lacking. ...