Sep 13, 2006· Comment submitted by Howard J. Feldman, Director, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OPPT-2005-0036-0021
EPA should state that export notification is required only for elemental mercury when exported in the form subject to the SNUR, i.e., when used in convenience light switches, ABS switches, and active ride control system switches in certain motor vehicles. This clarification is necessary to avoid the confusion and burden that would be associated with applying the annual export notification requirements to elemental mercury regardless of form or application. Mercury is a naturally occurring element that has the potential to be present in trace levels in a variety of substances.