> Factor (A) asks whether the use is significant. You're making the mistake of thinking "significant" here has some independent semantic meaning that must be r

> Factor (A) asks whether the use is significant. You're making the mistake of thinking "significant" here has some independent semantic meaning that must be read into the text. First, it doesn't; it's a descriptive label of the kinds of a "new use" that, if the Administrator determines fits the four criteria, is subject to statutory requirements. Second, A says nothing about significance. It says the Administrator must take into account the projected volumes involved. As for the rest, I think what's tripping everyone up is that "use" isn't just any old use out in the world. The Code of Federal Regulations defines in great and painful detail what kinds of uses are subject to regulation: see 40 CFR Part 721, subpart B (https://www.law.cornell.edu/cfr/text/40/part-721/subpart-B https://www.law.cornell.edu/cfr/text/40/part-721/subpart-B). Manufacturers have to submit a notice of the uses they are putting the chemicals to. That gets reviewed by EPA. If EPA approves, that use (or the corresponding part in 40 CFR 720) is added to the chemical's listing in subpart E (see https://www.law.cornell.edu/cfr/text/40/part-721/subpart-E https://www.law.cornell.edu/cfr/text/40/part-721/subpart-E). But if EPA finds out that a chemical is being used in practice in a way that matches subpart B, but isn't listed in subpart E because no one sent the required notifications, they can take various actions to force compliance (under various penalties). When the manufacturer complies and submits the appropriate notifications, the use gets added to the chemical listing in subpart E.