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The Government Circuit: Environmental, Health, and Safety Issues Are Hot in U.S., EU, and Asia

Although coronavirus, trade wars, and supply chain concerns have dominated the discussion in our industry in recent months, many important environmental, health, and safety (EHS) issues are on the agenda as well. This column provides an overview of the EHS policy landscape and what IPC is doing to advocate for the electronics manufacturing industry.

IPC believes proactive efforts to prevent negative impacts on human health and the environment can reduce or eliminate business risks and the need for compliance-driven activity. Our industry’s concerns revolve primarily around the safe use of chemicals that may pose a risk to human health or the environment. Although it is the responsibility of every company to understand the environmental, health, and safety requirements that apply to them, IPC serves as your educational resource and your advocate.

If you have any questions or would like to learn more, please contact Kelly Scanlon, our hard-working director of EHS policy and research, and subscribe to our weekly e-newsletter ^[1].

Chemical Regulations Evolving in the U.S.

In the U.S., the EHS policy with perhaps the broadest impact right now is the U.S. Environmental Protection Agency’s (EPA) Chemical Data Reporting (CDR) system ^[2]. The CDR rule requires manufacturers and importers of certain chemical substances listed under the Toxic Substances Control Act (TSCA) Chemical Substance Inventory ^[3] to report data to the EPA every four years, and the current submission period is open through November 30. There are several changes you should be aware of, including requirements for making confidentiality claims; changes related to manufacturing byproducts, including exemptions; a phaseout of certain data codes; and an improved process for reporting co-manufacturing.

Meanwhile, in a separate CDR rulemaking ^[4], the EPA also updated definitions for small manufacturers that are exempt from reporting.

To report using e-CDRweb, you must first register with the Chemical Data Exchange system ^[5]. Please let us know if you have any questions as your company goes through the reporting process.

On another front, the EPA last spring released 20 “scoping documents” for its upcoming reviews of high-priority chemical substances under TSCA. Several of the substances are relevant to electronics manufacturing: flame retardants, phthalates, solvents, and formaldehyde. The comment period for these scoping documents is now closed, and we are waiting for the final versions to be issued. The scoping process is the foundation of the risk evaluation process that will eventually determine how EPA regulates or mitigates unreasonable risks.

As this process goes forward, IPC needs your input to ensure a thorough, accurate review. Delve into the details of which chemicals are being reviewed—and which are important to electronics manufacturing—in an IPC blog post by Kelly Scanlon ^[6].

Does Your Company Use PFAS to Make Electronics? 

Regulators in the United States and the European Union are eyeing chemicals in the per- and polyfluoroalkyl substances (PFAS) class. In July, IPC completed a screening study ^[7] to gain a better understanding of the evolving policies shaping the production and use of PFAS. IPC needs you to review the preliminary findings from our screening study to confirm whether we accurately captured the uses of PFAS in electronics products and processes. Please send your feedback to Kelly Scanlon by August 28, let us know if you use PFAS in your electronics processes and products, and again, check out IPC’s new blog on PFAS regulation ^[6].

Elsewhere in the U.S., chemicals in the PFAS class have been the focus of contentious debates among legislators in Congress as they undergo the yearly National Defense Authorization Act (NDAA) and appropriations processes. Several members of Congress are seeking funds for more research and restrictions on the chemicals.

Meanwhile, the EPA has codified ^[8] a list of 172 PFAS that are subject to reporting through the Toxics Release Inventory Program ^[9]. On June 22, the EPA issued a final significant new use rule for long-chain perfluoroalkyl carboxylate and perfluoroalkyl sulfonate chemical substances.

An Active Summer in Europe

Over in Europe, EHS issues remain at the forefront of the policy discussion. At the highest level, the European Commission and European Parliament are both working to promote economic recovery and growth consistent with the European Green Deal ^[10]—a sweeping plan to address climate change, create a “circular economy,” and reduce or eliminate the use of toxic substances, among other goals.

Most recently, on July 10, the parliament adopted a non-binding resolution ^[11] on a new chemicals strategy for sustainability ^[12], which is being developed by the European Commission (EC). The resolution “welcomes the zero-pollution ambition for a toxic-free environment” and “acknowledges the essential role of the chemicals sector in reaching the multiple targets of the Green Deal.” The resolution also called on the European Commission to “define the concept of and criteria for the ‘essential use’ of hazardous chemicals.” The draft strategy comes as 10 European Union Member States are advocating for the elimination of substances of concern for non-essential uses ^[13]. The commission is expected to adopt a final communication on the chemicals strategy in October.

Meanwhile, on June 25, the European Chemicals Agency (ECHA) added four new substances ^[14] to the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) Candidate List of substances of very high concern (SVHCs). One in particular, 2-methylimidazole (CAS number 693-98-1), is used in electronics manufacturing as a hardener for epoxy resin systems for semiconductor potting compounds and soldering masks and as a component of numerous polymers, including epoxy resin pastes. Beginning in January 2021, companies will need to notify the ECHA’s upcoming Substances of Concern in Products (SCIP) database ^[15] if they have products containing SVHCs. IPC urges companies to check their legal obligations ^[16] relating to the safe use of these substances.

And a recent report ^[17] from the ECHA noted the REACH directive has been the most powerful force pushing companies to replace harmful chemicals with safer alternatives. Customer demand, corporate sustainability policies, and corporate image have also had a notable impact on companies’ substitution efforts. However, companies face many challenges in such efforts, especially those of a “technical nature.” To overcome these barriers and facilitate the substitution process, the ECHA suggests trade associations and regulators establish collaborative networks across supply chains and organize events where companies can share experiences and best practices.

Interested in Chemical and Product Regulations in Asia?

Please check out these new white papers from IPC on evolving chemical regulations in China ^[18], Japan ^[19], and South Korea ^[20]. These papers provide a detailed look at the history of the policies, recent regulatory updates, and the regulatory trends in the respective countries. As always, reach out to us if you have any questions regarding environmental or chemical restrictions in Asia.

IPC Active Participants in Global EHS Conferences

IPC recently participated in two virtual conferences that addressed the ECHA’s upcoming SCIP database ^[15], the current state of chemicals management and restrictions in electronics, and much more. The ECHA SCIP Database Cross-Sector Conference ^[21] was held on July 3 and featured government officials, industry representatives, and other experts who shared their advice, experiences, and best practices regarding the SCIP database and the current state of chemical policy in Europe. IPC presented on the evolution of standards to achieve materials declaration requirements.

Meanwhile, the Chemicals Management for Electronics Europe 2020 ^[22] conference was held July 7–8, where IPC presented on the Restriction of Hazardous Substances Directive, standards as solutions for chemical content management, and Asia-Pacific happenings on chemical regulations affecting electronics. We also hosted a virtual workshop highlighting IPC’s advocacy role in Europe and how we track the chemical policy landscape. IPC will continue to share our industry expertise with decision-makers and will remain proactive in our approach toward a safer circular economy in Europe while we navigate current regulatory obligations.

How to Properly Disinfect Electronic Equipment Amid COVID-19

Amid the ongoing COVID-19 pandemic, keeping our workplaces ^[23] and communities safe is a top priority. IPC is continuing to monitor the coronavirus pandemic and providing members with relevant, actionable industry information ^[24].

The International Electronics Manufacturing Initiative (iNEMI) recently published a guide ^[25] on how to mitigate the risk when disinfecting electronic equipment and assemblies. “Many commonly recommended disinfection substances and/or application methods could potentially cause failures in electronic equipment if the internal electronics were inadvertently exposed to them,” said iNEMI CEO Marc Benowitz. "This is an obvious concern for electronics manufacturers who are wanting to ensure the safety of their employees, supply chain partners, and customers, while protecting the reliability and integrity of their products,” continued Benowitz. The next time you disinfect your workplace, we want you to do it safely! For more information, check out IPC’s recent blog ^[26].

Cyber Safety Affects Your Business, Too; What You Need to Do

Concerning a different kind of safety issue, on July 23, IPC hosted a webinar ^[27] on the Cybersecurity Maturity Model Certification (CMMC), which will soon be a requirement for more than 350,000 vendors in the Department of Defense (DoD) supply chain. If you do business with the DoD—or if you do business with anyone who does—you must be CMMC-certified by passing an independent CMMC audit. If you missed our presentation, check out the full video ^[28], and let us know if you have any questions.

Brighter Days Ahead

If you’re looking for signs of hope, June saw another month of strong demand for PCBs in North America, suggesting growth for electronics manufacturing remains robust, according to IPC Chief Economist Shawn DuBravac. See more of the latest findings from the PCB Statistical Program ^[29].

If you’re looking for inspiration, watch this video message from IPC President and CEO John Mitchell, who encourages industry leaders to be optimistic in responding to the COVID-19 crisis. “We are being tested as leaders, but we are also given a unique opportunity to change our processes and not go back to the way things have always been,” he says.

And finally, have you ever struggled to explain to someone what your company does or why it matters? Now you can show them IPC’s new 90-second video ^[30], which illustrates the many ways that electronics are making people’s lives safer, healthier, more connected, secure, and fun. We designed the video to help us explain the basic technology and the importance of electronics to non-technical audiences such as policymakers and educators.

Please help us promote the video by sharing it on social media with the hashtag #OurLivesDependonElectronics ^[31], or send a link by email to your workforce, business partners, elected officials, families, and friends. IPC’s advocacy page, which empowers you to contact your elected officials on a variety of IPC advocacy matters and sign-up for policy updates, is located at ipc.org/A-Team.

As always, please let us know if you have any questions or suggestions for IPC advocacy in the coming months. We are here to support you as we all navigate these challenging times.

References

1. IPC, “Global Advocacy Report.”
2. EPA, “Chemical Data Reporting Under the Toxic Substances Control Act.”
3. EPA, “TSCA Chemical Substance Inventory.”
4. EPA, “Small Manufacturer Definition Update for Reporting and Recordkeeping Requirements Under the Toxic Substances Control Act (TSCA) Section 8(a),” Federal Register, May 28, 2020.
5. EPA, “Instructions for How to Complete Self-Identification and Other Certifications in CDX for EPA-Initiated Risk Evaluations.”
6. K. Scanlon, “Important Advocacy Opportunity: How Is Your Company Affected by U.S. EPA Action on High-Priority Substances?”
7. IPC, “Preliminary Findings: PFAS Use in the Electronics Industry,” July 31, 2020.
8. EPA, “EPA Takes Next Step to Implement PFAS Legislation,” May 18, 2020.
9. EPA, “Toxics Release Inventory (TRI) Program.”
10. EC, “A European Green Deal.”
11. European Parliament, “Chemicals Strategy for Sustainability,” July 10, 2020.
12. EC, “Chemicals: Strategy for Sustainability (Toxic-Free EU Environment).”
13. Kingdom of the Netherlands, “Joint Letter: Safe Chemicals for the Future; Building Blocks for the Chemicals Strategy for Sustainability and the Zero Pollution Ambition,” June 24, 2020.
14. ECHA, “Candidate List update: Four new hazardous chemicals to be phased out,” June 25, 2020.
15. ECHA, “SCIP Database.”
16. ECHA, “Summary of obligations resulting from inclusion of SVHCS in the Candidate List.”
17. ECHA, “Impacts of REACH restriction and authorisation on substitution in the EU,” July 2020.
18. IPC, “Chemical and Product Regulations Affecting Electronics: China,” 2020.
19. IPC, “Chemical and Product Regulations Affecting Electronics: Japan,” 2020.
20. IPC, “Chemical and Product Regulations Affecting Electronics: South Korea,” 2020.
21. Chemical Watch, “ECHA SCIP Database Cross-Sector Conference,” July 3, 2020.
22. Chemical Watch, “Chemicals Management for Electronics Europe 2020,” July 7–8, 2020.
23. IPC, “New Resources for Worker Safety and Support.”
24. IPC, “COVID-19 (Coronavirus) Update.”
25. iNEMI, “Recommended Best Practices for Protecting the Reliability and Integrity of Electronic Products and Assemblies When Disinfecting for SARS-CoV-2 (COVID-19),” July 2020.
26. IPC, “iNEMI Publishes Best Practices for Protecting the Reliability and Integrity of Electronic Equipment when Disinfecting for COVID-19.”
27. IPC, “CMMC Will Affect Your Business: What You Need to Do,” July 23, 2020.
28. CMMC Consulting LLC, “Your Business Will Be Affected by CMMC: Know What to Do (Webinar),” July 27, 2020.
29. IPC, “North American PCB Industry Sales up 0.8 Percent in June: IPC Releases PCB Industry Results for June 2020,” July 30, 2020.
30. IPC, “Our Lives Depend on Electronics,” May 28, 2020.
31. IPC, “What Is Electronics Manufacturing and Why Is It Important?”

Chris Mitchell is IPC’s VP of global government affairs. Contact him at ChrisMitchell@ipc.org.