Issue link: https://iconnect007.uberflip.com/i/1367446
50 SMT007 MAGAZINE I MAY 2021 • EU's Chemicals Strategy for Sustainability and Sustainable Products Initiative, which are both part of the EU's broader Circular Economy Action Plan • U.S. TSCA (Toxic Substances Control Act) implementation We're also prioritizing advocacy on sev- eral chemical substances that are essential to electronics manufacturing and the subject of emerging chemical and product policies: • Lead (Pb) • Flame retardants such as TBBPA and PIP (3:1) • Per- and polyfluoroalkyl substances (PFAS) such as PTFE and other fluoropolymers Here's an example of how our collective effort gets results. At the end of March, IPC submitted comments to the public docket on the U.S. Environmental Protection Agency's (EPA) proposed rule for "Fees for the Admin- istration of the Toxic Substances Control Act." e expertise of IPC members and the infor- mation that they were able to share enabled IPC's GR team to advocate for a more equita- ble administration of fees to support TSCA. e existing fees rule was difficult to imple- ment for companies importing articles con- taining TSCA high-priority substances and for companies manufacturing or importing small quantities of these substances. As a result of deliberations with member companies, IPC was able to partner with two other electron- ics industry associations to advocate for com- mon-sense reforms to the rule. e proposed rule recognizes the implementation challenges faced by the electronics industry and includes solutions that will enable the EPA to achieve its goals without an unequitable burden on the electronics industry. Visit ipc.org/blog for the full story. e EHS Committee and ENV SMT mem- bers also were helpful when we were evaluat- ing the industry's role in providing feedback to the EPA on five final rules for risk management of specific persistent, bioaccumulative and toxic chemicals. eir expertise helped IPC to determine its level of engagement. Shortly aer the industry's engagement, the EPA announced a new 60-day comment period. Now we are positioned to have a larger role in shaping the updated final rules to ensure real- istic timelines for identifying safer chemistries and other practical risk management actions. Meetings of the EHS Committee and ENV SMT offer members chances to engage with each other, exchange information, and learn about opportunities to get involved with broader advocacy activities. For example, the RoHS Industry Umbrella Project is a group of more than 50 associations and companies working together to track EU RoHS-related policy happenings and prepare exemption applications in accordance with existing proto- cols. IPC takes information learned from our work with the Umbrella Project and dissemi- nates it to the EHS Committee and ENV SMT. Also, IPC encourages its members to engage directly with the various working groups of the Umbrella Project to support the exemp- tion application process. In 2019 and 2020, IPC members participated in several working groups responsible for submitting more than two dozen applications. ere are more examples of our collective EHS work, but they all highlight the same truth: the electronics manufacturing industry, the environment, and human health all benefit from an active volunteer base of subject matter experts who dedicate their time to engaging on environmental policy issues. IPC appreciates the time taken by volunteers to get engaged with IPC's government relations activities. For more information on joining either the EHS Committee or ENV SMT, please contact me at KellyScanlon@ipc.org. SMT007 Kelly Scanlon is IPC director of EHS policy and research.