Issue link: https://iconnect007.uberflip.com/i/612684
70 The PCB Magazine • December 2015 that they actually violated known laws of sci- ence and solubility. Anyway, we calculated that it would cost each facility a quarter of a million dollars a year to implement these regulations. We hired an economist to assess the stress that would pose on the industry, and they came up with a percentage of companies that would be forced out of business. Goldman: It was probably significant. Abrams: The EPA had calculated seven, and the numbers that our experts came up was in the couple hundreds. The EPA had made some re- ally flawed assumptions that the cost of compli- ance could just be completely passed on to the customers. In the end, after two years of hard work by our EHS steering committee members and board members, with members testifying and hearings across the country, the EPA completely walked away from the regulations and proposed no changes. Goldman: That's a huge win, because you don't usually win against the EPA. Abrams: It is a huge win because no, you don't get it very often. Two years ago, we were com- pletely successful—another big win—on ex- port controls. The Obama administration had proposed a complete reexamination of export controls in the country, and the idea that a lot of the aerospace industry had been advocating was every little pump and screw and hose is reg- ulated under ITAR if it goes into a defense item. The system is completely broken, truly. The goal of the administration was to put higher walls and better controls on a smaller number of items, to truly determine what need- ed to be protected and what did not. From a PCB perspective, we saw this as an opportunity to clarify what we saw as broad misunderstand- ings about the nature of PCBs throughout elec- tronics, and particularly in the defense industry. I sat down with a major defense OEM, the head of their ITAR compliance, and this person said to me, "We know they're commodity items; they could go in our system, or they could go in a toaster." Goldman: Because, of course, we all know that ev- ery circuit board is pretty much unique. Abrams: Yes, each is designed for a specific item. What I realized was the problem with the way export controls were written and the way that our supply chain works, even if it's in the same company doing their own manufacturing, the engineers that know that a PCB is individually designed and the lawyers who understand ITAR are in completely separate parts of the company. And if you have suppliers who are build- ing your boards and their word is filtering up, you've got even more misinformation. IPC took this as an opportunity to do outreach to the in- dustry. We launched an educational campaign. We also hired one of the top lawyers in export controls, and as a result of all this, when the State Department issued a revised U.S. Muni- tions List for electronics, they made very clear exactly what we sought to explain: The classi- fication of the circuit board should match the item for which it's manufactured. You could have a classified plane, and it might have a radio system that's the same as a radio system in a Boeing passenger jet. Just because it's on a classified plane, that circuit board doesn't need to be restricted under ITAR. But if that circuit board is being designed for an ITAR-restricted item, then that circuit board IPC'S FERN ABRAMS: KEEPING UP WITH REGULATORY MATTERS FeATure inTerview