Comments and Testimony

2014

April 4, 2014 – IPC Submits Comments on RoHS Stakeholder Consultation for Reviewing Additional Substances for Restriction

March 10, 2014 – IPC Submits Comments to OSHA on Proposed Rule to Require Quarterly Reporting of Injury and Illness Information

February 4, 2014 – Dr. Brent Grazman, Viasystems, testifies before the House Subcommittee on Environment and the Economy on Section 8 of the Toxic Substances Control Act (TSCA)

2013

April 25, 2013 – IPC Comments to California's DTSC on April 2013 Version of Draft Safer Consumer Products Alternatives Regulations

March 11, 2013 – IPC Comments on the Review of Substances under RoHS2

February 28, 2013 – IPC Comments to California DTSC on January 2013 version of Draft Safer Consumer Products Regulation

February 8, 2013 – IPC Comments on First Stakeholder Consultation of Process within the Review of the "List of Restricted Substances" under the RoHS Directive

January 9, 2013 – IPC Comments on Environment Canada's Draft Screening Assessment Report on TBBPA

2012

October 11, 2012 – IPC Comments to California's DTSC on Draft Safer Consumer Products Alternatives Regulations

July 30, 2012 – IPC Comments on EPA's Proposed Rule on Certain Polybrominated Diphenylethers; Significant New Use Rule and Test Rule

2011

December 28, 2011 – IPC Comments to California's DTSC on Draft Informal Safer Consumer Products Regulation

October 20, 2011 - IPC Comments to EPA on Proposed Definition of solid Waste (DSW) Rule (.pdf)

September 20, 2011 - IPC Submits Comments to OSHA on Proposed Changes to Recordkeeping and Recording Requirements (.pdf)

September 12, 2011 - IPC Testifies at EPA Public Meeting on Proposed Changes to the Definition of Solid Waste (DSW) Rule (.pdf)

June 16, 2011 - IPC Submits Comments to OSHA on Proposed Addition of a Musculoskeletal Disorder (MSD) Column in OSHA's 300 Logs (.pdf)

April 4, 2011 – IPC Comments on EPA's Retrospective Review of Regulations – General Comments (.pdf)

April 4, 2011 – IPC Comments on EPA's Retrospective Review of Regulations – Proposed Modifications to the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) Rule (.pdf)

April 4, 2011 – IPC Comments on EPA's Retrospective Review of Regulations – Hazardous Waste Listing for F006, Wastewater Treatment Sludge from Electroplating (.pdf)

March 11, 2011 – IPC Comments on EPA Solicitation of Input from Stakeholders to Inform the National Framework for Electronics Stewardship (.pdf)

March 7, 2011 – IPC Comments to NIST on the Effectiveness of Federal Agency Participation in Standardization (.pdf)

2010

December 10, 2010 – IPC Submits Comments to the Federal Trade Commission on their Proposed Revisions to the Green Guides for Marketing (.pdf)

December 3, 2010 – IPC Comments on DTSC's Proposed Revisions to the Safer Consumer Product Alternatives Draft Regulation (.pdf)

November 1, 2010 – IPC Comments on California's Safer Consumer Product Alternatives (Green Chemistry) Draft Regulation (.pdf)

October 19, 2010 – IPC Comments to EPA on the Agency's Role in the Sustainability Initiative (.pdf)

October 12, 2010 – IPC Comments to EPA on Proposed Toxic Substances Control (TSCA) Inventory Update Reporting (IUR) Modifications Rule (.pdf)

July 15, 2010 – IPC Comments to California Department of Toxic Substances Control Safer Consumer Products Alternatives Draft Regulation (.pdf)

July 6, 2010 – IPC Comments to India Ministry on the Draft Notification of E-waste (Management and Handling) Rules 2010 (.pdf)

April 2, 2010 – IPC Comments to EPA on the Identification of the Electronics Industry for Financial Assurance Requirements under CERCLA Section 108(b) (.pdf)

March 30, 2010 – IPC Submits Join Comments on OSHA's Notice of Proposed Rulemaking (NPRM) to add a Musculoskeletal disorder (MSD) Column to the 300 Logs (.pdf)

March 9, 2010 – IPC Comments on EPA's Draft Environmental Justice Methodology for the Definition of Solid Waste (DSW) Final Rule (.pdf)

January 11, 2010 – IPC Urges OSWER to Reintroduce Electroplating Sludge (F006) Rule to Promote Materials Management and Beneficial Reuse (.pdf)

2009

November 4, 2009 – IPC Comments on California's DTSC Green Chemistry Straw Proposal (.pdf)

October 1, 2009 – IPC Comments to Environment Canada on Proposed Rosin Ban (.pdf)

June 30, 2009 – IPC Comments to US EPA on Reconsideration of the Definition of Solid Waste Rule (.pdf)

June 4, 2009 – IPC Comments to the US EPA on their Proposed Mandatory Reporting of Greenhouse Gases Rule

2008

May 15, 2008 - IPC Responds to the CA Department of Toxic Substances Control (DTSC) Questions Regarding Strengthening Consumer Protection Under the CA Green Chemistry Initiative (.pdf)

April 23, 2008 - IPC Comments to CA Department of Toxic Substances Control on the CA Green Chemistry Initiative (.pdf)

April 14, 2008 – IPC Comments to EPA on the Proposed Area Source NESHAP (National Emission Standards for Hazardous Air Pollutants) for Plating and Polishing Operations (.pdf)

March 27, 2008 - IPC Comments to the Öko-Institut Regarding their List of Potentially Hazardous Substances in EEE (.pdf)

January 10, 2008 - IPC Comments to the European Commission on the RoHS Review (.pdf)

January 7, 2008 – IPC Comments to OMB on EPA's TRI Information Collection Requests (ICR) (.pdf)

2007

November 21, 2007 - IPC Nominates TRI Lead Rule for the US Small Business Administration’s Regulatory Review and Reform Initiative (r3) (.pdf)

October 31, 2007 - IPC Comments to United States Trade Representative (USTR) on Foreign Trade Barriers (.pdf)

October 5, 2007 - IPC Comments on EPA’s Information Collection Request (ICR) for Emergency Planning and Community Right-to-Know (EPCRA) (.pdf)

September 10, 2007 - IPC Comments on EPA's TRI Information Collection Requests (ICR) (.pdf)

August 10, 2007 – IPC Comments on Norway's Proposed Prohibition on Certain Hazardous Substances in Consumer Products (.pdf)

July 30, 2007- IPC and CCA Comments on the California Department of Toxic Substances Control Proposed Permit by Rule for Treatment of Aqueous Wastes Containing Cyanide (.pdf)

July 23, 2007- IPC Comments on the July 9, 2007 Electronic Product Environmental Assessment Tool (EPEAT) Standards Development Roadmap (SDR) Final Background Document (.pdf)

June 25, 2007-IPC Comments on EPA's Supplemental Proposed Revisions to the Definition of Solid Waste (.pdf)

June 19, 2007- IPC Comments on the June 2007 Electronic Product Environmental Assessment Tool (EPEAT) Standards Development Roadmap (SDR) (.pdf)

May 9, 2007 - IPC Comments on the DHS Chemical Facility Anti-terrorism Standards Interim Final Rule (.pdf)

April 30, 2007 - IPC Comments on the Electronic Product Environmental Assessment Tool (EPEAT) Standards Development Roadmap (SDR) (.pdf)

January 25, 2007 – IPC Comments on EPA's Proposal to Extend the Spill Prevention Control and Countermeasures (SPCC) Compliance Deadline (.pdf)

2006

November 13, 2006 - IPC's Comments on OSHA's Advance Notice of Proposed Rulemaking on Hazard Communication – Globally Harmonized System of Classification and Labeling of Chemicals (GHS) (.pdf)

September 29, 2006 - SIA and IPC Comments on the International Finance Corporation EHS Guidelines for Semiconductors & Other Electronics Manufacturing (.pdf)

June 19, 2006 - IPC's Comments on Modification of the Hazardous Waste Manifest System (.pdf)

June 19, 2006 - IPC's Letter to EPA Assistant Administrator on the Agency's Decision to Withdraw F006 Rule (.pdf)

2005

December 05, 2005 - IPC's Comments on Toxics Release Inventory Burden Reduction Proposed Rule (.pdf)

August 16, 2005 - IPC Comments to CBS Evening News regarding octafluoropropane on the program "Red Planet Turning Green" (.pdf)

July 18, 2005 - IPC Comments on EPA's TRI Information Collection Request (.pdf)

2004

November 19, 2004 – Comments on EPA's SPCC Notice of Data Availability, Oil Filled and Process Equipment (.pdf)

November 19, 2004 – Comments on EPA's SPCC Notice of Data Availability, Facilities Handling Oil Below Certain Thresholds (.pdf)

July 21, 2004 – Comments on EPA's Hazardous Waste Generator Program (.pdf)

May 20, 2004 - Comments on OMB's Draft 2004 Report on the Costs & Benefits of Federal Regulations (.pdf)

April 9, 2004 - Comments on EPA's Draft Aquatic Life Criteria Document for Copper (.pdf)

April 9, 2004 - Comments on EPA's Proposed Contaminated Shop Towel Rule (.pdf)

March 11, 2004 - Comment on EPA's Proposed TRI Form Modifications (.pdf)

February 23, 2004 - Comments on EPA's Revisions to the Definition of Solid Waste (.pdf)

February 17, 2004 – IPC Testimony Opposing Maine's Legislation Banning Brominated Flame Retardants (.pdf)

January 9, 2004 – IPC Comments on RoHS Maximum Concentration Values for Hazardous Substances (.pdf)

2003

December 23, 2003 - IPC Comments on TRI Burden Reduction Online Dialog (.pdf)

November 26, 2003 - Comments to OMB & EPA on EPA's TRI Information Collection Request (ICR) (.pdf)

September 25, 2003 - IPC Testifies before Congress on Toxic Release Inventory (.pdf)

September 12, 2003 – Comments to EPA on Substances Nominated to the National Toxicity Program (NTP), including Tetrabrombisphenol A (TBBPA) (.pdf)

September 2, 2003 - TRI Form R Information Collection Request (ICR) Comments (.pdf)

September 2, 2003 - TRI Form A Information Collection Request (ICR) Comments (.pdf)

June 9, 2003 - Comments on SIS Ecolabeling Criteria for PCBs (.pdf)

May13, 2003 - Testimony on Massachusetts Legislation Relating to Mercury Reduction & Education (.pdf)

Comments on EPA's Draft Strategy for Clean Water Regulations (.pdf)

January 31, 2003 - CAAC Comments on EPA's Strategic Plan (.pdf)

March 26, 2003 - Comments on EPA's ECHO Website (.pdf)

January 8, 2003 - Comments to OMB on EPA's TRI ICR (.pdf)

2002

November 12, 2002 - IPC Comments on EPA's National Environmental Performance Track Program (.pdf)

September 5, 2002 - Comments on EPA's TRI ICR (.pdf)

July 22, 2002 - Comments on MP&M Notice of Data Availability (.pdf)

June 13, 2002 - IPC President Testifies to Congress on EPA's TRI Lead Rule

June 11, 2002 - Comments on EPA's Draft Data Quality Guidelines (.pdf)

May 28, 2002 - Comments on the OMB Draft Report to Congress on the Costs and Benefits of Federal Regulations (.pdf)

May 21, 2002 - Comments on EPA’s Intent to Remove Regulatory Barriers to the Recycling of Metal Containing Electroplating Sludge(.pdf)

May 20, 2002 - Comments on EPA’s RCRA Burden Reduction Initiative allowing CHMM to satisfy certain RCRA certifications(.pdf)

February 26, 2002 - Comments on EPA's Proposed CROMERRR (.pdf)

January 15, 2002 - Comments on EPA's Draft White Paper, "Beyond RCRA: Prospects for Waste and Materials Management in the Year 2020" (.pdf)

2001

November 8, 2001 - IPC Testifies on MP&M before the U.S. House of Representatives

July 3, 2001 - IPC opposes EPA's proposed MP&M effluent guidelines

2000

September 18, 2000 - IPC asks EPA for Regulation Flexibility in order to Promote the Recycling of F006 Sludge

August 15, 2000- IPC Requests Science Advisory Board Review of Persistant Bioaccumulative Toxin Stategy for Metals

February 25, 2000 - Comments on the Ergonomics standard citing lack of scientific basis and cost of compliance

1999

October 16, 1999 - IPC Comments on TRI Lead Reporting Rule - (MS WORD ® Document) IPC's Letter to the US Environmental Protection Agency urging revisions to the toxic reporting inventory proposal

February 16, 1999 - RCRA Waste Minimization PBT List

Industry