IPC Commends US EPA Proposal to Reduce Reporting Burden on Byproducts Sent for Recycling; Seeks Clarifications in Final TSCA CDR Rule

June 25, 2019 — The electronics industry supports many of the U.S. EPA’s proposed changes to the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) requirements and will continue to work with the agency to protect human health and the environment while streamlining reporting requirements.  

In comments filed at the agency, IPC – Association Connecting Electronics Industries says the proposed TSCA CDR rule offers regulatory relief for printed circuit board fabricators whose manufacturing byproducts are subsequently recycled offsite, a longtime goal of the association. Given IPC’s longstanding record of engaging with the EPA on CDR, “we would have liked to see the scope of our concerns better addressed,” IPC says. “However, the prospect of improvements to CDR … provides an outline for future relief that can address the scope of our concerns.”

For example, IPC supports efforts to better align reporting requirements under both TSCA and the Toxics Release Inventory (TRI) program. IPC also supports the proposed use of NAICS codes to enable industry-specific analyses that will improve uniformity and comparability.

IPC also is requesting clarification from the EPA about how the data are used, given that the byproducts, all of which are directed to recycling at facilities within the U.S., are typically managed in pipes, tanks, and containers with little or no chance of exposure to workers or the general public; and that none of the chemicals in the byproducts are listed on the EPA’s 2014 update to the TSCA Work Plan for Chemical Assessments.

“We appreciate EPA’s decision to address the electronics industry’s concerns in the proposed CDR rule, as well as the agency’s willingness to continue a dialogue with us to better align the reporting burden with other EPA programs and with the minimal environmental and human health risks resulting from our members’ activities,” said Kelly Scanlon, IPC director of EHS policy and research.   

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