Important Advocacy Opportunity: How Is Your Company Affected by US EPA Action on High-Priority Substances?
By Kelly Scanlon, director, environment, health and safety policy and research, IPC
The U.S. Environmental Protection Agency (EPA) released “scoping documents” for its upcoming reviews of certain high-priority chemical substances under the Toxic Substances Control Act (TSCA) Section 6(b). Your review of these documents is important because scoping is the foundation of the risk evaluation process that will eventually determine how EPA regulates or mitigates unreasonable risks.
Several of the substances are relevant to electronics manufacturing – flame retardants, phthalates, solvents, and formaldehyde – and IPC will work with electronics manufacturers like you to ensure a thorough review of the draft scoping documents.
You’ll recall that in 2019, the EPA designated 20 chemicals as high-priority (HP) substances for upcoming risk evaluations. EPA’s next step is to produce a scoping document for each chemical, identifying its conditions of use, hazards, exposures, and potentially exposed or susceptible subpopulations.
On April 6, the EPA released drafts for 13 of the HP substances, and on April 17, the EPA released an additional seven drafts.
Now is your chance to review these draft scoping documents; the current comment period is through mid-May for the first 13 drafts and the beginning of June for the remaining seven drafts.
The TSCA High-Priority Substances Sorted by Applicability to Electronics Manufacturing table and link below lists and provides links to all the designated HP substances; as well as the relevant draft scoping documents; and information from the draft about the substances’ possible uses in electronics. If your company manufactures, imports, processes, distributes, uses, or disposes of any of these chemical substances, then you will want to consider reviewing the drafts and providing information to EPA about the chemicals’ conditions of use.
Please consider the following questions as you review the draft scoping documents and consider whether to prepare comments to the EPA in conjunction with IPC.
• Did the EPA accurately identify this chemical substance’s use, based on your knowledge of electronics manufacturing and production processes?
• If not, how would you describe the scenario of use for the chemical substance, including potential human or environmental exposures?
• Does your company have access to or the ability to collect exposure data or information?
• What is the chemical’s criticality to the process and the product?
We will have several opportunities to engage with the EPA during the risk evaluations, but our effectiveness will depend on the quality of our information and insights, our members’ level of engagement, and our pro-active engagement and knowledge-sharing with the EPA TSCA team.
Our collective mission is to help the EPA develop policies that accurately reflect the uses of these chemical substances in our industry, and properly balance risk and cost-effectiveness. IPC will continue to facilitate that effort, with your help. Please contact me with any questions or comments at KellyScanlon@ipc.org.
TSCA High-Priority Substances Sorted by Applicability to Electronics Manufacturing
TSCA High-Priority Substances Sorted by Applicability to Electronics Manufacturing
| TSCA High-Priority Substances | CASRN | Draft Scoping Document Release Date | Applicability to Electronics as Mentioned in Draft Scoping Document |
| Triphenyl Phosphate (TPP) | 115-86-6 | April 6, 2020 | Flame retardant used in computer and electronic product manufacturing |
| Tris(2-chloroethyl) Phosphate (TCEP) | 115-96-8 | April 6, 2020 | Flame retardant used in electronic products |
| 4,4'-(1-Methylethylidene)bis[2,6-dibromophenol] (TBBPA) | 79-94-7 | April 6, 2020 | Flame retardant used in production of electronical and electronic products |
| trans-1,2-Dichloroethylene | 156-60-5 | April 6, 2020 | Solvent used for electronics degreaser and flux remover |
| 1,1,2-Trichloroethane | 79-00-5 | April 6, 2020 | Solvent used in plastic and petrochemical manufacturing; draft scoping document includes information regarding electronic materials and flexible printed circuit manufacturing |
| Formaldehyde | 50-00-0 | April 17, 2020 | Plating agent; draft scoping document mentions use as a chemical substance in commercial and consumer electrical and electronic products. |
| Phthalic Anhydride | 85-44-9 | April 17, 2020 | Industrial use as load absorber and industrial and commercial uses in electrical and electronic products; used in electronics adhesives (5 to 10% phthalic anhydride); used in production of plastic and rubber products including electronics. |
| Di-Ethylhexyl Phthalate (DEHP) | 117-81-7 | April 17, 2020 | Phthalate used in consumer or commercial electrical and electronic products; used in adhesives for electrical tape; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.” |
| Butyl Benzyl Phthalate (BBP) | 85-68-7 | April 17, 2020 | Phthalate with industry and commercial uses to include adhesives, sealants, floor coverings, paints and coatings, and use in plastic and rubber products; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.” |
| Dibutyl Phthalate (DBP) | 84-74-2 | April 17, 2020 | Phthalate used in ink, toner, colorant products used in the electronics industry; consumer exposures from products and articles include electrical and electronic products; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.” |
| Di-isobutyl Phthalate (DIBP) | 84-69-5 | April 17, 2020 | Phthalate; No specific electronic equipment uses listed in draft scoping document; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.” |
| Dicyclohexyl Phthalate | 84-61-7 | April 17, 2020 | Phthalate with industrial use in adhesives and sealants in electronic product manufacturing; industrial use in plastic and rubber products in electronic product manufacturing |
| Di-isodecyl phthalate (DIDP) | 26761-40-0, 68515-49-1 | Expected later April 2020 | (Possible use. This is a manufacturer-requested risk evaluation) |
| Di-isononyl phthalate (DINP) | 28553-12-0; 68515-48-0 | Expected later April 2020 | (Possible use. This is a manufacturer-requested risk evaluation) |
| 1,1-Dichloroethane | 75-34-3 | April 6, 2020 | No mention of electronics production in draft scoping document |
| 1,2-Dichloroethane | 107-06-2 | April 6, 2020 | No mention of electronics production in draft scoping document |
| 1,2-Dichloropropane | 78-87-5 | April 6, 2020 | No mention of electronics production in draft scoping document |
| 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-Hexamethylcyclopenta[g]-2-Benzopyran (HHCB) | 1222-05-5 | April 6, 2020 | No mention of electronics production in draft scoping document |
| 1,3-Butadiene | 106-99-0 | April 6, 2020 | No mention of electronics production in draft scoping document |
| Ethylene Dibromide | 106-93-4 | April 6, 2020 | No mention of electronics production in draft scoping document |
| o-Dichlorobenzene | 95-50-1 | April 6, 2020 | No mention of electronics production in draft scoping document |
| p-Dichlorobenzene | 106-46-7 | April 6, 2020 | No mention of electronics production in draft scoping document |