Electronics Industry Comments on EPA’s Proposed Rule on PFAS
As part of IPC’s ongoing advocacy on behalf of the electronics industry, IPC, the Consumer Technology Association (CTA), and the Information Technology Industry Council (ITI) jointly submitted comments to the U.S. Environmental Protection Agency (EPA) on their proposed Significant New Use Rule (SNUR) for Per- and Polyfluoroalkyl Substances (PFAS) that are designated as inactive on the TSCA Inventory.
The Toxic Substances Control Act of 1976 (TSCA) – amended in 2016 by the Frank Lautenberg Chemical Safety for the 21st Century Act (LCSA) – is the primary U.S. federal law addressing the production, importation, use, and disposal of chemicals that pose risks to human health and the environment. The U.S. Environmental Protection Agency (EPA) has the authority to require and enforce compliance with it.
TSCA Section 5(a) SNURs can be used to require notice to the EPA before a chemical substance or mixture is used in new ways that might create concerns. Under the SNUR, EPA would have the authority to regulate articles, but historically it has provided exemptions based on the complexities associated with identifying and reporting substances in articles.
Today’s comment reiterated the complexities of the electronics manufacturing supply chain and the difficulties associated with extracting and compiling data on specific chemistries. Thus the three associations encouraged EPA to maintain the articles exemption; maintain the impurities exemption; and expand the byproducts exemption, and we asked EPA to specify the CAS RN and accession numbers of the 330 substances on the inactive list.
This comment ties into IPC’s larger effort to advocate for fair and reasonable reporting on behalf of the electronics industry. While reporting data and information is important and sometimes necessary for human health and the environment, it is important that it be feasible, effective, and not overly burdensome to industry.
More information on IPC’s advocacy on TSCA can be found on our website.