PIP (3:1) 2022: Potential Changes

By Kelly Scanlon, director, EHS policy and research

In March 2021, the U.S. Environmental Protection Agency (EPA) issued a request for more public input regarding the uses of phenol, isopropylated phosphate (3:1) (better known as PIP (3:1), CAS number 68937-41-7) in articles such as electronics. The agency also extended a “No Action Assurance” (NAA) on the compliance timelines for the risk management rule, meaning it will “exercise its enforcement discretion” until the new deadline. In response to that notice, IPC -- working with peer electronics associations CTA and ITI -- provided information to EPA based on a survey of the industry and its uses of this substance across the life cycle  of electronics.  EPA considered IPC’s comments and other stakeholder feedback and, as the NAA expired as of September 4, 2021, the Agency announced the following updates regarding the risk management of PIP (3:1) in articles.

1. EPA is extending compliance deadlines to March 8, 2022, for the prohibitions on processing and distribution and the associated recordkeeping requirements.

2. EPA intends to issue a new notice of proposed rulemaking on a further extension of the compliance dates for PIP (3:1) in articles.  Future extensions will be considered if they are supported by data and information including documentation of specific uses in articles and documentation of concrete steps taken to identify, test, and qualify substitutes for those uses. There will be a public comment period for the new notice of proposed rulemaking.

3. EPA intends to propose a new version of the entire rule for PIP (3:1) and four other persistent, bioaccumulative chemicals, in the spring of 2023.

If you’re interested in learning more about IPC’s engagement with EPA on this topic, please contact me at KellyScanlon@ipc.org.