IPC Standards Committee Reports – Terms and Definitions, High Speed/High Frequency, Rigid Printed Boards, Embedded Devices, Printed Electronics

These standards committee reports from the 2014 Fall Standards Committee Meetings have been compiled to help keep you up to date on IPC standards committee activities. This is the third report in the series.

Terms and Definitions

The 2-30 Terms and Definitions Committee met to resolve comments to the Final Draft of IPC-T-50M, Terms and Definitions for Interconnecting and Packaging Electronic Circuitry.  The forthcoming revision will address new and revised terms for conformal coatings, potting and encapsulating materials, stencil design, statistical process control, and bottom termination component (BTC) devices.

High Speed/High Frequency

The D-21 High Speed/High Frequency Design Subcommittee has been reactivated to develop a new IPC-2228, Sectional Design Standard for High Frequency (RF/Microwave) Printed Boards.  The effort addresses a gap in the series of IPC-222X printed board design standards, as currently there are only IPC guidelines dedicated to RF/Microwave circuitry (IPC-2251 and IPC-2252).  This document will establish requirements for the design of printed boards as they apply to radio waves in the frequency range of 100 MHz to 100 GHz utilizing waveguides or antennas.  A working draft will be made available for review in in Q1 2015.

The D-22 High Speed/High Frequency Performance Subcommittee continued with updates to the the working draft of IPC-6018C, Qualification and Performance Specification for High Frequency (Microwave) Printed Boards.  Thermal stress testing requirements for high frequency boards with microvias was the primary topic.  The group also reviewed a proposal from Intel Corp. on the need for a standardized measurement methodology for the surface roughness of treated copper foil “in process” by a printed board fabricator prior to lamination to other subcomposite printed board layers.  A new IPC D-22a task group will be established to address this need.

The D-23 High Speed/High Frequency Base Materials Subcommittee having released the Amendment 1 to IPC-4103A, Specification for Base Materials for High Speed/High Frequency Applications found some additional changes that need correction and worked on five sections as a start on Amendment 2.

Rigid Printed Boards

The D-31b IPC-2221/2222 Task Group, responsible for the IPC-2221B, Generic Standard on Printed Board Design, met to discuss the need for a revision to the IPC-2226, Sectional Design Standard for HDI Printed Boards, which has not been updated since its original 2003 publication date.  It was agreed that the revision effort will be handled by this task group.  Members of WKK Distribution Ltd. and ESI offered to lead a sub-group that would work from October 2014 – February 2015 on a first working draft of IPC-2226A that would be provided for in-depth review at IPC APEX EXPO 2015.

The D-33a Rigid Printed Board Performance Task Group reviewed comments on the final draft of IPC-6012D, Qualification and Performance Specification for Rigid Printed Boards.  The group focused on comments related to requirements for periodic (monthly or quarterly) quality conformance testing and marking legibility requirements for etched or ink marking.  The task group then began developing a list of conforming and non-conforming imagery for new sections of IPC-6012D that will be incorporated into an IPC-A-600J, Acceptability of Printed Boards.

The D-35 Printed Board Storage and Handling Subcommittee addressed the working draft to IPC-1601A, Printed Board Handling and Storage Guidelines. The subcommittee plans to develop an Appendix that provides samples of industry packaging requirements for board fabricators across three categories of packaging complexity.  The group also addressed a gap in the document where the impact of baking of printed boards affects the solderability of ENIG applied surface finishes.

Embedded Devices

The D-55 Embedded Devices Process Implementation Subcommittee discussed comments received during the recent balloting of IPC-7092, Design and Assembly Process Implementation for Embedded Components Document passed the ballot process, but some reservations associated with one negative ballot were reviewed and dispositions provided. A final resolution acceptance meeting is required by procedure, which will either result in a unanimous acceptance or publication with one dissenting vote before January 1, 2015.

 Printed Electronics

The D-60 Printed Electronics Committee welcomed new additions to the leadership of this active general committee overseeing printed electronics standards development as Raj Kumar agreed to take the chair position, freeing Dan Gamota to step back to a vice-chair position.

The D-61 Printed Electronics Design Subcommittee continued to gather input for revision A of IPC-2291, Design Guidelines for Printed Electronics. The group has set a preliminary release date of fall 2015. Dr. Hirofumi Matsumoto has been added to the D61 leadership group as cice-chair to facilitate design needs exchange with the JPCA “mirror” committee.

The D-62 Printed Electronics Base Materials Substrates Subcommittee is preparing significant expansions in scope to IPC/JPCA-4921 including new information on glass and glass-like substrates, many additional plastic film alternatives, and an entirely new cellulosics section. Target for publication of revision A: 1Q 2015.

The D-63 Printed Electronics Functional Materials Subcommittee continued to gather material for IPC/JPCA 4591A, expanded the scope to include information on insulatives, optically-active, and possible semi-conductive functional materials. The expanded scope may delay the proposed 1Q 2015 publication date until 3Q 2015.

The D-64 Printed Electronics Final Assembly Subcommittee prepared a working draft of IPC-6901, Performance Requirements for Printed Electronics Assemblies for review. An additional co-chair is needed, but a vice chair has been added to help reduce the load on the existing chair, whose work duties force a pullback from IPC activities.

The D-65 Printed Electronics Test Method Development and Validation Subcommittee has begun independent activities with a number of new committee participants. The first draft of one test method subsection (flexibility evaluations) has been received and is under committee review. Murad Kurwa, Flextronics, is the new co-chair sharing the workload with Dan Gamota, Jabil Circuit.

The D-66 Printed Electronics Processes Subcommittee continues to work closely with the JPCA “mirror committee” to refine “best practices/implementation guideline” draft for printed electronics processing. Preliminary goal for initial release: fall 2015.

 

 

D.C. Circuit Court of Appeals to Rehear Conflict Minerals Case

Yesterday, Tuesday, November 18, a three-judge panel of the U.S. Court of Appeals for the D.C. Circuit agreed to rehear a case challenging the U.S. Securities and Exchange Commission’s (SEC) conflict minerals rule.

In April, the panel struck down the portion of the rule forcing companies to declare whether or not their products are “conflict free,” ruling that it violated the First Amendment. The appeals court upheld other aspects of the law, such as requiring companies to check their supply chains to see whether minerals from the Democratic Republic of the Congo (DRC) region were being used, and to file reports to the SEC.

Yesterday’s panel decision is potentially at odds with the D.C. Circuit’s full-court ruling in July that country-of-origin labeling for meat does not violate commercial free speech protections. In both cases, the key question regards compelled speech — how far the government can go to force companies to say something that they would not otherwise state.

The D.C. Circuit panel, in granting the rehearing petition, asked the lawyers in supplemental briefs to address what effect, if any, the meat-labeling decision has on the SEC’s conflict minerals rule.

 

IPC Standards Committee Reports — Base Materials, Fabrication, Assembly & Joining, Flex Circuits

These standards committee reports from the 2014 Fall Standards Committee Meetings have been compiled to help keep you up to date on IPC standards committee activities. This is the second in a series of reports.

Base Materials

The 3-11 Laminate/Prepreg Materials Subcommittee successfully revised, balloted and released IPC-4101D, Specification for Base Materials for Rigid and Multilayer Printed Boards in April 2014. Shortly after this, a few company members brought up some details in the released version that they believe requires an Amendment modification to the D revision. This took up more than 75 percent of the meeting to discuss and decide the items to be covered in an amendment to IPC-4101D. The other 20-25 percent of the meeting involved distributing hard copies of IPC-4101D to the 3-11 Subcommittee members listed in the document’s Acknowledgement Page.

The 3-11f UL/CSA Task Group discussed upcoming items for ballot by the STP members in the UL 796 standard for rigid or multilayer printed boards. The group went through nearly two dozen items for comment in UL 746E Ballot by the STP group on these items in this UL standard will begin shortly.

The 3-11g Corrosion of Metal Finishes Task Group reviewed the status of mixed flowing gas testing of various metal finishes for corrosion on component leads as well as printed board surfaces. Flowers of Sulfur (FoS) corrosion testing was also reviewed during the meeting.

The 3-12a Metallic Foil Task Group addressed some round-robin data results using the non-contact surface roughness test (proposed TM 2.2.22). While data is only available from three of six test facilities, data is trending to show reasonable surface roughness information.

The 3-12d Woven Glass Reinforcement Task Group examined weave size data for four weave styles (106, 1080, 2116 and 7629) measured in a round robin test format by four test facilities. Statistical analysis (Gauge R & R) of the test data was not as consistent as hoped, but was showing adequate viability of the test procedure used by the four test companies. More testing is needed.

Fabrication Processes

The 4-14 Plating Processes Subcommittee reviewed revision A efforts underway on IPC-4552, Specification for Electroless Nickel/Immersion Gold (ENIG) Plating for Printed Circuit Boards. The group is using the released copy of IPC-4556, Specification for Electroless Nickel/Electroless Palladium/Immersion Gold (ENEPIG) Plating for Printed Circuit Boards as a template. Some of the items to be included in the revision A were discussed: a) Work on a test vehicle to evaluate a thinner gold plate for performance, b) Other work on evaluating hypercorrosion of the electroless nickel when the immersion gold is deposited, c) A test method being developed to measure the phosphorus content in the nickel is nearly completed, and d) In order to analyze the phos content of the underlying nickel, two test methods to strip the gold overplate are in development.

Assembly and Joining

The 5-11c Electronic Assembly Adhesives Task Group is approaching final draft status for a new document, IPC-HDBK-4691, Guidelines for Design, Selection, Application, and Reliability of Adhesives and Associated Processes Used for Electronics Assembly Purposes (working title). Publication target: 1 Q 2015.

The 5-21g Flip Chip Mounting Task Group is preparing revision A of IPC-7094, Design and Assembly Process Implementation for Flip Chip and Die Size Components. The committee confirmed 7094 will not contain new packaging concepts of 2.5 and 3-D package configurations (addressed separately in a, IPC-7091 byB-11 Subcommittee). To facilitate that separate approach, a limited-scope (fast-track) revision of 7094A is planned, primarily for the addition of ultra-fine-line, copper pillar, and bump-on-trace (BOT) technologies, to free up some of the shared resources for the larger, more complex IPC- 7091 effort. Target publication of 7094A is expected by 2016 IPC APEX Expo.

The 5-21k IPC-SM-817 SMT Adhesive Task Group completed follow-up on comments received on the Final Industry Review circulation of IPC-SM-817A, General Requirements for Dielectric Surface Mounting Adhesives. The document will now be balloted.

The 5-22a J-STD-001 Task Group celebrated the release of IPC J-STD-001F, Requirements for Soldered Electrical and Electronic Assemblies. The committee also discussed industry feedback on some of the changes and voted to open the document for an amendment. The committee leadership is considering teleconferencing as a means for moving ahead quickly with discussions on these concerns.

The 5-22arr J-STD-001/Conformal Coating Material & Application Industry Assessment Task Group discussed the current status of round robin testing.

The 5-22as Space Electronic Assemblies Task Group completed review of the comments to the new revision F. The document will be prepared for Final Industry Review.

The 5-22F IPC-HDBK-001 Task Group continued work on the revisions to the document to incorporate J-STD-001 Revision F changes. The task group set an aggressive timeline and is working to complete actions and discussion before the end of 2014 using KAVI and teleconferencing opportunities.

The 5-22bt J-STD-001 Technical Training Committee met with the provider for the updates to the J-STD-001 training program and to discuss the use of Certification Quality Initiative (CQI) for testing and reporting. The beta class for the new course materials is being scheduled for December 2014.

The 5-22ad Requirements for Military Systems Working Group reviewed soldering on military systems and identified where more stringent requirements than those currently in J-STD-001 may be necessary.

The 5-23b Component and Wire Solderability Specification Task Group continued working on the next revision of J-STD-002, Solderability Tests for Component Leads, Terminations, Lugs, Terminals and Wires.

The 5-24b Solder Paste Task Group is reviewing test methods originating with the group.

Flexible Circuits

The D-13 Flexible Circuits Base Materials Subcommittee has started a 30-day ballot on revision A of IPC-FC-234, Pressure Sensitive Adhesive (PSA) Assembly Guideline for Rigid, Flexible or Rigid-Flex Printed Boards. The subcommittee is also in the ballot process for an Amendment 1 to IPC-4203A, Cover and Bonding Material for Flexible Printed Circuitry that will add another specification sheet material (/25 for a polyamide-imide copolymer) to the document.

The D-15 Flexible Circuits Test Methods Subcommittee addressed revising TM 2.6.3.2 Insulation and Moisture Resistance Flexible Base Dielectric Board to its C revision,that will have a new title: Surface Insulationand Moisture resistance, Copper Clad Flexible Dielectric Material. The work that took place significantly improved the test method’s clarity.

California to Require Hazard Warnings on Products Containing Twelve Common Chemicals

Anyone who has ever been to California is familiar with the ubiquitous Proposition 65 signs, “WARNING: This product contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm.”  Applying to any product sold in the state of California, Proposition 65 traces origins to a 1986 voter initiative. Because of the overuse of the vague warning, the ubiquitous signs ultimately communicate very little information to the end user. This problem has been recognized by California courts, advocates, and businesses. Proposed changes to the rule could require manufacturers to provide detailed information on chemicals in products sold in the state of California.

By the end of 2014, California’s Office of Environmental Health Hazard Assessment (OEHHA) is expected to formally propose changes to Proposition 65. OEHHA has released a pre-regulatory draft of the potential changes that are cause for concern. Based on the pre-regulatory draft, potential changes could include:

  • Requiring manufacturers to provide a detailed report to OEHHA that includes the manufacturer’s contact information, anticipated route of exposure of the chemical, anticipated level of human exposure to the chemical, and steps a person can take to minimize or eliminate exposure;
  • Eliminating safe harbor language, which would require the warning label language to say “can expose” instead of “chemical is present;”
  • Identifying 12 chemicals that must be specifically named on any warning label. These chemicals are: acrylamide, arsenic, benzene, cadmium, chlorinated tris, 1,4-dioxane, formaldehyde, lead, mercury, phthalates, tobacco smoke, and toluene; and
  • Requiring the use of a new pictogram.

IPC continues to monitor these developments and will be hosting a timely, in-depth panel discussion on this topic during IPC APEX EXPO in February 2015. The panel will include an industry perspective, a representative from OEHHA, and a company representative to talk about how the changes would impact them.

More information can be found at www.ipcapexexpo.org.

 

IPC Standards Committee Reports — Printed Board Design, Cleaning & Coating, Testing, Process Control, Product Assurance

These standards committee reports from the 2014 Fall Standards Committee Meetings have been compiled to help keep you up to date on IPC standards committee activities. This is the first in a series of reports.

 Printed Board Design

The 1-10b Current Carrying Capacity Task Group met to discuss a roadmap for a revision of the existing IPC-2152, Standard for Determining Current Carrying Capacity in Printed Board Design.  The revision effort is intended to address high current (transient) pulses, flexible printed boards, and microvias.

The 1-10c Test Coupon and Artwork Generation Task Group provided an update on the forthcoming IPC Test Coupon Gerber Generator that is being developed to allow OEMs and fabricators to create Gerber files for AB/R test coupons described in Appendix A of IPC-2221B, Generic Standard on Printed Board Design. The Coupon Generator is expected to be available for industry use in Q1 2015.

 

Cleaning and Coating

The 5-32c Bare Board Cleanliness Assessment Task Group is evaluating a proposed rewrite to the 3.8 cleanliness section within IPC-6012C, Qualification and Performance Specification for Rigid Printed Boards. The rewrite addresses advances in cleanliness testing by way of ion chromatography (IC) and related testing within IPC-5704, Cleanliness Requirements for Unpopulated Printed Boards. Members of the 5-32c task group are working with members of the D-33a Rigid Printed Board Performance Task Group to edit the proposal and submit as a future Amendment 1 to the D Revision of IPC-6012, which is expected to be completed by Q1 2015.

The 5-32e Conductive Anodic Filament (CAF) Task Group discussed revising the IPC-9691A, User Guide for the IPC-TM-650, Method 2.6.25, Conductive Anodic Filament (CAF) Resistance Test (Electrochemical Migration Testing) to its B revision. There is need to split the user’s guide into two major modes; true CAF failures and internal electrochemical migration which is caused by hollow glass fibers, poor resin wetting of the reinforcements, roughly drilled holes and excessive copper wicking. Revision B of IPC-9691 will progress at a slower rate than earlier anticipated, as this information is gathered.

 

Testing

The 7-11 Test Methods Subcommittee established a list of “domain experts” within the subcommittee that would be available to assist relevant task groups who are either creating or revising IPC-TM-650 test methods when they are tasked with building a Gage R&R Validation Plan for their method, which is a requirement of the IPC-MDP-650, Method Development Packet. These domain experts would assist a test method group in identifying what would need to be reported in a Validation Plan for their specific method creation or revision.

The 7-12 Microsection Subcommittee established a Gage R&R Validation Plan for the new IPC-TM-650, Method 2.1.1F, Microsectioning, Manual and Semi or Automatic Method. The revision is a combination of previous versions of IPC-TM-650 Methods 2.1.1 and 2.1.1.2.  Method 2.1.1.2 will be cancelled following the release of Method 2.1.1F.  The subcommittee also discussed plans for a new IPC-TM-650 Method 2.1.1.3 that will address microsection evaluations of blind and buried microvia structures, included stacked and staggered configurations.

 

Process Control

The 7-23 Assembly Process Effects Handbook Subcommittee addressed problems, probable cause, and actions taken in troubleshooting assembly processes in the developing IPC-9111, Troubleshooting for Printed Board Assembly Processes. A working draft of the document is close to being completed for review by the committee.

The 7-24 Printed Board Process Effects Handbook Subcommittee is pushing completion of IPC-9121, Printed Board Process Effects, a companion document, to IPC-9111, Printed Board Assembly Process Effects. This document will serve as a new process effects analysis/troubleshooting guide and also as syllabus for an advanced troubleshooting PD class under development. The handbook will provide printed board anomaly illustrations with possible cause and solution explanations and will be more closely tied to IPC-A-600 acceptability criteria.

 

Product Assurance

The 7-31b IPC-A-610 Task Group celebrated the release of Revision F of IPC-A-610, Acceptability for Electronic Assemblies. The committee also discussed industry feedback on some of the changes and voted to open the document for an amendment. The committee leadership is considering teleconferencing as a means for moving ahead quickly with discussions on these concerns.

The 7-31bt IPC-A-610 Technical Training Task Group met with a training provider to discuss updates to the IPC-A-610 training program and to discuss the use of Certification Quality Initiative (CQI) for testing and reporting. The beta class for the new course materials is being scheduled for February 2015.

The 7-31f IPC/WHMA-A-620 Task Group began revision work on IPC/WHMA-A-620. The task group is on an aggressive schedule to resolve comments and add new content as it becomes available. The committee is using KAVI to communicate and share documents.

The 7-31k Wire Harness Design Task Group and the 7-31h IPC-HDBK-620 Handbook Task Group combined their efforts to continue working on IPC-D-620, Design and Critical Process Requirements for Cable and Wiring Harnesses. The group is nearing completion of its draft and is moving toward a final industry review in the coming months.

The 7-31m Fiber Optic Cable Acceptability Group is creating a standard (IPC-A-640) to provide information on the general design and acceptance requirements for optical fiber, optical cable and hybrid wiring harness, and installation. This standard will be a collection of visual, mechanical, and performance quality acceptability requirements for fiber optic cable assemblies. A working draft document is being developed.

IPC Sets Webinar on Mid-Term Elections

The outcome of the 2014 mid-term elections will likely have a significant impact on business conditions over the next few years. It is important to factor the results of Tuesday’s voting into your strategic planning especially since our industry is heavily effected by legislative and regulatory initiatives

Next week, IPC will provide valuable insight on some the potential for change in areas that impact member companies. A webinar on November 10 will review results of the mid-term elections and provide insight on what it means for the electronics manufacturing industry.

For more information and to sign up for the webinar, click here.

Industry Survey Reveals Significant Cost for Conflict Minerals Compliance

The first year of conflict minerals reporting has come and gone, but how much did it cost? What lessons have we learned? A comprehensive Tulane University survey of 2013 issuers shows average costs per issuer, identifies qualitative measures issuers are currently using, and identifies common supply chain practices.

The survey results indicate an overall cost of $709 million. On average, issuers dedicated 2.7 employees – either part-time or full-time – to their conflict minerals compliance efforts. The procurement, supply chain and quality departments were identified as the departments primarily responsible for conflict minerals compliance. Management and legal departments were distant followers. When asked about procuring external resources, 75 percent of respondents reported they hired a consultant to assist in their compliance efforts. Several issuers also hired lawyers to assist. A company’s IT needs were generally outsourced, however, 37 percent of respondents reported they did not have any software needs.

The survey also explored various qualitative aspects of conflict minerals compliance. Survey results discuss several “good” practices exhibited by respondents. These included: verifying 3TG (tin, tantalum, tungsten and gold) presence or lack thereof; effectively and efficiently conceptualizing and implementing an internal conflict minerals program; effective supply chain communication and engagement; and collaboration and standardization through trade associations. Issuers also identified the need to pursue additional opportunities for consolidation and supply chain cost reduction.

The survey included a long list of perceived benefits from the conflict minerals legislation and ensuing regulation that an overwhelming majority of respondents disproved. Responses indicated clear disincentives from sourcing from the DRC region, including higher costs associated with additional reporting and audit requirements and potential damage to brand recognition.

The majority of respondents were downstream, U.S. companies. A total of 178 responses were received, with the electronics sector and aerospace and defense being the largest sectors represented at a combined 31 percent of total respondents.

Chris Bayer, a newly conferred International Development Ph.D., who helped author the 2011 Economic Impact Analysis, worked with the Payson Center of International Development at Tulane University Law School, to develop this survey. IPC was an integral participant in the stakeholder advisory group, which provided important feedback to Mr. Bayer on the survey, and was instrumental in advocating for issuers to participate in the survey.

Read more for complete survey findings.

 

Congressman Rob Woodall Visits Leading Georgia Companies in the Electronics Manufacturing Industry

Today, Congressman Rob Woodall (R-GA-7) met with executives and employees of IPC member-companies, Hunter Technology in Lawrenceville, Ga. and Viscom in Duluth, Ga., as part of a nationwide effort to discuss with policymakers legislative and regulatory issues that affect the electronics manufacturing industry. IPC and its member companies have hosted more than a dozen Members of Congress in 2014 at a variety of locations across the country.

“I’m grateful to Hunter Technology and Viscom for inviting me out to their operations today,” said Rep. Woodall. “The opportunity to hear first-hand from those who work in the manufacturing industry is tremendously helpful. We’re fortunate to have such a robust manufacturing community in the Seventh District, and it’s vitally important that we in Washington, D.C. work in cooperation with our local job-creators and innovators rather than in opposition to them.”

Hunter Technology provides a full range of electronic design, manufacturing and test services. “On behalf of IPC, Hunter Technology, our 350 employees and their families, I’d like to thank Congressman Woodall for his visit to our Lawrenceville factory and for his ongoing support of the manufacturing industry” said Joe O’Neil, President and CEO of Hunter Technology and Vice Chairman of IPC’s Board of Directors.

Viscom is one of the leading suppliers of high-quality inspection systems for electronics assemblies. “It is important for the manufacturing sector to reach out to policymakers and provide a first-hand look at our industry, and I want to personally express our appreciation to Congressman Woodall for taking the time to hear our perspectives,” said Carsten Salewski, CEO of Viscom.

Rep. Woodall toured the facilities and discussed with staff at both sites important policy and regulatory issues impacting the electronics manufacturing sector. Of particular importance was the Revitalize American Manufacturing and Innovation (RAMI) Act. The RAMI Act, recently passed by the U.S. House of Representatives, is awaiting Senate approval. The bill will establish multiple centers for manufacturing innovation, known as Institutes for Manufacturing Innovation (IMI). These centers will focus on different technology areas to strengthen advanced manufacturing in the United States.

Rep. Woodall’s visits were part of IPC’s “Meet the Policymakers” program, through which IPC government relations staff arrange opportunities for IPC members to host elected officials at company locations. IPC member companies interested in hosting a legislator should contact IPC Vice President of Government Relations John Hasselmann at JohnHasselmann@ipc.org.

Hunter Technology visit

Hunter Technology visit

Viscom visit

Viscom visit

 

Experts Question Conflict Minerals Action

While advocacy groups have made conflict minerals a centerpiece of their campaign to stop human rights abuses in the Democratic Republic of the Congo (DRC), a recent open letter by a group of 70 policy experts from around the world questions the benefits of the focus on conflict minerals.

According to the experts, “the conflict minerals campaign fundamentally misunderstands the relationship between minerals and conflict in the eastern DRC.” In contrast to what advocacy groups imply, the academic consensus is that mining is neither the cause of conflict in the Congo nor necessary to keep the fighting going. Conflict minerals contribute to the violence, but they’re also vital to the Congolese people’s survival. The result, according to the letter, is that the ore trade “holds as much potential to help steer the region away from conflict as it does to contribute towards it.”

In recent years, activists believing that removing conflict minerals trade will stop the bloodshed by denying revenue to those perpetrating violence, have succeeded in pushing for language in the U.S. Dodd-Frank Wall Street Reform Act, the Organisation for Economic Co-operation and Development (OECD) and the United Nations published recommendations aimed at cutting off the Congo’s ore trade, and now guidelines under consideration by the European Union.

IPC continues to voice concerns about the cost and unintended results of conflict minerals legislation, both in the United States and European Union.   In May 2012, IPC Board Chairman Steve Puddles testified before the U.S House of Representatives regarding, “The Costs and Consequences of Dodd-Frank Section 1502.”

 

Congressman Prods EPA on Value of Chemicals Reporting

On October 8, 2014, Congressman Bill Johnson (R-OH) sent a letter to U.S. Environmental Protection Agency (EPA) Administrator Gina McCarthy requesting an analysis of reporting data pertaining to byproducts sent for recycling collected during the 2012 Chemical Data Reporting (CDR) reporting cycle. Johnson’s letter stated that, “an analysis of such CDR data is a necessary first step in realizing EPA’s own commitment to reassess the need for CDR information in future reporting cycles and also whether further legislative changes may be needed to ensure that the benefits to EPA of this data collection justify the cost to industry.”

The letter from Congressman Johnson followed February 4, 2014 testimony by Dr. Brent Grazman, vice president, Viasystems Group, Inc. regarding the Toxic Substances Control Act (TSCA) requirement that byproducts sent for recycling be reported to EPA as new chemicals. Dr. Grazman testified that EPA’s reporting requirements for byproducts sent for recycling are burdensome and unnecessary, and serve to discourage recycling.

On August 16, 2011, the EPA issued the TSCA CDR rule (formerly the Inventory Update Reporting (IUR) rule). The CDR rule requires manufacturers of chemicals to report information about the manufacturing (including import), processing, and use of those chemical substances. The final CDR rule explicitly states that byproducts sent for recycling are new chemicals subject to TSCA CDR reporting because they are a feedstock to the recycler and therefore subject to TSCA reporting. This applies to several byproducts produced during the manufacture of printed boards, including copper hydroxide (WWT sludge), copper sulfate (spent baths), cupric chloride (spent etchant), and tetraamine copper dichloride (spent ammoniacal etchant).

For more information on TSCA Reform efforts and the CDR rule, visit IPC’s Environment, Health & Safety web page.

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