IPC Reponds to U.S. House Committee Regarding Burdensome Federal Regulations

Last month, staff for Congressman Issa, chair of the Committee on Oversight and Government Reform, contacted IPC regarding burdensome federal regulations facing our industry. After consulting with members of the IPC Government Relations Committee and Environmental, Health, and Safety Steering Committee, IPC sent a letter to Congressman Issa and Subcommittee chair Jordan today. The text of the letter is provided below.

June 1, 2012

Representative Darrell E. Issa
Chairman, Committee on Oversight and Government Reform
U.S. House of Representatives
2347 Rayburn House Office Building
Washington, D.C. 20515-6143

Representative Jim Jordan
Chairman, Subcommittee on Regulatory Affairs, Stimulus Oversight and Government Spending
U.S. House of Representatives
1524 Longworth House Office Building
Washington, D.C. 20515-6143

Dear Chairman Issa and Jordan,

IPC – Association Connecting Electronics Industries once again wishes to thank you for the opportunity to provide insight on existing and proposed regulations that have negatively impacted the economy and job growth.  Although excessive regulation is not the only cause of reduced U.S. employment in the electronics industry, regulations are a significant cause of the continuing decline of U.S. employment in the electronics manufacturing sector.  According to BLS statistics, employment in the printed board industry decreased by 29% between 2008 and 2010, a loss of over 15,000 jobs. Similarly, employment among electronic manufacturing service (electronics assembly) companies decreased by 14% over the same time period.

We would like to call your attention to three regulations and one issue that will have a significant negative impact on manufacturers, and therefore warrant oversight.

  • The Security and Exchange Commission’s (SEC’s) proposed regulations on conflict minerals (SEC Release No. 34-63547; File No. S7-40-10). The regulations being developed by the SEC under Section 1502 of the recent Dodd-Frank Wall Street Reform and Consumer Protection Act could impose extremely burdensome reporting requirements on manufacturers, such as electronics manufacturers, that use tin, gold, tantalum, and tungsten in their products.
  • The Environmental Protection Agency’s (EPA’s) modifications of the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) Rule (76 CFR 50816 August 16, 2011). By requiring all manufacturers that recycle byproducts to report those byproducts as new chemicals, the EPA will create burdensome, costly and unnecessary regulatory requirements that penalize manufacturers for doing the right thing – recycling. The CDR rule results in duplicate, and in some case triplicate, annual reporting of many of these byproducts which are already reported under the EPA Toxic Release Inventory (TRI) program and under Resource Conservation and Recovery Act(RCRA) biennial reporting.
  • The EPA’s reopening of the Definition of Solid Waste (DSW) rule (EPA–HQ–RCRA–2002–0031). The EPA’s decision to reopen the DSW rule, which was finalized in October 2008 to lessen regulatory burdens blocking the recycling of secondary materials, would impose significant regulatory burdens on recycling.
  • Our members are increasingly concerned that OSHA is stretching the boundaries of their authority to support expansive interpretation and enforcement of OSHA regulations.  Two recent court decisions to overturn unwarranted citations and penalties, Caterpillar Logistics Services, Inc. v. Sec’y of Labor, No. 11-2958 (7th Cir., Mar. 20, 2012), and AKM LLC dba Volks Constructors v. Secretary of Labor, Civ. No. 11-1106, are indicative of these issues.

Thank you for your attention to these and other issues affecting American competitiveness.  Please feel free to contact Fern Abrams, Director of Government Relations, at 703-522-0225 or fabrams@ipc.org for more information about any of these issues.


Dr. John W. Mitchell
President and CEO
IPC—Association Connecting Electronics Industries

One Comment

  1. pellontyres
    Posted June 23, 2012 at 10:30 am | Permalink

    hi this is all very important work carried out by highly intelligent and intellectual people please carry on the good work. Eric Roberts

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