IPC Members Advocate for Regulatory Relief

On Tuesday, June 5, 2012, IPC members traveled to Washington, D.C. to meet with senior U.S. Environmental Protection Agency (EPA) staff on regulatory relief. The members advocated for regulatory relief from onerous Resource Conservation and Recovery (RCRA) regulations, the recycling of wastewater treatment sludges from electroplating operations (F006), pointing out that F006 contains a large concentration of valuable metals. EPA is inhibiting recycling by imposing unnecessary burdens through proposed changes to the Definition of Solid Waste (DSW) rule.

Moises Barona, EHS (Environmental, Health and Safety) & Security manager, DDi/Viasystems, Bret Bruhn, environmental engineer/operations manager, Viasystems and Lee Wilmot, director, EHS, TTM Technologies, traveled to Washington, D.C. for this important meeting. Barona, Bruhn, and Wilmot are all active members of IPC’s Environmental, Health and Safety Steering Committee, providing critical information on EHS issues impacting the industry. Wilmot serves as chairman.

During the meeting, they discussed the importance of key provisions that should be included in a final DSW rule, namely the transfer based exclusion and remanufacturing exclusion. The transfer-based exclusion, as finalized in the 2008 DSW rule, would allow generators of F006 to economically transfer secondary materials off-site for recycling. This is critical to printed board (PB) manufacturers because F006 cannot be recycled onsite at PB manufacturing facilities. The transfer-based exclusion would empower the marketplace to create cost-effective recycling options.

Additionally, IPC members discussed the importance of including high-value, metal-bearing secondary materials, such as F006, in the remanufacturing exclusion that was proposed in 2011. They also argued that in order to provide maximal human health and environmental benefits the exclusion should be expanded to take advantage of the principles of natural ecology by allowing remanufactured materials to be used in any appropriate product.

F006 is one of the largest sources in the United States of untapped metal-bearing secondary materials amenable to metals recovery. EPA has long realized the value of these materials and their relatively benign nature and has sought a route to increase their reclamation. Unfortunately, many of these materials continue to be landfilled instead of recycled due to the costly burdens imposed by designation as a hazardous waste.

Additional Resources:

Key points made during the meeting

Follow up letter to EPA senior staff

IPC comments to EPA on proposed DSW rule

More Information on the DSW rule

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