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.