Important Advocacy Opportunity: How Is Your Company Affected by US EPA Action on High-Priority Substances?

By Kelly Scanlon, director, environment, health and safety policy and research, IPC

The U.S. Environmental Protection Agency (EPA) released “scoping documents” for its upcoming reviews of certain high-priority chemical substances under the Toxic Substances Control Act (TSCA) Section 6(b). Your review of these documents is important because scoping is the foundation of the risk evaluation process that will eventually determine how EPA regulates or mitigates unreasonable risks.

Several of the substances are relevant to electronics manufacturing – flame retardants, phthalates, solvents, and formaldehyde – and IPC will work with electronics manufacturers like you to ensure a thorough review of the draft scoping documents.

You’ll recall that in 2019, the EPA designated 20 chemicals as high-priority (HP) substances for upcoming risk evaluations. EPA’s next step is to produce a scoping document for each chemical, identifying its conditions of use, hazards, exposures, and potentially exposed or susceptible subpopulations.

On April 6, the EPA released drafts for 13 of the HP substances, and on April 17, the EPA released an additional seven drafts.

Now is your chance to review these draft scoping documents; the current comment period is through mid-May for the first 13 drafts and the beginning of June for the remaining seven drafts. 

The TSCA High-Priority Substances Sorted by Applicability to Electronics Manufacturing table and link below lists and provides links to all the designated HP substances; as well as the relevant draft scoping documents; and information from the draft about the substances’ possible uses in electronics. If your company manufactures, imports, processes, distributes, uses, or disposes of any of these chemical substances, then you will want to consider reviewing the drafts and providing information to EPA about the chemicals’ conditions of use.

Please consider the following questions as you review the draft scoping documents and consider whether to prepare comments to the EPA in conjunction with IPC.

• Did the EPA accurately identify this chemical substance’s use, based on your knowledge of electronics manufacturing and production processes?
• If not, how would you describe the scenario of use for the chemical substance, including potential human or environmental exposures?
• Does your company have access to or the ability to collect exposure data or information?
• What is the chemical’s criticality to the process and the product?

We will have several opportunities to engage with the EPA during the risk evaluations, but our effectiveness will depend on the quality of our information and insights, our members’ level of engagement, and our pro-active engagement and knowledge-sharing with the EPA TSCA team.

Our collective mission is to help the EPA develop policies that accurately reflect the uses of these chemical substances in our industry, and properly balance risk and cost-effectiveness. IPC will continue to facilitate that effort, with your help. Please contact me with any questions or comments at KellyScanlon@ipc.org.

TSCA High-Priority Substances Sorted by Applicability to Electronics Manufacturing 

TSCA High-Priority Substances CASRN Draft Scoping Document Release Date Applicability to Electronics as Mentioned in Draft Scoping Document
Triphenyl Phosphate (TPP) 115-86-6 April 6, 2020 Flame retardant used in computer and electronic product manufacturing
Tris(2-chloroethyl) Phosphate (TCEP) 115-96-8 April 6, 2020 Flame retardant used in electronic products
4,4′-(1-Methylethylidene)bis[2,6-dibromophenol] (TBBPA) 79-94-7 April 6, 2020 Flame retardant used in production of electronical and electronic products
trans-1,2-Dichloroethylene 156-60-5 April 6, 2020 Solvent used for electronics degreaser and flux remover
1,1,2-Trichloroethane 79-00-5 April 6, 2020 Solvent used in plastic and petrochemical manufacturing; draft scoping document includes information regarding electronic materials and flexible printed circuit manufacturing
Formaldehyde 50-00-0 April 17, 2020 Plating agent; draft scoping document mentions use as a chemical substance in commercial and consumer electrical and electronic products.
Phthalic Anhydride 85-44-9 April 17, 2020 Industrial use as load absorber and industrial and commercial uses in electrical and electronic products; used in electronics adhesives (5 to 10% phthalic anhydride); used in production of plastic and rubber products including electronics.
Di-Ethylhexyl Phthalate (DEHP) 117-81-7 April 17, 2020 Phthalate used in consumer or commercial electrical and electronic products; used in adhesives for electrical tape; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.”
Butyl Benzyl Phthalate (BBP) 85-68-7 April 17, 2020 Phthalate with industry and commercial uses to include adhesives, sealants, floor coverings, paints and coatings, and use in plastic and rubber products; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.”
Dibutyl Phthalate (DBP) 84-74-2 April 17, 2020 Phthalate used in ink, toner, colorant products used in the electronics industry; consumer exposures from products and articles include electrical and electronic products; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.”
Di-isobutyl Phthalate (DIBP) 84-69-5 April 17, 2020 Phthalate; No specific electronic equipment uses listed in draft scoping document; Phthalates DEHP, BBP, DBP, and DIBP were added to Annex II to the RoHS Directive 2011/65/EU, “Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials.”
Dicyclohexyl Phthalate 84-61-7 April 17, 2020 Phthalate with industrial use in adhesives and sealants in electronic product manufacturing; industrial use in plastic and rubber products in electronic product manufacturing
Di-isodecyl phthalate (DIDP) 26761-40-0, 68515-49-1 Expected later April 2020 (Possible use. This is a manufacturer-requested risk evaluation)
Di-isononyl phthalate (DINP) 28553-12-0; 68515-48-0 Expected later April 2020 (Possible use. This is a manufacturer-requested risk evaluation)
1,1-Dichloroethane 75-34-3 April 6, 2020 No mention of electronics production in draft scoping document
1,2-Dichloroethane 107-06-2 April 6, 2020 No mention of electronics production in draft scoping document
1,2-Dichloropropane 78-87-5 April 6, 2020 No mention of electronics production in draft scoping document
1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-Hexamethylcyclopenta[g]-2-Benzopyran (HHCB) 1222-05-5 April 6, 2020 No mention of electronics production in draft scoping document
1,3-Butadiene 106-99-0 April 6, 2020 No mention of electronics production in draft scoping document
Ethylene Dibromide 106-93-4 April 6, 2020 No mention of electronics production in draft scoping document
o-Dichlorobenzene 95-50-1 April 6, 2020 No mention of electronics production in draft scoping document
p-Dichlorobenzene 106-46-7 April 6, 2020 No mention of electronics production in draft scoping document

TSCA High-Priority Substances Sorted by Applicability to Electronics Manufacturing

One Comment

  1. Posted April 10, 2020 at 3:52 pm | Permalink

    Formaldehyde is the reducing agent in most electroless copp0er plating solutions used to make vias in printed conductive. It is a critical material for the reliable manufacture of most printed circuits, especially HDI circuits. multilayer circuits and semi-additive circuits.


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