U.S. EPA Moving Toward Risk Management Deliberations on Toxic Chemicals

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

The U.S. Environmental Protection Agency (EPA) is approaching a critical phase of deliberations under the Toxic Substances Control Act (TSCA), and the next several steps in the process will have major ramifications for electronics manufacturers, who need to focus on this issue now to protect their own long-term interests and help IPC advocate for the industry.

The EPA’s process for assessing and managing risks from existing chemicals has three basic steps: prioritization, risk evaluation, and risk management.

Currently, there are two cycles of this three-step process happening at the same time, for two different sets of chemicals. In the first cycle, EPA is nearing the completion of 10 risk evaluations; in the second cycle, EPA is just beginning the risk evaluations for 20 more high-priority chemical substances.

Just over the horizon, the EPA will begin to consider and then propose actual risk management strategies for the first 10 of these chemicals. By law, the EPA is required to take action to address such risks within two years after a risk evaluation is published. This will be the first time that the EPA is doing risk management under the 2016 amendments to TSCA, so it’s a unique opportunity to get involved.

Thus, now is the time for our industry to get organized, collaborate, and prepare to advocate our views on how the EPA should address any unreasonable risks to human health and the environment. The EPA is seeking input from us, and our expertise will be critical to forging smart solutions to manage and address risks.

Which chemicals are we talking about?

Since June 2020, the EPA has published three final risk evaluations for:

  • methylene chloride (CAS 75-09-2);
  • 1-bromopropane (CAS 106-94-5); and
  • cyclic aliphatic bromide cluster chemicals (CASRN 25637-99-4, 3194-55-6, and3194-57-8), including hexabromocyclododecane (HBCD).

Notably, each of these risk evaluations mentions the use of these chemicals in electronics.

  • For methylene chloride, the EPA has determined that the use of this chemical as a solvent in industrial processes where electronics equipment, appliance, and component manufacturing takes place presents an unreasonable risk of injury to human health.
  • For 1-bromopropane, the EPA has determined that the use of this chemical as a solvent for cleaning or vapor degreasing in the manufacturing of electrical equipment presents unreasonable risks of injury to human health.
  • For HBCD, the EPA has determined that the use of this chemical in solder paste or flux presents an unreasonable risk to the environment.

To manage unreasonable risks, the EPA has several regulatory options at its disposal, including the ability to prohibit, limit, or otherwise restrict their manufacture, processing, or distribution for particular uses; to regulate the manner or method of their disposal; to regulate how risks are communicated to consumers and various supply chain actors; and/or to require monitoring, testing, and recordkeeping.

If you have information that is relevant to these proceedings, we need to hear from you. Specifically, if you have information on safe and essential uses; on safe and effective alternatives; or on uses that have been phased out or can be phased out; then now is the time to get ready to work with IPC and engage with the EPA. 

The IPC Government Relations team will facilitate and coordinate a unified industry response. Ultimately, the EPA needs our knowledge and expertise to arrive at solutions that protect human health and the environment and enable our industry to thrive.

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