Category Archives: IPC

Congress Votes to Overturn OSHA Recordkeeping Rule

Yesterday, March 22, 2017, the Senate passed H.J. Res. 83, the Congressional Review Act (CRA) resolution to invalidate an Occupational Safety and Health Administration (OSHA) regulation which was promulgated in December 2016 to overturn the 2012 D.C. Circuit Court “Volks” decision regarding the statute of limitations for recordkeeping violations.  The “Volks” CRA was previously passed […]

IPC Files Comments on TSCA Inventory Reset

On March 14, 2017, IPC filed comments on the EPA’s proposed regulations to “reset” the inventory by sorting the TSCA inventory into active and inactive chemicals.  The inventory reset is one of the implementing regulations under the “Frank R. Lautenberg Chemical Safety for the 21st Century Act” (LCSA) which amends the Toxic Substances Control Act […]

IPC Comments on SEC Conflict Minerals Regulation

On March 16, 2017, IPC filed comments with the Securities and Exchange Commission (SEC) asking the SEC to consider modifications of the rule and Section 1502 to reduce the burden on U.S. manufacturing industries. The comments were filed in response to Acting SEC Chairman Michael S. Piwowar’s January 31, 2017 statement, questioning the effects of […]

IPC Supports EU Vote for Voluntary Conflict Minerals Requirements for Manufacturers

On March 16, 2017, the European Union (EU) Parliament voted to adopt regulations regarding the sourcing of conflict minerals in high risk zones. The regulations, which require supply chain due diligence self-certification of tin, tantalum and tungsten, their ores, and gold originating in conflict-affected and high-risk areas, are mandatory for smelters and importers of raw […]

IPC Meets with EPA Transition Team on RCRA Hazardous Waste Generator Improvements Rule

IPC met last week with EPA senior staff to discuss our concerns with the recently published Hazardous Waste Generator Improvements Rule and the February 24 petition for review filed with the D.C. Circuit Court of Appeals by IPC and eight other trade associations. Although EPA’s rule includes some common-sense updates that will bring greater efficiency […]

New Draft Guidance on REACH Substances in Articles

On February 1, 2017, the European Chemicals Agency (ECHA) shared a revised draft of their Guidance on requirements for substances in articles. The current draft of Version 4.0 is being shared with members of the Forum for Exchange of Information on Enforcement (Forum), which is a network of authorities responsible for the enforcement of the […]

PD18 : Preventing Production Defects and Product Failures

Under today’s manufacturing and market environment, the effort to maximize production yield, reduce cost, and assure product reliability is becoming increasingly important to a company’s competitiveness. Considering the new and anticipated developments in packaging and assembly and with the goal of achieving high yield and reliability in mind, the “how-to” prevent prevailing production defects and […]

ECHA Guidance on Substances in Articles Delayed Until Summer

The European Chemicals Agency (ECHA) announced earlier this week that the update of their guidance on Substances in Articles will not be published until July or August 2017.  ECHA had previously indicated that guidance would be released in early 2017. The delay is needed to allow ECHA to evaluate the nearly 700 comments on its […]

SEC to Reconsider Conflict Minerals Guidance

On January 31, 2017, Acting Securities and Exchange Commission (SEC) Chairman Michael S. Piwowar released a public statement directing the SEC staff to consider whether their 2014 guidance is still appropriate and whether any additional relief is appropriate.  The guidance was issued by the SEC after the April 2014 D.C. Circuit Court of Appeals’ finding […]

OECD Public Consultation on Due Diligence Guidance for Supply Chain Issues

The Organization for Economic and Cooperative Development (OECD) is currently developing a general OECD Due Diligence Guidance for Responsible Business Conduct and Companion to the Due Diligence Guidance to provide practical support to companies on the implementation of the OECD Guidelines for Multinational Enterprises. Both the U.S. Dodd-Frank and the recent EU legislation reference the OECD […]