Do You Have a Stormwater Permit for Your Facility?

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

The U.S. Environmental Protection Associations (EPA) is seeking public comment on a proposed 2020 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) for stormwater discharges from industrial activity. This proposed permit would replace the 2015 MSGP upon finalization. This proposed permit would cover stormwater discharges from industrial facilities in areas where EPA is the NPDES permitting authority. Most states have their own programs and you likely would comply with your state’s permit requirements. However, while this industrial stormwater general permit applies to four states (NH, MA, NM, ID) and some designated facilities in some states and Puerto Rico and other territories, it can be copied by many states as the national model rule.

We’ve been alerted to two changes to the proposed MSGP that may impact you now (or later, if your state adopts these changes):

1. Proposed Appendix Q provides Stormwater Control Measure Checklists that should be reviewed to determine if there have been significant changes between the 2015 permit and this proposed permit. The best management practices should be appropriate for electronics (represented as Sector AC), but that would be something we welcome your feedback about.
2. Proposed requirement for quarterly benchmark monitoring for pH, TSS and COD for the five year duration of the permit. Sector AC is deemed part of “light industry” and this sector has had no previous requirements for chemical monitoring. Exceedances of any benchmark could trigger responses that vary depending on the exceedance. (For example, one facility could have costly corrective action based on a single exceedance.)

The presentation from the EPA provides better explanations of what’s happening with the proposed MSGP. Please let us know whether the proposed changes apply to your facility. The comment period ends on May 31, 2020. We have several options to consider regarding how to respond to the EPA, but need your feedback in order to determine the best path.

I look forward to hearing from you.

Interview with Kate Stees – An Emerging Engineer

What better way to learn about the electronics industry than from real people successfully pursuing their careers in great companies? Charlene Gunter du Plessis, Senior Director of the IPC Education Foundation talked to Kate Stees, a Materials and Process Engineer at Lockheed Martin Missiles & Fire Control in Ocala, Florida.

Kate currently works in the failure analysis laboratory supporting a range of electronic assembly related production issues, as well as research and development projects. She has worked for Lockheed Martin Ocala Operations for more than seven years, starting as a Quality Engineer and transitioning to a Manufacturing Engineering role, supporting program assembly builds and the automated processes areas.

Kate is in her final year of the IPC Emerging Engineering program and currently serves as Vice-Chair and A-Team Lead on the IPC-A-610 committee. Kate holds a Bachelor of Science degree in Mechanical Engineering from the University of Central Florida.

We asked Kate questions about the electronics manufacturing industry, tips for career advancement within the industry, and key strategies to prepare for landing a dream job.

Charlene: “What do you love about your profession and the industry in general?”

Kate: “Problem solving, continuous learning and making a difference are the three aspects that I love about my profession and the industry. I get to do all three on the daily bases.”

Charlene: “Why did you decide to become a Materials and Process Engineer?”

Kate: “Working as a Materials and Process Engineer in a failure analysis (FA) laboratory has been the most fun and rewarding job I have had thus far. While I was working in my previous role, as a Manufacturing Engineer, I got a chance to help out in the FA lab. The work in the FA lab has challenged me and helped me grow a diverse set of skills, including technical writing. It also made me feel like I was making a difference. I decided to switch my role to the Materials and Process Engineer when an opportunity came up.”

Charlene: “What was the highlight of your career thus far?”

Kate: “The highlight of my career is making an impact on a global level through participation in IPC Standards creation. I get to make that impact by leading the IPC-A-610 Task Group as a Vice-Chair and A-Team lead, and as a committee member of other IPC Task Groups, including J-STD-001 and IPC/WHMA-A-620.”

Charlene: “What are your goals in terms of engineering today?”

Kate: “My goals in terms of engineering include continuous growth of my technical knowledge and skills, as well as leadership skills which are also critical to have in your engineering toolbox.”

Charlene: “What do you look forward to in the future?”

Kate: “The industry is very fluid in this day and age. I am looking forward to seeing how the industry evolves with the current workforce dynamics, emerging technologies and digital transformation that is taking place.”

Charlene: “How would you describe the term “Engineering”?”

Kate: “Engineering is the application of science and creativity to create tangible solutions to problems.”

Charlene: “You are one of IPC’s Emerging Engineers. Why did you decide to get involved and what are the benefits?”

Kate: “I learned about the IPC’S Emerging Engineering program from Teresa Rowe, IPC liaison, at my first J-STD-001 Task Group meeting. As a newcomer, it was challenging to follow what was happening during the meeting, therefore, I decided to join the IPC Emerging Engineering program to help me expedite the learning process of standards creations. Completing the IPC Emerging Engineering program has enabled me to expand my technical knowledge, leadership skills and vital connections in the electronics industry – it allowed me to become a voice in the industry at an accelerated rate.”

Charlene: “What aspects do you love about your job?”

Kate: “I work in a failure analysis lab that supports a manufacturing floor. What I love about my job is that it is interesting and engaging, and rarely mundane. Even though my job title is a Materials and Process engineer, my job covers many other disciplines of engineering, including mechanical and electrical engineering. I also work with a great group of technical experts that are fun to work with and learn from.”

Charlene: “What makes the industry exciting?”

Kate: “The exciting part about the electronics industry is that it touches every aspect of our lives, from cellphones to medical devices to spacecrafts, and we, the people in the industry, get to be the force that drives the industry.”

Charlene: “What suggestions do you have for students to consider when exploring different career paths?”

Kate: “First, determine what you are passionate about. There are various online tests one can take to help them narrow down their career path. The next step is to expose yourself to the careers that you are interested in by shadowing, interning, volunteering and just asking questions in the fields of interest. This will enable you to narrow down your career choices even further.”

Charlene: “What advice do you have for young professionals, especially students in finding a job?”

Kate: “Networking is the most effective step you can take in finding a job – go to the career fairs, join engineering clubs, create a LinkedIn account. Networking can feel uncomfortable and inauthentic. I am an introvert by nature, so I understand how challenging it can be for some; however, networking is a necessity in today’s world. Creating and nurturing a professional network will lead to more job opportunities and advancements, as well as increased job satisfaction.”

Charlene: “What can a student do to prepare for that interview?”

Kate: “There are a lot of interview tips and tricks that one can find on the internet, but the basics include the following:
Analyze the job that you are interviewing for and research the company.
Make a link between your professional experience and the job requirements.
Review the typical job interview questions and prepare answers.
Pick out your interview attire, print copies of your resume, etc.
Figure out the location of the interview and prepare to arrive early.
The reason for being prepared in every aspect of the interview is to help you stay calm and alert without draining your mental energy on unnecessary tasks and worries during the day of the interview. Additionally, during the interview, don’t forget to relax and make a connection with your interviewer. We tend to get caught up in giving rehearsed answers to tough questions during the interview and forget to make a connection with the person on the other side. Making that connection will bring about a genuine conversation that will bring you a step closer to landing that job.”

Charlene: “Where do you think are the emerging technologies over the next 5 years?”

Kate: “One of the emerging technologies is digital transformation which encompasses Industry 4.0 smart factories, automation, artificial intelligence (AI) and machine learning. Since we live in a digital age, digital transformation is inevitable. The digital transformation will be long and painful process, but it will enable the industry to work smarter. Another emerging technology is additive manufacturing, or 3D printing. Additive manufacturing can solve a multitude of engineering problems including manufacturing of complex designs. It can help consolidate multiple manufacturing steps into one step, increasing the productivity and eliminating waste. These two emerging technologies will completely redefine the industry.”

Charlene: “What do you currently do to change the world of engineering today?”

Kate: “I am changing the world of engineering through my participation in creation of the IPC standards. Collectively, the members of the IPC are making a global impact by ensuring that the industry designs and manufactures electronics to the highest quality standards.”

Charlene: “Thank you so much for your time. We wish you all the best!”

Kate: “Thank you for the opportunity.”

301 Tariff Update — U.S. Suspends Certain Import Duties

by Chris Mitchell, vice president, global government relations

The U.S. Trade Representative (USTR) has prioritized the review of Section 301 exclusion requests related to the U.S. response to COVID-19. In March, USTR granted approximately 200 separate exclusions primarily covering personal protective equipment products and other medical-care related products.

On March 20, USTR published in the Federal Register a request for comment on additional 301 exclusions necessary to combat COVID-19. The docket for comment will remain open until June 25 and will be extended as appropriate. More information about the process for submitting an exclusion request can be found here.

This week, Senators Tom Carper (D-Del) and Pat Toomey (R-PA) urged USTR to suspend the Section 301 tariffs on Chinese products identified as necessary inputs for the manufacture of medical supplies and equipment. They said that companies “should not be subjected to the lengthy process of submitting tariff exemption requests for each individual input required to make products essential for addressing the ongoing pandemic.”

Suspension of Certain Import Duties
President Trump issued an Executive Order April 19 authorizing temporary relief of the payment of certain duties, interest and fees associated with imported merchandise. The move is designed to provide relief to importers struggling with liquidity issues amid the COVID-19 pandemic. The order calls for 90 days of deferral for regular tariffs only for importers who can establish they are experiencing significant financial hardship related to COVID-19. The deferral does not apply to tariffs imposed for remedial purposes, including Section 232 steel and aluminum tariffs, Section 201 and Section 301 tariffs, or antidumping and countervailing duty tariffs.

The temporary postponement applies to merchandise imported in March or April 2020. CBP (U.S. Customs and Border Protection) will not return deposits of estimated duties, taxes, and fees that have already been paid. CBP will consider an importer to have experienced significant financial hardship if:

1. the importer’s operations are either fully or partially suspended during March 2020 or April 2020 due to orders from a governmental authority limiting commerce, travel, or group meetings due to COVID-19: and
2. the gross receipts of such importer for March 13-31, 2020 or April 2020 are less than 60 percent of the gross receipts for the comparable period in 2019.

CBP guidance clarifies that no interest will accrue – and that no penalty, liquidated damages or other sanctions will be imposed – for the postponed payment of such estimated duties, taxes, and fees during the 90-day deferral period. The Department of Homeland Security published the final rule on April 22. CBP has also published a FAQ.

IPC Responds to COVID-19

John Mitchell, IPC president and CEO, provides information on how IPC and the electronics manufacturing industry are responding to the coronavirus pandemic.

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

Real-time Update on Electronics Manufacturing and COVID-19 – April 6, 2020

As health officials around the globe struggle to “flatten the curve” of coronavirus cases, the electronics manufacturing industry continues to face ambiguous operating restrictions, uncertain economic conditions, abnormalities in supply chains, and greater gaps in the workforce.

Over the past week, IPC has continued to monitor the health of the electronics manufacturing industry amid the COVID-19 pandemic, including an ongoing series of calls with member company executives. The following observations are current as of April 6, 2020.

Executives remain very concerned about the impacts of COVID-19. Some 43 percent of executives who replied to IPC’s latest online poll said they were “extremely” concerned, and 92 percent were “somewhat” or “extremely” concerned. Only 8 percent are neutral or unconcerned.

Medical equipment production is ramping up. Some companies are reporting they have stopped making their usual products in order to produce inputs for medical equipment. According to IPC’s most recent online poll, roughly 7 percent of companies have stopped production of other equipment in order to create capacity for medical equipment.

Companies continue to face a myriad of abnormal conditions. Eighty percent of executives who responded to our online poll reported a variety of supply constraints as a result of the coronavirus outbreak. Some 30 percent of respondents reported facing abnormal workforce issues; 30 percent reported abnormal shipping costs; 33 percent reported abnormal shortages; and 55 percent reported abnormal shipping delays. Roughly one in five executives (20 percent) reported they are facing no abnormal supply constraints.

Slowing demand is slowing manufacturing output. Some companies report that they haven’t felt any pressure to ramp up production back to full capacity in China or elsewhere. Some believe that demand will return by the second half of 2020, but there remains significant uncertainty.

Stockpiling or buying ahead not likely to happen. Some companies report they are not stockpiling supplies or buying ahead because “cash is king” in the current environment.

Hardship and retention bonuses are appearing. Executives report a variety of approaches to employee compensation. Some companies are offering “supportive” or “supplemental” pay with the recognition that this is a more difficult time for some employees. Other companies report they are offering bonuses later in the year, when cash flows will be more certain, for employees who continue to show up throughout the crisis. Some companies are paying workers double-time immediately if they’ve worked more than 48 hours a week. Some companies are reporting bonus programs for the next 90 days to ensure they can retain critical mass within certain areas of the business.

Executives weigh temporary leave versus layoffs or retention of workers after coronavirus. Some companies report they have workers on temporary leave (furlough) as work has dried up. The challenge is guessing what demand will look like after the worst of COVID-19 passes, and how many workers they will need versus possible layoffs of staff.

Some expect strong backlogs. Some companies report their customers have strong backlogs, and they expect demand to improve as we emerge from the worst of COVID-19. Companies in the defense sector continue to report that orders are flowing, without signs of weakness.

Safety committees are active. Companies report they continue to have a strong focus on employee safety. Some report they are convening their safety committees as often as daily to address any issues.

Success stories:

Winchester Interconnect was selected by General Motors to help them manufacture Ventec ventilators. The company faced several issues as they ramped up, including tooling availability and lead times. They needed to borrow and rent applicators for two to four weeks while they waited for purchased units to arrive. IPC played a helpful role by sharing that request with the industry at large. Three different manufacturers and five different part numbers were involved, but the need was met within one day. “This is the kind of opportunity where we can come together as a community,” said IPC President and CEO John Mitchell.

Green Circuits was profiled by journalist Tim Aeppel of Reuters. Company CEO Joe O’Neil highlighted the challenges of staying operational in Santa Clara County, which was among the first U.S. localities to institute a shelter-in-place order.
IPC Updates: IPC staff remains on the job working to support the needs of the industry.

Visit IPC’s COVID-19 resource page at www.ipc.org/coronavirus to access more information about:

IPC’s Policy Roadmap for Economic Recovery
• Industry needs and opportunities
• Federal assistance for electronics manufacturers
• Changes to IPC workforce training & certifications
• Changes to IPC’s calendar of events and meetings
• Ongoing IPC standards development activities

For more information related to this Industry Update, please contact:
John Mitchell
President and CEO
JohnMitchell@ipc.org

Shawn DuBravac
Chief Economist
ShawnDuBravac@ipc.org

Chris Mitchell
Vice President, Global Government Relations
ChrisMitchell@ipc.org

 

 

 

 

An IPC Policy Roadmap to Economic Recovery

By Chris Mitchell, vice president, global government relations

As the unprecedented COVID-19 crisis continues to unfold, IPC is calling for a bold, sustained policy agenda to help the electronics manufacturing sector weather the economic downturn and support the economic recovery.

There can be no doubt that governments all over the world should take extraordinary measures to keep the electronics manufacturing sector healthy. According to new, soon-to-be published data from IPC, our industry supports more than 5.3 million U.S. jobs and drives more than $714 billion in U.S. GDP, almost 4% of total U.S. GDP. Every U.S. electronics manufacturing job supports an estimated three other jobs in the U.S. economy.

Our industry’s role is equally important – and in some cases even more important – in the economies of other nations. Electronics are at the heart of thousands of products and hundreds of industries worldwide, with healthcare prominent among them. Our supply chains need to keep flowing to keep the overall economy growing.

Over the last month, governments and central banks around the world have taken a series of actions to blunt the economic carnage. In the United States, IPC commended President Trump and Congress for reaching agreement on a $2 trillion economic stabilization package including $500 billion in loans and loan guarantees for hard-hit companies, including $17 billion for businesses critical to national security; plus another $350 billion targeted to help small businesses; and $50 million for the Hollings Manufacturing Extension Partnership, which helps small- and medium-sized manufacturers maintain and expand their markets.

Moreover, the Federal Reserve’s decision to lower interest rates and inject cash into the nation’s financial system will help maintain liquidity at a time when firms of all size need it. Many other national, regional, and local governments have taken similar actions.

And yet, we’re still on the front end of this emerging crisis, and more will need to be done.

For all these reasons, IPC consulted with its members and industry experts and developed an IPC Roadmap to Economic Recovery, with additional steps that we recommend governments should take to help sustain our industry and the broader economy. Those steps are:

Keep Essential Electronics Manufacturing Open

  • States and localities should adopt the Department of Homeland Security’s (DHS) definition for “critical infrastructure,” which covers factories related to defense and healthcare; commit to keeping these critical manufacturing facilities open; and ensure that curfews do not impede a healthy workforce from getting to and from manufacturing facilities.

 Support Supply Chain Resiliency

  • Congress should establish a $10 billion Electronics Manufacturing Initiative to enhance the resiliency and security of the nation’s electronics value chain by establishing public-private partnerships focused on the following priorities:
    • Capacity: Grow domestic capacity for electronics manufacturing and establish systems to monitor capacity in times of crisis.
    • Capabilities: Spur investment and R&D in artificial intelligence (AI) and other technologies that make U.S. manufacturers more globally competitive.
    • Workforce: Bridge the skills gap through more robust federal support for online workforce training and credentialing.
    • Resiliency: Establish metrics for industrial base resiliency with capacity, capabilities and geographic diversity as key factors.
    • Security: Integrate resiliency and security initiatives to strengthen the trusted electronics supply chain.

Spur Global Trade by Cutting Tariffs

  • The Trump administration should suspend the imposition of import duties through December 31, 2020 on all products from countries that agree to provide reciprocal treatment for U.S. exports; and allow companies to defer payment of import duties through December 31, 2020.
  • The Trump administration should reinvigorate negotiations with China on a “Phase 2” deal and suspend Section 301 tariffs on imports related to healthcare and other vital supplies necessary to combat COVID-19.
  • Congress should increase funding for U.S. export promotion programs, including the U.S. Foreign Commercial Service and Small Business Administration, to help U.S. manufacturers compete in the global marketplace.

Delay Non-Essential Rulemakings

  • The Trump administration should put a 90-day pause on non-essential regulatory rulemakings unless they are directly related to urgent public health, environmental health, or economic recovery efforts. We need our business leaders to focus on maintaining compliance with existing regulations while taking on appropriate pandemic response actions.  A 90-day pause on new proposals and implementation of new requirements will likely guarantee better compliance in due time.

Facilitate Shipping & Transportation Recovery

  • Governments at all levels should support the continued and robust operation of U.S. ports to ensure so that food, medical equipment and other vital supplies will continue to reach people.
  • Governments should incentivize airlines to expand cargo capacity and keep air freight rates on par with historical norms.
  • Congress should enact landmark transportation legislation that, among its goals, expands capacity on U.S. freight corridors.

 Support the Financial Security of Manufacturing Workers

  • The Labor Department should facilitate federal and state cooperation to allow companies to pay a portion of wages to underemployed workers who may be receiving unemployment benefits.
  • Congress should provide a tax credit for employers who continue to pay workers who are quarantined, have exhausted their allotted leave time, or have had their workplace shutdown.

Keep Manufacturing Workers Healthy

  • CDC should issue guidance related to cleaning processes, social distancing, and other operational practices that can help stem the spread of the virus in facilities that must stay open given the “essential” nature of their production.
  • Congress should enhance tax deductions for employers who invest in safety equipment, including hand washing stations, respiratory equipment and cleaning products.

These actions – expressed in terms aimed at U.S. policy makers but applicable to policy makers all over the world – would allow electronics manufacturers to serve the near-term needs of a world in crisis, while also providing immediate and long-term economic stimulus.

If you agree with the proposals in the IPC Roadmap for Economic Recovery, I encourage you to download it and share it with your elected officials. The Roadmap will form the core of IPC’s advocacy agenda for the foreseeable future.

Meanwhile, if your company is experiencing any problems or uncertainties caused by the government’s response to COVID-19, we want to hear from you and assist you. IPC’s coronavirus resource page, including webinars with industry experts and tips for what you can do, is here.

If you would like to receive our weekly advocacy reports and occasional action alerts to get involved in our advocacy, visit our “A Team” page and sign up.

As IPC President and CEO John Mitchell said in his keynote speech at APEX 2020, “This industry knows all about change. We are disruptors, and we are used to being disrupted ourselves. … The companies that will thrive amid the radical changes occurring all around us will be the ones who take responsibility and lead the change.”

IPC will continue to be your partner and supporter through all the changes that lie ahead.

 

 

Important Update Regarding the TSCA Fees Rule and Your Company

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

Over the past month, IPC has brought to your attention that the TSCA Fees Rule may apply to your company beginning in 2020 and that there could be several challenges for those who need to comply. Challenges include the requirement to self-identify as a manufacturer that imports articles containing high-priority substances and the subsequent requirement to form consortia with other manufacturers in order to make fee payments to the U.S. EPA for risk evaluations. IPC has worked with the EPA to bring awareness to these challenges via meetings with senior officials and through comments to the public docket. Those comments include both a request for an extension to the comment period as well as a collaboration with the Consumer Technology Association (CTA) and Information Technology Industry Council (ITI) to address concerns regarding burdens to the electronics industry around the requirement to self-identify as an importer of an article containing a TSCA High-Priority Substance.

We are glad to report that on March 25, the EPA confirmed that it is exploring potential exemptions to the TSCA Fees Rule for manufacturers that:
– import articles containing high-priority substances;
– produce the chemical substance as a byproduct; and
– produce or import the chemical substance as an impurity.

This announcement means that the EPA is no longer expecting manufacturers in this category to self-identify under the TSCA Fees Rule. This potential regulatory relief could reduce long-term administrative and financial burdens for those manufacturers that fall into this category.

Also, the EPA is providing a No Action Assurance to these manufacturers with respect to the self-identification requirements; the No Action Assurance establishes that the EPA will exercise its enforcement discretion to not pursue enforcement action for violations of the self-identification reporting obligations.

Regardless of this proposed regulatory and enforcement relief, companies that were already erroneously identified by the EPA on their preliminary list of fee payers should still plan to certify in the EPA’s Chemical Data Exchange (CDX) system if they fall into this category.

For all potentially affected stakeholders, IPC recommends that you:
1. Determine whether you are a manufacturer or importer of any of the HP substances or if you are an importer of articles containing HP substances, produce the chemical substance as a byproduct or as an impurity.
2. Review the preliminary lists of manufacturers and importers of HP substances as compiled by the EPA. Your company belongs on the list if it manufacturers or imports any of the substances.
3. If your company is listed incorrectly, then a correction notice must be submitted during the open comment period. Corrections are submitted through the Chemical Data Exchange (CDX) system. The EPA has modified the CDX to facilitate responses for those who fall into the potentially exempt category of manufacturers. Here are instructions for reporting to the CDX.
4. If you believe that your company needs to be listed, then you are required to self-identify through the CDX system.

Please contact me with your questions regarding this update on the TSCA Fees Rule and its applicability (or lack of applicability) to your company.

The Coronavirus Outbreak Will Likely Impact New Product Introductions

By Shawn DuBravac, IPC chief economist and Matt Kelly, IPC chief technologist

According to IPC’s recent Coronavirus impact study (March update), roughly 22 percent of electronics manufacturers and suppliers reported that the coronavirus outbreak will result in fewer new product introductions (NPIs) in 2020. In a normal year, original equipment manufacturers (OEMs) would be readying production of new products to be released in the coming year. This is especially true for consumer electronics manufacturers, which tend to follow six- to 12-month cycles and aim to release NPIs in the fall months just ahead of the holiday shopping season.

Electronics manufacturers in the OEM supply chain would generally prepare for NPIs by traveling several times to visit input suppliers in the lead-up to full-scale production. Each of these trips would last up to a few weeks and would involve all aspects the NPI process, including design tweaks, incoming component supply, assembly and test process definition, product qualification, reliability assurance, manufacturing yield assessment, and final product fulfillment models – all in preparation to support ramp to volume production requirements.

Corporate travel bans have cancelled many of these trips and left engineering teams rushing to develop alternative approaches. Some are turning to U.S. firms to help. Because build schedules are already extremely tight, delays of any kind could impact planned product release dates. In short, the coronavirus outbreak is causing delays that could affect planned NPIs.

Some companies are already reporting such impacts. Arlo Technologies, a maker of wireless security cameras, noted in its fourth-quarter 2019 financial results conference call that “coronavirus is impacting our business on the supply side as our vendors do not have sufficient quantities of the required components to fulfill our demand … Additionally, in the second quarter, we have new product introductions planned that we believe will be impacted by the component shortages, as well as delayed delivery of some of the manufacturing equipment from China.” Logitech noted in a statement that “due to the availability of labor and varying timing of component supply recovery, there is potential for delays to new product introductions.”

Because of the long lead times involved, timing constraints and travel bans that hinder collaboration between designers, engineers, and manufacturing facilitates could also impact NPIs in 2021, even if other impacts from the coronavirus outbreak are reversed quickly.

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Electronics Supply Chain in Flux Due to Tariffs, Epidemic, Other Factors

by Shawn DuBravac, IPC chief economist

Over the last year, electronics manufacturers have been adjusting their supply chains, driven by a variety of factors but especially trade tensions between the United States and China and the growing expectation that higher tariffs between the U.S. and its partners may be “the new normal.”

More recently, the coronavirus epidemic that originated in China and now is sweeping the world is driving further decoupling between China and the United States. A recent IPC survey of its members revealed an overwhelming majority (84 percent) were worried about the epidemic’s impact on their business operations, with some looking to develop alternative sources of inputs from other countries.

The primary beneficiaries to date include countries with competent workforces, modern infrastructure, and congenial business environments, including Mexico, Vietnam, Indonesia and Taiwan, where we do see some elements of the electronics supply chain expanding.

If your company is contemplating or in the process of sourcing from new countries instead of China, I would be interested in hearing from you as part of IPC’s ongoing research and monitoring efforts. Your information will be held in confidence, although we are always looking for members who are willing to share their insights and experiences with reporters and policymakers.