TSCA

The U.S. Toxic Substances Control Act (TSCA) requires the Environmental Protection Agency (EPA) to cost-share risk assessment fees for 20 chemicals designated as high priority across all U.S. manufacturers (including importers) that produce or import at least one of the chemicals including Formaldehyde, Di-ethylhexyl phthalate (DEHP) and Dibutyl phthalate (DBP). Providers of the substances must self-declare as manufacturers or importers under a 5-year look-back requirement.The SEMI EPA TSCA working group formed to assess the potential impact of the self-declaration requirement has uncovered two points of primary concern: 1. Of the 20 substances, about 10 are commonly found in electro-technical components such as capacitors, resistors, transformers and power supplies.2. Companies that import articles (e.g., components and parts) containing any level of these substances, even unintended residue from a production process upstream in their supply chain of imported articles, must self-identify. Manufacturers and importers that self-identify will be required to share the $1.4 million risk-assessment cost per substance. Small business concerns qualify for an 80 percent discount, with larger businesses covering the balance.The EPA has identified a preliminary list of companies that provide each chemical. The number of companies on the lists ranges from two to 525.On January 27, 2020, the EPA opened a 60-day period for organizations to submit comments to the EPA and self-identify as a manufacturer (or importer). SEMI plans to submit comments prior to the March 27 deadline, in part to request an extension.More information is available by visiting the Federal Register or contacting Olivier Corvez. This EPA webpage contains a February webinar transcript that is also a helpful resource.Olivier Corvez is senior manager of Environment, Health, Safety and Sustainability at SEMI.

Environmentally sound policies and the health and the safety of workers in the microelectronics supply chain are vitally important to SEMI and its members. For more than two decades, together we have focused on worker safety by focusing on global environment, health and safety (EHS) compliance and regulatory issues and the advancement of sound EHS practices. Today, EHS has taken on an even higher profile in the microelectronics industry with its growth across Europe, North America and Asia. Never has the industry been under greater scrutiny. The list of regulatory agencies is growing. To keep pace with rising EHS requirements and continue to ensure worker safety, we’d like your help. The SEMI EHS summit will open with a keynote presentation from Russ LaMotte, Managing Principal of Beveridge Diamond, and a recognized expert on EHS issues in the electronics industry. Member companies representing equipment, materials, facilities and devices will then each share their EHS concerns. Finally, working groups will address industry EHS challenges and gaps. Outputs from the working group meetings will form the basis for the future SEMI EHS program. The EHS issues SEMI’s program and company volunteers are addressing include: PFOA – Government efforts to eliminate pefluoro-octanoic acid and related compounds and salts (collectively known as PFOA) from company supply chains REACH – A European Union regulation to strengthen protections against chemical risks to human health and the environment. Other countries – Japan, Korea, Taiwan – have enacted similar regulations. Stockholm Convention – An international environmental treaty designed to eliminate or restrict the production and use of persistent organic pollutants (POPs) Waste Framework Directive Database – The European Commission and the European Chemicals Agency (ECHA) are building a database where all suppliers will be required to register certain articles. Other groups are dealing with country-specific aspects of the Restriction of Hazardous Substances (RoHS) and the Toxic Substances Control Act (TSCA). Complementing our advocacy efforts, SEMI has established 25 primary EHS standards with SEMI S2 (Safety) as the cornerstone. The S2 family of SEMI Standards acts as performance-based EHS considerations for semiconductor manufacturing equipment and has also been adopted by adjacent industries. Sign up for the November 29th SEMI EHS Summit today Team up with your SEMI colleagues to collectively formulate the semiconductor manufacturing industry’s EHS program. SEMI members can register for the November 29th SEMI EHS Summit by clicking here. If you cannot make this meeting but wish to be added to SEMI’s regular communication on EHS and Advocacy issues, please click here and choose Advocacy from the list of topic choices. Michael Ciesinski is vice president of the FlexTech Alliance, a SEMI Strategic Association Partner chartered with building up infrastructure for flexible electronics manufacturing.