Health and Safety

As the volume of regulations grows across all levels of government, both in the U.S. and abroad, the semiconductor industry is increasingly struggling to keep up with its reporting obligations. Potential consequences include shipments delayed by customs, existing stocks of materials, parts, and components unexpectedly being made obsolete, and disruptions to multiple tiers of the supply chain that persist over time.To minimize the burden of numerous, varied reporting expectations, the SEMI PFAS Transparency Working Group, led by Intel and Tokyo Electron, is working to:Enable standardized communication on the presence of Per- and polyfluoroalkyl substances (PFAS) in chemical formulations, materials, tools, parts, and fab infrastructure to minimize the burden of varied reporting expectations;Enable traceability; andProtect confidential business information. While the initial focus of the effort is on PFAS, the intent of the group is for the methodology to be applicable to other substance reporting requirements.The group will be holding a working session at SEMICON West in Phoenix, Arizona on Wednesday, October 8 from 10:30 a.m.-12:00 noon at the North Building, 200 Level, Room 229A of the Phoenix Convention Center. All segments of the semiconductor manufacturing supply chain are invited to join the meeting and contribute to this critical effort. This session is intended for individuals involved in: Data management and reportingSupply chain managementMajor business continuity planning and crisis managementRisk assessment and mitigationEHS/regulatory complianceSub-supply chain visibility challengesThe PFAS transparency effort will also be introduced during the SEMI EHS Summit and SEMI Global Standards Summit, both scheduled on Tuesday, October 7.For additional resources, download the PFAS Explainer or SEMI PFAS Position Paper. Contact [email protected] for questions or more information about the working group session.James Amano is Senior Director of EHS at SEMI.

The work of the SEMI Environment, Health and Safety (EHS) COVID-19 working group to address industry EHS issues and share best practices has morphed as rapidly as COVID-19 itself as the vaccine rollout continues, inspiring new hope for a return to normal. The group has evolved from mounting crisis responses to urgent issues such as the shortage of masks and sanitization wipes and sprays to helping companies prepare for their employees’ return to the workplace and developing on-site health-screening procedures for employees and visitors to help ensure their safety. Hot SEMI EHS COVID-19 working group topics have included the following as the team continues to meet every other week to stay abreast of COVID-19 developments and their industry impacts. Vaccinations SEMI members have been monitoring the progress of U.S. states and counties in delivering vaccines. So far, no essential workers in the electronics industry have been eligible to be vaccinated. To help gauge the availability of vaccines to essential industry workers, some companies have hired external consultants to monitor the phase-in. The SEMI EHS COVID-19 working group will collect and centralize the information to help members plan for their employees’ return to the workplace. Policy Enforcement At manufacturing sites, some employees reportedly are becoming complacent in following masking and distancing policies, prompting reminder communications from top management for workers to comply until the pandemic is brought to heel. The higher-ups are also encouraging staff to get vaccinated once they are eligible, with some member companies offering workers time off or other incentives for their employees and families to get vaccinated. Contact Tracing Despite the intense focus on contact tracing since the initial COVID-19 outbreak last year and early efforts to track people movement using smartphone applications or wearables, no tracking technology has emerged as the standard for helping to curb the virus’s spread. SEMI members have been testing various technologies ranging from Bluetooth to wearables with wide-band radio waves to track employees while on site. Tracing by wearables has proven inaccurate. Left with no better alternative, the vast majority of SEMI members are performing time-consuming manual contact tracing. OSHA Compliance While OSHA has picked up the pace in issuing new regulations related COVID-19, pandemic-related site inspections have lagged, some SEMI working group members report. In California, CAL/OSHA recently passed a COVID-19 Preparedness Plan that defines the responsibility of employers in preventing workplace outbreaks, offering PPE to workers and conducting frequent testing. The California plan mirrors the CDC recommendations implemented at the onset of the pandemic. To join the SEMI EHS COVID-19 working group, contact our EHS team at [email protected]. Olivier Corvez is senior manager of Environment, Health, Safety and Sustainability at SEMI.

Olivier Corvez, senior manager of Environment, Health, Safety and Sustainability at SEMI, sat down (virtually) with Todd Patterson, vice president of global EHS for Entegris Global Operations, to discuss how Entegris has responded to the global pandemic.Corvez manages and Patterson participates in the COVID-19 EHS Task Force currently meeting weekly to discuss industry response and share best practices. SEMI: Was Entegris prepared for the COVID-19 pandemic? How did the company respond?Patterson: Entegris has a strong risk management framework and a risk assessment team of senior leaders who meet at least once a quarter. This focus gives us early visibility into events that could destabilize our organization or threaten our operations. Such a framework helps ensure we have the information necessary to act as soon as possible when the need arises. However, our business continuity plans for a pandemic of this scale were far less than with other more commonly occurring catastrophic events such as earthquakes or hurricanes. The COVID-19 crisis was clearly unprecedented and as such, the necessary systems and procedures were not in place with the depth and detail needed. Our strong governance structure made it possible for us to hold steady even as the pandemic caused increasing uncertainty and disruption around the world. For example, despite major supply chain shutdowns across many industries, to date, our supply chain and manufacturing operations have only been modestly impacted by COVID-19. Our supply chain team was assessing daily the areas of risk with our suppliers and taking appropriate action as well as preemptive steps to ensure our critical supply lines remained open.Our sales team engaged in regular communications with our customers providing them updates about our Business Continuity Plans and our actions to mitigate the risk to any of their deliveries. In addition, we maintained current information about the continuity of our supply chain on the company’s intranet for the global sales team to access as they engaged with customers. Also, a proactive communication plan was implemented immediately to send weekly video messages from senior executives directly to employees’ emails. It was an effective way to communicate with our global teams, to keep them informed about the status of the company’s operations and maintain a common sense of purpose at a time when many colleagues worked from home. In these weekly messages, we also focused significant attention on the health and safety protocols established to protect our manufacturing and lab employees from the virus.Among the health and safety protocols we implemented immediately as the virus moved across different regions were those related to facility screenings, work-from-home policies, social distancing, self-quarantine requirements, contact tracing, increased disinfecting, and travel restrictions. With approximately 5,300 employees worldwide, we had teams in every region ready to implement these comprehensive protocols. We believe we were among the first companies to implement work-from-home policies and travel restrictions.Temperature screening stations at Entegris facilities in Jangan, Korea (left) and Kulim, Malaysia (right). In addition, our CEO led a COVID-19 Steering Committee comprised of senior executives and managers from operations, human resources and communications. The committee met several times a week during March and April to evaluate and formulate responses to the issues that emerged as the virus spread from region to region. The committee’s work created a strong partnership among senior executives and divisional and functional leaders, and the initial guidelines developed by the committee have formed the backbone of a global playbook to limit the spread of the virus to our other sites around the world.Recently, the committee has changed its focus to more strategic issues such as creating a framework for transitioning remote workers back into our office locations. Meanwhile, local leadership teams at each of our global sites have been empowered to address ongoing tactical issues consistent with our thoroughly documented health and safety protocols.Looking to the future, we are using our experience in responding to COVID-19 to develop a more comprehensive pandemic response plan. We have project teams working on better ways to: measure temperatures of personnel entering our sites facilitate social distancing in the workplace redesign common use areas to reduce the number of high touch points disinfect all spaces thoroughly and regularly, and manage emergency pandemic supplies. SEMI: From the SEMI EHS survey, we noted that all members had a Business Continuity Plan. How effective has it been for deploying resources and adapting quickly and minimizing the crisis? Why or why not? Patterson: Because we have operations in China, Entegris experienced the impact of the virus immediately. We quickly formed two task force teams for our two primary facilities in the region. These teams developed the means for communicating key information to employees and started working on prevention plans to protect employees and comply with local requirements for when operations resumed. They met the challenges head on and found quick solutions. An example was finding an effective way of communicating to the employees for each location. Group chats were established through social media. It was this work that led to their success in getting approvals from local authorities to resume operations. Those plans have laid the groundwork on which our other sites around the world could build their response plans.The effective management of our global supply chain also stands out as a key success of the company’s Business Continuity Plan. Entegris has a highly complex supply chain with approximately 6,500 suppliers and a $850 million annual spend, and we ship work-in-progress and finished goods from over 90 sites globally.As I mentioned earlier, despite the virus crippling supply chains across many industries, Entegris experienced very little disruption to its supply chain. The supply chain team was able to accomplish this despite a 90% reduction in global freight capacity. A key factor in keeping goods flowing to our factories was the intensive work the team had done earlier to develop an in-depth understanding of the company’s top suppliers and to mitigate sourcing risks. They had established alternate sources, balanced the sources geographically, and placed inventory across our supply chain to buffer risk.The team also had integrated statistical modeling into reporting tools, which made it possible to reset safety stocks and logistics lead times quickly as conditions changed. And a supply chain digitalization provided one aligned and integrated view via dashboards, giving the company the ability to respond rapidly and to communicate in real time with our suppliers. We essentially had a virtual war room where we monitored the daily impact of the spread of the virus and could address bottlenecks and other issues immediately.SEMI: What lessons have been learned, so far? How do you see changes in your company’s operations in the future?Patterson: Institutionalizing what we’ve learned has already begun. Whether the measures implemented during the pandemic are temporary or become permanent is still to be determined. Regardless, the learnings need to be documented and available as a playbook for if – or when – the next pandemic occurs.Entegris is already working on a more comprehensive pandemic plan that will be based on five levels of preparedness. Level 0 will cover annual training requirements and management of emergency inventory of pandemic supplies. Level 1 will include early recognition of an outbreak, and then Levels 2-4 will include requirements for when specific response measures are implemented. Entegris also has formed the “New Normal” task force, which consists of leaders representing a number of disciplines directing the project teams previously mentioned to create a more comprehensive pandemic response plan. One of the project teams is working on improving the facility screening process that performs temperature measurement for personnel entering Entegris sites. The team is looking at the best technology to scan body temperature. As to whether this technology is employed only while COVID-19 is still active or becomes a permanent way of doing business, this is still being discussed.SEMI: EHS is involved in both providing technical support to protect individuals but also in making organizational changes to favorize social distancing. Could you explain some of the successes and challenges while tackling these two fronts?Patterson: Very early in the pandemic, Entegris established a work-from-home policy for non-essential employees. This significantly reduced the number of personnel and the potential for contact at the Entegris locations. Significant facility changes also were required. These included the design of facility screening booths and modifications to common gathering areas such as canteens, meeting rooms, prayer rooms, and smoking points. Physical markings were used to designate 2 meters distancing, and the seating in canteens and meeting rooms was reduced and staggered to minimize the risk of exposure to the virus. Entegris also has a project team focused on developing design solutions for offices and workstations when space makes it difficult to maintain 2 meters social distancing. These changes turned out to be essential for some sites in meeting mandates by local authorities. Our sites in Hangzhou, China and Kulim, Malaysia both were allowed to resume partial operations after demonstrating to government authorities the effectiveness of the preventative measures put in place. One particular challenge we are facing is the range of personal differences and awareness levels within the workforce – including those that don’t understand the importance of the new guidelines. We are working closely in advising supervisory staff to be aware of the need for employees to follow all health and safety protocols we have put in place, including social distancing. That preventative measure is the most difficult to make part of our new behavior – it is unnatural and inconsistent with our human nature, but it is critical to preventing the further spread of the virus.SEMI: How do you envision the progressive steps in deescalating to bring back “normal” operations? Patterson: I don’t know whether Entegris will ever go back to the old “normal.” As previously mentioned, we are working on the “New Normal.” Our focus now is on bringing our work-from-home employees back to the workplace without adding risk of exposure to the virus. We are still exploring options, but we expect to do it in a phased approach so that we can adequately assess the preventive measures that are in place and determine whether adjustments need to be made to any of our health and safety protocols.We are starting to see a variety of different frameworks emerge for evaluating repopulation timing and procedures. We will assess them on an office-by-office, or site-by-site basis, utilizing consistent criteria to define the potential for exposure to the virus. This also applies to our field service workforce. However, I have not yet seen any governmental guidance that offers a recommended framework for returning employees to the workplace. I think this represents an opportunity for SEMI EHS and the Standards groups to work to establish that framework for our industry.SEMI: Anything else you would like to share that you have observed throughout this crisis?We have not discussed the challenges faced in procuring and acquiring pandemic supplies. Almost immediately after the outbreak occurred in Wuhan, it became increasingly difficult to find supplies. Even when confirmation was provided by suppliers and delivery dates confirmed, the majority of the dates were pushed out or canceled. We found that what worked best was to have purchasing teams at the local site work with their local contacts on obtaining smaller quantities while a corporate point person was also managing larger orders. In preparation for any future pandemics, Entegris will be maintaining an emergency inventory for masks, sanitizer, thermometers, and disinfectants.For 18 months, Todd Patterson has held the position of VP Global EHS for Entegris Global Operations. His experience with emergency management and BCP has become invaluable in the past three months. He is grateful to his global response teams around the world for coming together to support the Entegris team in this unprecedented situation. Todd is an active participant on the SEMI EHS COVID-19 response teams led by Olivier Corvez at SEMI. Olivier Corvez is senior manager of Environment, Health, Safety and Sustainability at SEMI.

Cameron Burks, head of Global Security, Enterprise Business Resiliency and Health, Environment Safety with Adobe Systems, and a member of the White House Task Force for COVID-19 response, briefed members of SEMI’s IT Leadership (ITL) and Environment, Health Safety (EHS) groups on April 20, 2020, on enterprise resiliency principals specific to the current COVID-19 crisis. Burks has spent over 20 years in the global security, crisis management and business continuity fields for public and private global companies. In the meeting, he noted, “This is all new. No one has had to respond to a crisis of this magnitude and impact. Ever.” On top of all of the learning and responding that teams are doing in real-time, it is helpful to have a strong business continuity plan (BCP). The following is a recap of insights that Burks shared on best practices for business continuity with examples from Adobe’s BCP.The Long-Term Picture: How to Plan for Business ContinuityBurks emphasized that the first step in any crisis is identifying risks and ensuring the safety of all human life. Once human safety is assured, the next part of the plan must form a strong foundation for escalation, operation evaluation and response. A solid foundation also creates the business factors to restart operations efficiently. The foundation of the Adobe pandemic plan was laid during the summer of 2019 while the global team was updating their infectious disease plan and rehearsing with headquarters and regional offices. That plan includes six main sections:1. Crisis Management Plans – escalation, roles and responsibilities, team operations2. Crisis Communication Plans – internal and external stakeholder communications3. Incident Management Plans – site or regional management response4. Emergency Response Plans – immediate local response to events5. Business Recovery Plans – business and facility recovery6. Disaster Recovery Plans – IT and technology recoveryThis format has worked and scaled well over the past few months, and the company is now in the stage of evaluating how to help offices recover and repopulate. Response Team Structure – Global and LocalAlthough it is critical to have plans and leadership coming from headquarters when it comes to a crisis, LOCAL teams are on the front lines since most crises start and evolve quickly. In the planning process, the local teams need to know and be trained on plans for a wide range of incidents and events including: People- and product-related Security – both external and internal Operational (e.g. cyberattacks) Natural disasters Health-related, such as this pandemic The severity of the event will determine the corporate impact and activation of appropriate plans. Low-impact events include those where stability is quickly reached and response plans have effectively contained the incident. High-level events will cause severe disruption for employees and customers and require an efficient and coordinated response. Regardless of the severity level of the event, all response teams need to be prepared to quickly activate and then to thoroughly coordinate on crisis management and communications. It is critical to have established actions to implement based on the severity level of an event. Table 1 provides an example of Key Trigger Levels for implementing specific actions depending on the severity of an event. Table 1 – Key Trigger Levels X = phase to consider first implementing controls The team needs to understand what the staff requires to maintain business continuity. Burks recommended aligning with ISO 22301, the Business Continuity standard. The standard will lead a company to understand what redundancies need to be in place to keep essential operations running. In Adobe’s case, this includes keeping data centers running and providing essential gear to the 90+ members of the response and global security teams. Adobe tests the plans every month and addresses the bugs – every time.Repopulating Business Facilities During COVID-19 While COVID-19 infection and death rates are currently flattening in many locations, there remain a significant number of new infections, limiting the ability to repopulate business facilities without threatening the health of the workforce and their families. Adobe is using multiple indicators to calculate when the virus is contained, the threat is reduced, and employees can return to workplaces. For now, Burks recommended maintaining social distancing as much as possible while keeping operations running. He believes summer may see some abatement due to weather. However, most experts expect to stay hyper-aware and responsive well into 2021.Although Adobe tries to provide actual dates for return to their employees – and did early on with best estimates – they have had to change to a “until further notice” statement. Repopulating is going to be much more complicated than the original decisions to work from home. The Adobe operations team is providing much larger conference rooms, enhanced cleaning regimens, and new norms of interacting at the workplace for everyone. The goal is to bring people back in small groups on a site-by-site basis. The first group will be only 7-10% of the workforce. That group includes the cleaning and facilities crews to support the professional staff, who would return to reap the benefits of a collaborative environment. Many people want to come back to the office. They are suffering in isolation, and productivity is dropping in those cases.Adobe is planning to create a manual on interacting at the workplace and will require training and adherence to new social constructs. Security officers will be “ambassadors,” helping the workforce remember and adhere to the new rules. The company will use footprint stickers to provide visual clues to employees on walking single file and avoiding groups. Stickers will designate desks that can and cannot be used. To provide a more open office plan, they will remove desks and arrange movable white boards to accommodate the collaboration employees want.The situation is complex and dynamic and requires decision-making based on a definitive set of criteria. The following is a summary of information that Burks shared on Adobe’s criteria for returning to work after COVID-19: Indication of health and safety assurance utilizing risk assessment criteria – locally assessed and qualified for a minimum of six weeks. Travel prohibitions and local/external meeting guidelines to be modeled separately utilizing case-by-case risk assessment criteria. Assessment of the case fatality rate, infection peak and downside projections – curve must be flat. Management team decision on how much risk to assume, as this disease is durable Assessment of infection vector and prevalence vis-à-vis relaxation of nonpharmaceutical interventions; assessment of local healthcare capacity Government shelter-in-place restrictions fully (or partially) lifted; declarations by public leaders that the virus has been contained at some level (city, state, country) Assessment of facilities to physically distance employees and/or staggered shift schedule; assessment of security capability/resource availability Assessment of public transportation and infrastructure, including parking garage Assessment of school closures, childcare and/or adult-care Assessment of nonpharmaceutical intervention awareness campaign, medical surveillance program, and/or onsite medical or clinical support No visitor program until approved by global security staff when office repopulation program begins. Create exceptions list. Emergency plans formally in place Site capacity identified; Emergency Response Team (ERT) skeleton crew part of the repopulation Full plan in place to close offices for a period of no less than three weeks if one employee or vendor tested positive for COVID-19 during repopulation exercise; plan includes informing workforce within “return population” of circumstance and having the facilities team execute a deep clean. The plan would then activate communications for the crisis management remediation phase, which includes full workforce transparency via town halls, webinars, emails, etc. Burks noted that contact tracing has moved from an unthinkable invasion of privacy to a likelihood for most workplaces, taking into consideration privacy laws predominant in Europe and U.S. If anyone falls ill or tests positive for the virus, they will automatically be sent home and everyone who has been in contact with them will need to enter a 14-day quarantine before returning. Burks’ presentation, and his thoughtful approach to planning and the current situation with COVID-19, allowed the attendees to consider their positions and paths for bringing their workers back to the offices and facilities. A lively question and answer session enabled members to further clarify points and get immediate feedback on their plans and strategies. Burks finished with a request to industry members to continue the dialogue and send industry data for him to report back to the White House Task Force. For additional resources from SEMI, visit our COVID-19 response website, which provides best practices and the opportunity to submit company stories.About the AuthorHeidi Hoffman is Senior Director of Corporate Marketing for SEMI. She is currently serving on the SEMI COVID-19 Response Team, coordinating multiple inputs from across the industry to assist all SEMI members in responding to the crisis. To submit your company response story, visit our COVID-19 News and Blogs webpage and scroll down to the green submit bar below the news.

Part 2 of 2Read Part 1.While companies navigate the ongoing COVID-19 crisis, corporate leaders should be evaluating a number of key business continuity issues as well as steps they can take to not only react to business disruptions but also reshape their business and recovery plans.We spoke with Dan Steele, Senior Director and the APAC Head of Environmental, Health, Safety, and Security (EHS S) at GLOBALFOUNDRIES (GF) Singapore, via teleconference for insights into the best practices he and his team have implemented from their Business Continuity Plan (BCP) to guide them through the health crisis.SEMI: How can SMEs (small and medium-sized enterprises) afford BCP, as they are often quite costly?Steele: BCP is not something you afford. Rather, it is essential to good management. Every business is about managing risks and every manager’s responsibilities include risk mitigation. Regardless of their size, companies often pay a higher price for survival in a crisis because they are ill-prepared. All companies owe it to themselves, their employees and other stakeholders to conduct ongoing business continuity planning. No one knows what or when the next crisis will be, and no plan is perfect in mitigating crisis impacts.However, it is critical to plan for potentials, institutionalize EHS and security best practices, ensure the supply chain has both redundancy and robustness, train employees to adopt additional skills, and work with customers in advance. Companies that continue to ask themselves what if are the ones that will be the best prepared. And, if BCP is done right, businesses can avoid huge losses. Dwight Eisenhower said, "Planning is everything, the plan is nothing." I think too many companies spend far too much time creating exacting plans when instead they should be planning. Since planning the survival of the company is every manager’s daily responsibility, BCP should not be purely looked upon as a cost, but also as an expected deliverable from the management team.SEMI: Companies have rolled out mandatory work-from-home (WFH) policies and it has become a new normal for many of us. What other measures can GF take should this WFH period be extended?Steele: Our work-from-home policy seems to be working quite well at this point. However, WFH will only be effective if the right tools are provided to employees – we give our employees access to our system so they can work remotely. WFH also offers opportunities to drive new and innovative ways of working, and accelerates some of our automation efforts such as Augmented Reality (AR).At the same time, mental health is just as important and we conduct weekly check-ins with employees to assess their anxiety levels by asking two basic questions: How is the team’s morale and has it impacted productivity in our operations? For us at GF, WFH is not a disintegration of the team. It is important to our operations to continue the social aspects of working as ONEGF. That means online meetings should require face-to-face interactions. It is important for people to connect. Additionally, we maintain the same quality expectations for remote work as we do when employees are on-site. If this WFH period is extended, we need supervisors and managers to reach out and ensure that we stay connected with our employees.SEMI: What BCP lessons have you learned during the outbreak and will the learnings change any of your business or operations strategies when normalcy returns?Steele: I am not sure we learned anything new about BCP. As stated, our approach to BCP is to spend less time on exact plans and more time on planning, asking ourselves what if and mentally walking our way through potential solutions. This crisis reinforces the premise that we must be prepared. We did not have a plan on our shelf for working-from-home, but we had visualized it, knew what we would have to enact and now have employees managing highly sophisticated, technical and skilled manufacturing operations from home, and some of them reside in Malaysia. BCP must be a conscientious, concerted effort even when normalcy returns – it helps us better prepare. Additionally, BCP is not the responsibility of a single person or department. Just like our daily business, BCP is an integrated effort across many functions. Good and great ideas come from anywhere in a time of crisis. Listening is extremely important.SEMI: If there is one takeaway from this unusual and uncalled experience, what will it be?Steele: What we walk away with is the fact that we are dealing with a pandemic that is highly unpredictable, and that we need all types of employees with diverse backgrounds, experiences and perspectives. This inclusion has made us successful all along, and that is what is helping us ride through this crisis today and into tomorrow. We are glad that we have a diverse and proactive BCCM team that is able to quickly adapt and respond to the many challenges of a crisis. SEMI: What advice would you offer to stay productive while WFH?Steele: We acknowledged that it is difficult for the WFH policy to be effective in the manufacturing sector. Although we do not see any productivity loss thanks to automation, we’ve seen a slowdown in our engineering activities.My advice: First stay healthy, monitor your health, and follow the government’s hygiene advice for yourself, your families and the communities you live in. If you socialized before, there is no reason to stop. Stay connected with your co-workers and team. Personally, I don’t believe WFH now means you are always on. Just as you did when working on-site, you still need your personal time. You have to strike the balance that works best for you.Dan Steele has over 25 years of experience in environmental, health, safety and security operations. He has also held other leadership roles in facilities engineering, quality, reliability and assurance, and risk management.Bee Bee Ng is president of SEMI Southeast Asia.

This article is the fourth in a series highlighting the vital importance of SEMI Standards to commemorate the publication of the 1000th SEMI Standard in July 2019. Find the entire series here.Computer prices have plunged over the years even as desktop and laptop PC performance has skyrocketed thanks to the semiconductor industry, giving users much more bang for their buck. The chip industry stands in a stark contrast to healthcare and education with their exponentially rising costs.What distinguishes the semiconductor industry from healthcare and education in the capacity to deliver so much for so much less over time? After all, even in other parts of the technology sector that are heavily regulated, such as cable television, we have not witnessed the same price decreases as in microelectronics.Some pundits claim that the difference among sectors is tied to their degree of regulation. Does greater regulation somehow degrade product value? The reality is far more nuanced. But one thing is clear: Smart self-regulation (i.e. standards) in the semiconductor industry has contributed mightily to its success.The recipe for success has been simple. Standards have been rocket fuel for competition, which in turn has sparked innovation, driving down device prices while boosting performance. Computer prices fell dramatically between 1997-2015 while the cost of cable TV and internet services rose. Myth of unregulated competitionA semiconductor fab might actually be the most regulated place on earth. Fabs hew to a much higher standard of air quality and cleanliness than even uber-sterile hospital operating rooms. Manufacturing processes are voluntarily regulated not to millimeters, but to nanometers. While some standards are proprietary with limited reach, others span the supply chain. Regulation has worked so well in this sector that the semiconductor industry isn’t moving toward less standardization. It’s moving toward more. Secret is smart standards The gap between regulation and self-regulation is more like a chasm. We typically view regulation as a series of top-down directives that more often focus on the interests of the producer than the consumer. Healthcare regulation, for example, may improve quality of care, but it’s often insurers, big pharma and hospitals that benefit most from regulation, rather than consumers.The semiconductor industry, on the other hand, uses self-regulation to improve business operations and make better products for consumers. Falling prices and rising performance are natural byproducts.Semiconductor industry self-regulation is an ecosystem-wide effort, where input isn’t just top-down, but also bottom-up or even side-to-side. The first SEMI Standard, which specified wafer sizes, exemplifies this approach.The SEMI Standards Committee formed in 1973 to address silicon wafer dimensional specifications. At the time, wafer specifications proliferated. Numbering more than 2,000, the various specifications led to major inefficiencies just when the industry was just getting underway. Wafer suppliers banded together under SEMI to solve this problem and rapidly developed consensus specifications for 2- and 3-inch wafers. By the mid-1970s, over 80% of wafers conformed to these new standards.Standardized wafer sizes freed equipment companies to focus on innovations that reduced cost and increased performance. It also allowed manufacturers to focus on product differentiation without having to worry about device fabrication process and cost. Since that first SEMI Standard made possible the modern semiconductor equipment industry, original equipment manufacturers (OEMs) have competed to deliver amazing innovations. For example, lithography systems routinely use light to design chips with feature sizes smaller than the wavelength of light.SEMI’s 1000th standard on energetic materials demonstrates how smart standards are also pragmatic. This standard is not about banning materials or assigning blame when things go awry. It is about creating practical guidelines that companies will follow, enabling them to realize greater innovation. Guidelines that reduce accidents and risks will spur more, not less, energetic materials’ exploration. Industry suppliers will be the big winners.The 1st to the 1000th SEMI standard all represent examples of cooperation making more sense than competition.Standards for the real worldCreating a business-friendly standard that still gets the job done is a process. As SEMI Standards Task Force and Committee members, materials, equipment and manufacturing companies take part in defining best practice guidelines that support safe and practical use of materials and equipment. Task force and committee members assign particular responsibilities and associated costs to the most logical segments of the supply chain. They also develop information-sharing practices around competitive process recipes and purity standards.Andy McIntyre, CIH, a member of the energetic materials task force and an executive vice president and managing principal at BSI EHS Services and Solutions, summarized what makes SEMI standards smart.“SEMI standards are pragmatic,” said McIntyre. “They take into account the need for implementation in a real-world business environment. They embrace an engineering approach to problem-solving to create practical solutions, and they define specifications and performance goals in ways that allow engineers — in collaboration with EHS professionals — to identify practical solutions for reducing risk in R D, pilot line and manufacturing operations.“SEMI standards employ a holistic process that considers all the important points of view throughout the supply chain, from materials selection, installation, use, recycling and/or disposal,” said McIntyre. “The breadth of SEMI EHS Guidelines, for example, is also very comprehensive as the SEMI EHS Committee and task forces work to ensure that standards keep pace with dynamic technology developments. Energetic materials is a prime example where the industry recognized the need for a new safety guideline to document safe usage of pyrophoric, water-reactive and unstable reactive materials, which have become increasingly important in semiconductor and advanced materials R D and manufacturing.”This is the real secret to the success of the semiconductor industry. Smart self-regulation allows industry players to cooperate in the development and implementation of standards that are pragmatic, comprehensive and dynamic. Participants in SEMI Standards have a voice in the semiconductor industry because they are the voice of the semiconductor industry.While innovation in semiconductors may not always keep pace with Moore’s Law, we can depend on one truth: As long as collaboration and cooperation are the rule and not the exception, we will continue to advance technology in amazing and unprecedented ways. You, me and all other consumers will continue to reap the rewards of innovation. Use your voice to affect standardization in and around the semiconductor industry. Learn about SEMI Standards – and become part of the solution.Heidi Hoffman is senior director of technology communities marketing at SEMI. Hoffman and her team shine a spotlight on the work of the more than 20 technology communities under the SEMI electronics manufacturing supply chain collaboration platform. Actively engaging community members in marketing programs that showcase their unique value, Hoffman’s team helps companies to grow and prosper through the power of connection, collaboration and innovation.

IntroductionStarting July 4, 2022, PFOA (Perfluorooctanoic acid) levels in semiconductor manufacturing and related equipment (SMRE), including replacement parts, entering the European Union (EU) will be restricted to 25 ppb per component (or any part thereof). Semiconductor equipment components (and the parts thereof) of particular concern include fluid tubing and fittings, pipe/seal tape, wire and cable insulation, filters, valves, tanks, panels, reaction vessels and o-rings; if they are made from fluoropolymers or fluoroelastomers.When PFOA is used as an aid to the manufacture fluoropolymers such as PTFE, PFA, PVDF or fluoroelastomers such as FKM and FFKM (collectively referred to as fluoromaterials), an unintended PFOA residue can be trapped within the fluoromaterial. Buyers of components used in SMRE are usually unaware of the processing method used for any fluoromaterials they may contain, and, as a consequence, the potential for PFOA residue. This lack of information about potential PFOA residues could result in regulatory enforcement actions and restricted market access, particularly in the EU.The impact of restrictions on fluoromaterials used in SMRE has been introduced in previous SEMI articles ‘Fluorinated Compound Restrictions May Trigger Costly Equipment Changes’ and ‘Fluorinated Substance Restrictions Triggers Costly Equipment Changes.’PFOA and its related compounds, such as the ammonium salt APFO (collectively called PFOA in this article), are recognized internationally as hazardous chemicals and are now targeted for regulatory restriction in the U.S., Taiwan, Canada and the EU. The UN Stockholm Convention on Persistent Organic Pollutants (POPs) is also considering listing PFOA, which could lead to additional international restrictions.The SEMI EHS Division PFOA Compliance Working Group has been working to understand: The likelihood of PFOA residue entering the supply chain of new components The residual level of PFOA in fluoromaterials produced prior to the phase out of PFOA by some manufacturers The impact of PFOA residue on the secondary equipment market This SEMI resource page, ‘Elimination of PFOA from the Equipment Supply Chain,’ and the supporting FAQ contain the Working Group’s key findings and conclusions.PFOA in the Fluoromaterial Supply ChainSignatories to the U.S. EPA Stewardship Program, which include FluoroCouncil members, eliminated PFOA from their manufacturing processes by 2013. However, other fluoromaterial manufactures – particularly in China, Russia and India – might still use PFOA and pose a significant risk to the worldwide supply chain.China, the world’s largest fluoromaterial producer, accounts for 53 percent of global production of PTFE and 38 percent of worldwide production of PVDF, FEP and FKM. An estimated 75 percent to 85 percent of fluoromaterials are manufactured using PFOA in China. Fully 25 percent of these fluoromaterials are exported, primarily to the U.S, Japan, EU and India. What’s more, finished goods made from or containing fluoromaterials that might be used as components in SMRE are exported from China.Documentation that traces fluoromaterials through the supply chain back to the original fluoromaterial manufacturer is key to meeting the PFOA regulatory requirements. This traceability can be straightforward in cases when an SMRE manufacturer directly specifies the use of a fluoromaterial in a custom-fabricated fluoromaterial component. However, for off-the-shelf components (e.g., cable ties, wiring insulation, tubing) or the components assembled from these components (e.g., controllers), the complexity and dynamics of the supply chain makes traceability back to the original fluoromaterial producer almost impossible.Residual PFOA Levels If, or how much, PFOA/APFO residue is contained in a fluoromaterial depends on the manufacturing process. Details of the manufacturing processes are proprietary and vary widely. Post manufacturing thermal treatments, such as sintering, extrusion, and molding, can result in the rapid thermal decomposition of APFO above 250C, but PFOA is significantly more stable. The temperature and time of thermal treatments is also proprietary and varies depending on the type of fluoromaterial and what is being made.This variability makes it impossible to estimate the likely level of trapped PFOA or APFO in a finished component or a part thereof. It is unwise to use data on the level of residue made known for one case to extrapolate the level of residue across the fluoromaterial industry. However, an industry-wide range on the order of 1ppm-10ppm (nearly 1000 times the EU limit) is suspected. Testing for the presence of PFOA/APFO at 25ppb in components is also problematic as there is no standard test method, and results among the custom methods developed in each test lab may vary.Given this uncertainty in test methods, a system of supplier declarations warrants consideration.Impact on Secondary (Used) EquipmentThe EU REACH restrictions apply to SMRE and replacement parts placed on the market at any time (not just initial placement – known as “first placing on the market”). For fluoromaterial components manufactured prior to 2013, there is a higher likelihood of residual PFOA/APFO levels exceeding the 25ppb limit of EU REACH. In principle all the SMRE components containing fluoromaterials should be investigated, and those containing PFOA above 25ppb must be replaced before the SMRE can be legally placed again on the EU market. Companies (e.g., semiconductor manufacturers) in the EU who wish to sell used equipment within the EU will be required to demonstrate the used equipment is in compliance. Selling older used equipment would likely be unprofitable after necessary investigations and component replacements are completed.Next StepsWhile the EU semiconductor manufacturing industry heavily depends on the secondary (used) equipment market, EU regulators may be unaware of the PFOA restriction’s damaging impact to this market. The EHS Division PFOA Working Group, in conjunction with SEMI Europe, is now considering how to bring this concern to the attention of regulators and to collaborate and lobby for effective changes including possible modifications to the EU Persistent Organic Pollutants (POPs) regulation.