IPC: New EPA Proposal for “High Priority” Chemicals


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The U.S. Environmental Protection Agency (EPA) proposes to designate 20 chemical substances as High-Priority Substances for upcoming risk evaluations. Several of the proposed chemicals are relevant to the manufacture or production of electronics: phthalates, flame retardants, and formaldehyde. The EPA is asking for comments on the proposed designations by November 21, 2019 and IPC will work with you to coordinate comments from the electronics industry and to represent the electronics industry in briefings with members of the TSCA office in Washington, D.C.

The table below lists the proposed candidates for High-Priority Substances. Highlighted text indicates that the EPA has identified uses that may be relevant to the electronics sector. If your company manufactures (including imports), processes, distributes, uses, or disposes of any of these chemical substances, then you will want to consider providing information regarding the chemical’s conditions of use. The EPA will use this information to determine whether the proposed designation as a High-Priority Substance is appropriate.

Please consider the following questions when determining 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?
  • What function does the chemical perform in the process or the product?
  • What is the chemical’s criticality to the process and the product?
  • How would you describe the scenario of use for the chemical substance including potential human or environmental exposure?

The proposed designation of the chemical substances as a High-Priority Substance is not a finding of unreasonable risk, rather this designation will initiate a risk evaluation for the chemical substance. The risk evaluation will determine whether the chemical presents an unreasonable risk to health or the environment under the conditions of use. Risk evaluations will inform risk management actions that impose restrictions on the chemical. We will have opportunities to engage with the EPA at several points during any future risk evaluations, but early engagement and frequent knowledge-sharing with the policy makers will enable development of policies that accurately reflect the uses of these chemicals.

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