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IPC - Association Connecting Electronics Industries Letter to Chairman Issa - January 7, 2011

IPC - Association Connecting Electronics Industries Letter to Chairman Issa - January 7, 2011

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Published by CREW
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 companies, trade groups, and research organizations asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 companies, trade groups, and research organizations asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.

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Published by: CREW on Jan 26, 2011
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 January 7, 2011Representative Darrell E. IssaChairman, Committee on Oversight and Government ReformU.S. House of Representatives2157 Rayburn House Office BuildingWashington, D.C. 20515-6143Dear Chairman Issa,IPC
 – 
Association Connecting Electronics Industries thanks you for the opportunity to provideinsight on existing and proposed regulations that have negatively impacted the economy and jobgrowth.We would like to call your attention to three regulations that will have a significant negativeimpact on manufacturers, and therefore warrant oversight:
 
The
Environmental Protection Agency’s
(
EPA’s
) proposed modifications to the
ToxicSubstances Control Act (TSCA) Inventory Update Reporting (IUR) Rule
(EPA
 – 
HQ
 – 
OPPT
 – 
2009
 – 
0187). By requiring all manufacturers that recycle byproducts to reportthose byproducts as new chemicals, the EPA will create burdensome, costly andunnecessary regulatory requirements that penalize manufacturers for doing the right thing- recycling.
 
The
EPA’s reopening of the D
efinition of Solid Waste (DSW) rule
(EPA
 – 
HQ
 – 
RCRA
 – 
2002
 – 
0031). The EPA
’s decision to
reopen the DSW rule, which was finalized inOctober 2008 to lessen regulatory burdens blocking the recycling of secondary materials,would impose significant regulatory burdens on recycling.
 
The
Security and Exchange Commission’s (SEC’s
)
proposed regulations on conflictminerals
(SEC Release No. 34-63547; File No. S7-40-10). The regulations beingdeveloped by the SEC under Section 1502 of the recent Dodd-Frank Wall Street Reformand Consumer Protection Act could impose extremely burdensome reportingrequirements on manufacturers, such as electronics manufacturers, that use tin, gold,tantalum, and tungsten in their products.Our concerns regarding these regulations are detailed below. Additionally, the comments wesubmitted to the respective agencies on these issues are attached for your reference.
 
Representative Darrell E. IssaJanuary 7, 2011Page 2
 About IPC and the Electronic Interconnect Industry
IPC represents all facets of the electronic interconnect industry, including design, printed boardmanufacturing and electronics assembly. Printed boards and electronic assemblies are used in avariety of electronic devices that include computers, cell phones, pacemakers, and sophisticatedmissile defense systems. IPC has 1,795 member companies located in the U.S. which employ anestimated 90,000 people.The U.S. has a competent, competitive and organized electronic interconnect industry. However,an ever increasing number of regulatory burdens placed on companies have resulted in lostbusiness opportunities, lost revenue, lost jobs, and a dramatic consolidation of the industry. Thenumber of U.S. companies in the electronic interconnect industry has been significantly reducedover the past twenty years.In just the printed board industry alone, costly regulatory burdens combined with intense globalcompetition
has resulted in a fifty percent reduction in the number U.S. PCB companiesand associated high-quality U.S. jobs
. The ongoing reduction is troubling since U.S.electronics companies provide much-needed jobs in the U.S. Companies comprising the U.S.electronic interconnect industry need Congressional oversight on regulations impacting theirability to conduct business, remain viable, and keep their staff employed.
 EPA’s
 Proposed Modifications to the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) Rule
We strongly believe that the EPA
’s
proposed modifications to the TSCA IUR rule warrantoversight. We are concerned that EPA has proposed a number of changes to the TSCA IURreporting requirements that are extremely burdensome and provide no clear benefit to the publicor the environment. If finalized as proposed, the rule would subvert Congress
’ original
intent toexempt byproducts from burdensome TSCA reporting requirements. The IUR rule is intended toregulate new chemicals that are produced for a commercial intent/purpose; not byproducts.
EPA’s
absurd interpretation that would render a byproduct a new chemical feedstock undermines
Congress’ in
tent and overreaches beyond
TSCA’s mandate.
If the TSCA IUR rule is finalized asit currently reads, manufacturers that recycle byproducts will be required to submit costly, time-consuming reports that may be useless due to poor data quality. We strongly encourage you to
conduct oversight of EPA’s proposed modifications to the TSCA IUR rule to ensure
manufacturers are not unduly burdened by erroneous reporting requirements.
Additionally, EPA’s proposed modifications to the TSCA IUR rule
raise significant timing anddata quality concerns. The proposed modifications will apply to data collected in 2010, yet EPAhas not finalized the reporting requirements. EPA expects to finalize the rule in May 2011 thatwill require reporting to begin on June 1, 2011, less than a month after the rules are promulgated.This unfeasible short period will leave manufacturers with scant time to gather the required newdata or even understand the complex new reporting requirements. In addition to imposing asignificant and disruptive burden on manufacturers, it is likely that the data quality will be poor
 
Representative Darrell E. IssaJanuary 7, 2011Page 3due to the extremely limited time provided for manufacturers to gather and report data. We hopethat as a result of your oversight, EPA will delay the reporting requirements under the newTSCA IUR guidelines by a minimum of one year to provide a more reasonable timeframe fordata gathering and reporting.
 
 EPA’s
 Re-opening of the Definition of Solid Waste (DSW) Rule
Congress should also conduct oversight on EPA
’s
decision to reopen the DSW rule, a rulefinalized in October 2008, due to Environmental Justice (EJ) concerns raised by environmentalgroups. The DSW rule was published to address multiple court decisions that EPA hadoverreached their authority by regulating recycled secondary materials as hazardous waste. Byde-regulating secondary materials that are legitimately recycled, the DSW rule reducedregulatory burdens on manufacturers recycling secondary materials. Now, in re-opening the ruleto readdress EJ issues that were already adequately addressed, EPA would greatly increase theburden on manufacturers that are recycling secondary materials. We encourage you to conductoversight
on the EPA’s
attempts to undermine the ability of the DSW rule to promote therecycling of secondary materials.
 P
roposed Security and Exchange Commission’s Regulations on Conflict M 
inerals
While IPC supports the underlying goal of Section 1502 of the Dodd-Frank Act, which is toprevent the atrocities occurring in the Democratic Republic of Congo (DRC), we are concernedabout the potential significant effects that the implementation of the regulations may have onU.S. manufacturing industries.We are also concerned that the proposed regulations may cause unnecessary disruptions of theminerals trade, which is vital to the livelihood of the people of the DRC. In order to minimizethese effects, without undermining the underlying legislative goals, IPC has recommended thatthe SEC allow companies the flexibility to develop appropriate due diligence measures,recognize ongoing efforts to improve the transparency of the supply chain, address the need tophase in requirements, and provide the necessary time to implement these measures.It is important that the regulations acknowledge the realities of the situation on the ground in theDRC, the complexities of the international minerals trade, and the broad and diverse globalelectronics supply chain. We encourage your office to work with the SEC in an oversightcapacity to ensure the development of regulations meet legislative intent without undulyburdening U.S. manufacturing.
 
Conclusion
Thank you for the opportunity to identify proposed and existing regulations that will be a burdento industry, job creation and the economy. We believe that the
EPA’s proposed modifications to
the Toxic Substances Control Act Inventory Update Reporting rule,
EPA’s re
-opening of the
Definition of Solid Waste rule, and the SEC’s proposed regulations on conflict m
inerals allwould impose costly and unnecessary regulatory requirements on U.S. manufacturers in

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