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.
Proposed Modifications to the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) Rule
We strongly believe that the EPA
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
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.
absurd interpretation that would render a byproduct a new chemical feedstock undermines
tent and overreaches beyond
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