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SEMI Uncovers Concerns Over EPA Self-Declaration Requirement to Share Chemicals Risk-Assessment Costs

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.

EHS PQThe 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 Environmental, Health, Safety and Sustainability at SEMI.

Topics: EHS , Environment, Health and Safety , EPA , TSCA , manufacturing chemicals , U.S. Toxic Substances Control Act , SEMI EPA TSCA working group , Environmental Protection Agency , self-declare




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