IPC Request for Information on Five Persistent, Bioaccumulative, Toxic Chemicals

On March 16, 2021, the U.S. Environmental Protection Agency (EPA) announced a 60-day comment period to collect information from stakeholders on the final risk management rules to reduce exposure to five different persistent, bioaccumulative, and toxic chemicals (PBTs). In addition, the EPA issued a temporary 180-day “No Action Assurance” to ensure enforcement discretion is given regarding prohibitions that were set to take effect on March 8, 2021, on the processing and distribution of phenol, isopropylated phosphate (3:1) – referred to as PIP (3:1) – and articles to which PIP (3:1) has been added.

This request for information aims to bring together industry information on the manufacturing (including import), processing, or distribution of these five PBTs or articles containing these PBTs in the electronics manufacturing supply chain. We are issuing this request to harmonize the response from industry and efficiently consolidate information for submission to the EPA in response to the 60-day comment period. The electronics manufacturing supply chain has an opportunity to collect and provide information to the EPA to ensure the updated final rule provides realistic risk mitigation strategies and timelines to implement these strategies. The specific provisions outlined in the final rule will protect human health and the environment by addressing risks and reducing exposures to PBT chemicals to the extent practicable. Without industry input, the EPA will be unable to create realistic risk management strategies.

All information that is received by IPC as a result of this request will be aggregated and anonymized.

What are the five PBTs being regulated under TSCA?

  • Phenol, isopropylated phosphate (3:1) (PIP (3:1)) (CAS Number 68937-41-7) is used as a flame-retardant, plasticizer, and anti-wear additive or an anti-compressibility additive in hydraulic and lubricating oils, lubricants, greases, and adhesives and sealants. PIP (3:1) remains mostly unregulated by existing global chemical and product regulations and, therefore, companies manufacturing or importing articles have only recently begun the process of identifying PIP (3:1) in their supply chains.
  • Decabromodiphenyl ether (DecaBDE) (CAS Number 1163-19-5) is used as an additive flame retardant in plastic enclosures and is commonly found in wire and cable rubber casings, textiles, building and construction materials, and aerospace and automotive parts.
  • 2,4,6-Tris(tert-butyl)phenol (2,4,6-TTBP) (CAS Number 732-26-3) is commonly found in fuel additives, fuel injector cleaners and oil and lubricants.
  • Hexachlorobutadiene (HCBD) (CAS Number 87-68-3) is used as a solvent in rubber manufacturing and in hydraulic, heat transfer or transformer fluid.
  • Pentachlorothiophenol (PCTP) (CAS Number 133-49-3) is found in rubber products and it is used to make rubber more pliable in industrial uses.

Request for Information

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