Roundtable – Amended TSCA and the Unanticipated Impacts to the Semiconductor Industry

Laurie Beu, Brooke Tvermoes; Virginia Cook, Bob Leet, Michael Castorano; Greg Sower, Marisa Kreider
(Laurie S. Beu Consulting, IBM, JSR, Intel, Dow, Ramboll Environ Cardno Chemrisk)

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Roundtable – Amended TSCA and the Unanticipated Impacts to the Semiconductor Industry Laurie Beu, Laurie S. Beu Consulting; Brooke Tvermoes, IBM; Virginia Cook, JSR; Michael Castorano, Dow; Bob Leet, Intel; Greg Sower, Ramboll-Environ; Marisa Kreider, Cardno Chemrisk. The Toxic Substances Control Act (TSCA) was originally enacted by Congress in 1976 to ensure the safe use of industrial chemicals within the US. Forty years later, in June 2016, the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) was signed into law significantly changing many aspects of how the US Environmental Protection Agency (EPA) evaluates and manages industrial chemicals within the US. The amended law gives the EPA new authority to obtain toxicity, exposure, and other data necessary to evaluate the potential risks of a given chemical with the intent that the new chemical review process would be more precise and more comprehensive. The risk-based safety standard also requires that at the end of a chemical review, the EPA make an affirmative finding regarding the safety of a chemical; thus, potentially impacting the entire supply chain including downstream entities such as those that process, use, and distribute chemicals and manufacture articles. This mandate, therefore, increases the need for communication and transparency of chemical information along the supply chain such that the safety of a chemical product or material can be accurately assessed. In general, this chemical information can include data on a chemical’s physical and chemical characteristics, toxicity data (both human health and environmental), as well as information pertaining to a chemical product’s use and exposure information (i.e., occupational, consumer, and environmental). Another defining characteristics of TSCA reform that has emerged over this past year is the need to undertake and share responsibilities for chemical safety along the supply chain. For example, EPA has recently been denying low volume exemption requests (LVEs) for a family of chemistries often collectively referred to as onium photo acid generators (PAGs) due to increased concerns regarding the acute and chronic toxicity potential of these compounds and their degradants. To address EPA’s concerns an “onium” PAG consortium has formed which includes both semiconductor manufacturers and photolithography chemical suppliers. The goal of this consortium is to preserve the industries’ ability to continue to safely use and develop iodonium and sulfonium compounds used in photolithography chemistries. This round table session will discuss the new chemical review process under TSCA reform and some of the impacts that it has had on industry this past year. It will also explore the need for increased communication and chemical disclosure throughout the supply chain and how this need was recently addressed through the formation of the consortium.

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