Toxic Substances Control Act (TSCA): Current Events Heighten Awareness for Semiconductor Industry

Bade, Renee*; Pawsat, Sally
(RSB Technical Services, Inc., Georgetown, TX)

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The Toxic Substances Control Act (TSCA) regulates any entity that manages chemicals including manufacturing, importing, exporting, processing, distributing, and using. The semiconductor industry is a key part of the regulated community and TSCA non-compliance can result in significant impacts to business operations. Until recently, however, the semiconductor industry deemed TSCA to be primarily a chemical manufacturing issue. While it is true that the majority of TSCA regulations are focused on chemical manufacturing, TSCA regulations equate importation with manufacture. This distinction became clear for the semiconductor industry on October 18, 2000, when EPA proposed a rule restricting the manufacture/importation of certain perfluoroalkyl sulfonates, collectively known as PFAS. This proposed restriction threatens the development of new technologies as certain PFAS compounds offer unique advantages in the photolithography process. This presentation will give an overview of the TSCA regulation, outline the obligations of the regulated community, and address the key components for assessing TSCA compliance.

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