- 18 April 2008 -
IPC Urges California Members to Act on Chemicals Initiative

The Association Connecting Electronics Industries (IPC) is urging its California members to contact the California Department of Toxic Substances (DTSC) regarding the state’s "Green Chemistry Initiative." Through its Green Chemistry Initiative, the DTSC plans to establish a new framework for chemicals management, which would have major adverse implications for all types of industries, including the electronics industry.  

More stringent than RoHS, Green Chemistry would ban many chemicals and mandate the use of so-called “safer alternatives,” the IPC said. The DTSC has requested public input on seven questions regarding implementation of California’s Green Chemistry Initiative by April 23, 2008.

IPC asks its members to urge the state of California not to ban specific chemicals without careful consideration of the full environmental, social, and economic impacts. Often substance bans result in unintended environmental consequences. For example, a review of the U.S. Environmental Protection Agency (EPA) Lead-Free Solder project [1] illuminates the environmental trade-offs inherent in material substitutions. The study evaluated the environmental impacts of tin-lead solder versus lead-free alternative solders. 

Because tin-silver-copper solder in electronics requires higher processing temperatures than tin-lead solder, tens of thousands of solder machines worldwide now operate at higher temperatures. The higher operating temperatures required for the manufacture of lead-free electronics has resulted in significantly higher energy usage during manufacturing. The increased energy use associated with manufacturing lead-free electronics was projected by the study to cause greater air pollution, acid rain, stream eutrophication, and global warming impacts than the tin-lead soldered electronics.

The environmental impact of lead-free alternatives is an important factor that was not considered during the European Union’s or State of California’s decisions to restrict the use of lead in electronics based solely on its potential toxicity. The EPA’s study serves as an important reminder that there are environmental trade-offs when substituting one substance with another. A complete application of the precautionary approach would be to examine the potential impacts of likely substitutes prior to instituting a ban of a critical substance.

IPC also urged California to take into account that the U.S. EPA is already engaged in a trilateral agreement between Canada, the U.S., and Mexico to assess and manage chemicals. California would undermine ongoing efforts of the federal government. Under the international agreement, U.S. EPA will screen, prioritize, and assess nearly all chemicals in U.S. commerce.  The EPA will develop hazard characterizations, risk characterizations, and risk-based decisions on how to manage these chemicals.

Background
On April 20, 2007, CalEPA Secretary Linda Adams announced that, in the face of recent attention to green chemistry and chemicals management concepts by other governments and academia, as well as increasing interest by the California legislature (more than 50 bills in 2007 alone), the Governor was implementing the Green Chemistry Initiative. California established a public blog and has been holding stakeholder meetings to receive input on four main green chemistry topics, including:

• A framework to design less toxic products;
• How the state should stimulate green chemistry;
• How to design a strategy that encourages manufacturers to assume greater responsibility for products and processes that involve toxic materials; and
• How to develop policies to avoid toxins in products by accident. 

In January 2008, a report of options for the Green Chemistry Initiative report was delivered to the CalEPA Secretary. A public draft framework is expected to be released in mid-May. On July 1, 2008, a final report is to be made to the Secretary on recommendations for a statewide green chemistry framework. 

The Green Chemistry Initiative is based on the assumption that the presence of certain chemicals, even at extremely low levels, is a de facto risk, and these chemical ingredients should be banned and substituted for other chemicals of allegedly lesser concern.  The philosophy underlying this initiative represents a major shift away from the scientific, risk-based approach that has characterized U.S. chemicals regulation policy to embrace the precautionary approach exemplified by European chemicals regulation in REACH. California’s Green Chemistry Initiative would set a negative precedent for chemicals management reform.  

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[1] U.S. Environmental Protection Agency.  August 2007.  Solders in Electronics:  A Life-Cycle Assessment. Available at: http://epa.gov/dfe/pubs/solder/lca/index.htm.