BANNOCKBURN, IL – Electronics manufacturers that send byproducts and waste for recycling are among the targets of a proposed rule from the EPA published Aug. 13, an industry trade group says.

The rule expands the reporting requirements under the Toxic Substances Control Act Inventory Update Reporting rule that requires manufacturers of chemical substances to report on the manufacturing, importation, processing, and use of those chemical substances.

The EPA estimates it will cost each facility $48,700 and take 792 hours to comply with the proposed rule. The comment period for the proposed rule ends Oct. 12.
In a statement today, IPC urged opposition of the EPA’s regulation of byproducts and waste under TSCA, as well as proposed changes to the reporting requirements.

The EPA says byproducts and waste sent for recycling are subject to IUR rule because they serve a commercial purpose as a feedstock to new products, IPC said.

Under the proposed rule, manufacturers would have to comply with existing TSCA IUR rule requirements for byproducts and waste sent for recycling, and with more burdensome reporting requirements, says IPC.

In the statement, IPC director of environmental programs and government relations Fern Abrams said the EPA rule considers F006 electroplating sludge – a listed hazardous waste under RCRA – as a new chemical if it is recycled.

Specifically, the proposed rule changes the definitions of manufacturer use and commercial use to include EPA’s interpretation that recycled byproducts must be reported under IUR; requires manufacturers to report if the production volume of a chemical substance meets or exceeds the 25,000 lb./yr. threshold during any calendar year since the last principal reporting year; increases mandated reporting to every four years (instead of five); requires more detailed manufacturing data, as well as processing and use data to be reported, and requires additional reporting for a variety of factors, including the number of workers likely to be exposed to the chemical and identifying consumer and commercial categories associated with the chemical substance.

The EPA’s proposed reporting requirements would apply to the 2011 submission reporting of 2010 manufacturing, processing and use information. Manufacturers should be collecting data now to submit next summer, even though the details on what data should be collected have not been communicated, IPC points out.

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