THE RECYCLED
AC I L I T y
-EPA/742/F-95/016
Reinventing Government
Through Common Sense and Design
By Christopher Rhodes
EPA'sComuSeia
InitiatinaadttulPC-
lonnmtttfinaii
promet helf fir M
ttiemrinmot
Steve Bold. Continent* '
Circuits (standing) led one
ol tilt two DFE wit terns
itthtOFE muting last
Septtmter.
Lee Wilmot (right) of Hadca.
Chair of IK's Eimmentil
Siibcsmiiiittss,
Cauldron Company, new part
of this writ tttm.
EPA and Musty lodes a
ttit first OK tick-off mtetof
included (tit to right): .
Industries John Lett
OuPwtlitofPtfot.
sndGng Pitts, UCC.
Saving the environment requires hard work.
Saving the environment while keeping the
PWB industry competitive requires ingenuity
and hard work. • '
Fortunately,.a group of committed industry, represen-
tatives and IPC members, public interest groups, and
government employees are ingenious enough to figure
out how to do both and they are willing to do the work.
They are willing to do die work, but the rules won't let
them. Environmental regulations often hinder innova-
tive approaches. So first, we need to change the rules.
Then we need to supply the right tools to do the job.
Changing the rules so we
PWB industry is, fortunate to be one. of the main CS
industry subsectors.
By now, you've probably heard the three words nios
commonly associated with CSI: cleaner, cheaper
smarter. In announcing the ^CSI program, EPf
Administrator Carol Browner stated that, "All too often
we've seen too little environmental protection at toe,
high a price." PWB manufacturers wouldn't argue witr
that Through the CSI, "Government officials at all lev
els, environmentalists, and industry leaders will com*
together w create industry by industry strategies that wiL
work cleaner, cheaper and smarter to protect public
health and our national resources." In short
Administrator Browner is proposing that EPA stop
telling industry how to meet environmental goals, and
start giving industry freedom to meet mutually agreed
upon environmental goals in whatever way industry
thinks best
In July 1994, die electronics interconnection industry,
including PWB manufecturing and electronic assembly,
was selected to participate in the CSI as a subsector with-
-------
in die electronics industry sector. Cathode ray
tubes and semiconductors are the other two
industry, subsectors besides electronic inter-
connections.
The six stated goals for CSI are as follows:.
1. Regulations. Improve existing rules as well as
future rule-making procedures through
greater cooperation and coordination.
2. Pollution Prevention. Promote pollution pre^
vention and other voluntary, environmentally
sound practices.
3. Reporting. Simplify and improve the effec-
tiveness of recordkeeping and reporting
requirements.
4. Compliance. Undertake compli-
ance and enforcement initiatives
to provide greater predictability,
better information, better com-
pliance assistance and greater
overall compliance.
5. Permitting. Streamline permit-
ting procedures.
6. Environmental Technology.
Promote innovative environmen-
tal technologies.
Before the CSI work teams can move ahead
on these and other issues, however, the EPA
must complete its task of appointing the
Common Sense Initiative Council or CSIC
(pronounced "seasick") ,• the governing bodv
for this initiative, as well as the various indus-
try sector steering committees. This should be
completed early this year so that everyone can
get down to work.
While the Common Sense Initiative is focus-
ing on changing the rules to encourage tech-
nology innovation and new approaches, the
IPC-EPA Design for the Environment (DFE)
PVVB it Assembly Program is concentrating on
Following industry sector selec-
tion, the first broad CSI electron-
ics sector stakeholder meeting
was held in Virginia on
September 26-28, 1994. IPC
members Steve Bold (Continen-
tal Circuits), Russ Tremblay
(M/A-COM) and Lee Wilmot
(Hadco) represented indepen-
dent PVVB and contract assembly
companies at this meeting. They
were joined by other IPC OEM
members as well as IPC stafit As
a result of this meeting, specific
regulatory issues or problems
were identified along with poso-
ble solutions or approaches.
Each industry subsector developed its own fist
and then worked to combine common topics.
Top priorities picked by the electronic inter-
connection industry include the following:
• Definition of solid/hazardous waste (cate-
gorical problems such as photoresist skins,
"derived-from rule," de-listing barriers);
• Regulatory barriers to pollution, prevention
(restrictions regarding on-site regeneration,
• conflicts between CAA, CWA and RCRA);
• Extensive reporting burdens (multiple
emergency response notification, duplicative
. genera] emissions reporting requirements,
lack of electronic reporting);
* Small business compliance problems (track-
ing, interpreting and applying regulations,
lack of compliance assistance);
• Permitting barriers (too stow, too inflexible,
conflicting rules, and inadequate de minimis
and permit-out options).
Never tell people
how to do things.
<>
Tell them what
YOU want them to
achieve and they \vill
surprise you with
their imiemiitv.
(-I \ik\i (.IOK<;I S. PviION
identifying new technologies and materials
that can be implemented as the rules are
changed to allow it These will be new tools
that we on use to build circuit boards in bet-
ter wayt.
The IPC-EPA Design for die Environment
(DFE) PVVB & Assembly Project was started in
May 1994 at die IPC Printed Circuits
Conference and Exposition. The overall goal
of this DFE project is to identify and evaluate
alternative chemicals and technologies that
can replace traditional PVVB processes, and
men d'«cm"m* the results of that evaluation
to the industry through a Cleaner
Technologies Substitutes Assessment (CTSA)
document and other means. DuPont's Dr.
John Lott is chairing this project with consid-
erable help from other IPC members includ-
ing: Michael Kerr of Crcuii Center. Tim Scott
of ADCj Robin Sellers of EMPF: and Greg
Pitts of MCC. -
There are seven major steps in this DFE pro-
ject
1. Identify use clusters
2. Score use clusters
3. Evaluate high score clusters for CTSA
4. CTSA identifies and evaluates alternatives
5. Disseminate results to industry and public
6. Implement options
7. Evaluate results of options
In DFE parlance, a "use cluster" is a set of
chemicals, processes and technologies that
can substitute for one anodier to perform a
specific function. For example,
at a working -meeting in
Washington on September 7-8,
1994, more than 50 industry rep-
resenatives, EPA.personnel and
other parties selected four priori-
ty process steps or use clusters for
further DFE assessment: innerlay-
er etching-, outerlayer etching
and plating; making holes con-
ductive; and HASL
A number of industry repre-
sentatives have already voluntari-
ly submitted chemical use data
for these four use dusters, and
the EPA is now completing use
duster scoring in order to rank
each duster for potential human
health or environmental adverse
effects. Af the same time, IPC is
developing the industry profile
document while MCC is working
on the use cluster profile.
The next step will be to select a
use duster for full CTSA evalua-
tion, and begin that work. An
industry-wide DFE meeting is
scheduled for May 4,1995, at die
IPC Printed Circuits Conference
• and Exposition, in San Diego,
Calif. Participants will be reviewing the indus-
try profile and use cluster profile documents,
as well as continuing work on die CTSA,
IPC welcomes support from any interested
party on these important project*. If you
would like more information or want to
get involved, please contact either John
Robison of die EPA CSI snff (202/260.3590),
Debbie Boger of the EPA DFE staff (202/260-
0880) or Sor Summer-field at IPC (708/677-
. 2850. cxt. 347; fax 708/6774570; e-mail
summsi@ipchq.comf.
By working together, who knows what we
might accomplish? C .
a CKume/fauKwis»
------- |