EPA and Industry
Design    for
A partnership'far a cleaner future.
Katherine M. Han, Deborah L. Boger, and Michael A. Kerr

           APCB shop's  ability to .react to complex
          environmental rules, regulations, and regu-
          latory costs can mean the difference between
success and  failure. To this  end,  companies in  all
industrial sectors are responding to current and future
environmental considerations and potential tort liability
by identifying opportunities to prevent pollution (e.g.,
eliminating the generation of hazardous waste) and by
using safer materials and technologies. Past methods of
addressing environmental problems, largely by control-
ling  pollution through  end-of-pipe  approaches, have
proven to be  expensive and  less effective.  Today's
successful companies are  finding that pollution preven-
tion  often results in substantial cdst savings and th'at
performance, productivity, and even marketability are
often enhanced by  adopting environmentally  friendly
processes and technologies and considering DfE.
                           f ,    -
What Is DfE?
     Design for the  environment  (DfE);. is most com-
monly viewed as an adaptation of the design  for "X"
concept, where "X" represents a'desired product charac-
teristic (e.g., safety, durability) integrated as a process-
goal. In DfE initiatives, cost and performance as well as
environmental considerations are an integral part of the
design or redesign of the  product.
     The evolution of the pollution prevention-philos-
ophy caused many companies to "design for the environ-
ment" by directing their environmental efforts earlier in
the production cycle, from clean-up and control technol-
ogies to better management to product  redesign. Deci-
sions made at the design  or  redesign  stage  affect  a
product's impact on worker and  consumer safety, the
risks and releases to human health and the environment.
and  the characteristics of the product's waste streams.

16 Printed Circuit Fabrication   •              •
The EPA's DfE Program
    The EPA's DfE program builds on the industry^
pioneered DfE concept by striving -to help  businesses
incorporate environmental considerations in all aspects
of plant operation. One way in which the EPA accom-
plishes this goal is through voluntary partnerships with
particular industry sectors in developing.the information
and tools needed to' make environmentally  informed
choices. The'EPA's  DfE program also includes broad
institutional projects aimed at changing general business
practices, which include:
  • working with the private sector to develop "account-.
    'ing tools that incorporate environmental costs and
  , benefits into .accounting  and capital  budgeting
    practices (total cost accounting)
  .• working with the National Science Foundation to
    encourage academic research into alternative meth-
    ods for producing chemicals that reduce or elimi-
 ,   nate the use or generation of toxic substances (the
    Benign by Design program)'
  • working with the insurance industry to  encourage
    , the incorporation of pollution prevention principles
    in the underwriting and risk management decision-.
    making process
'  • working with  the financial community to facili-,
    tate companies in financing pollution prevention
    initiatives     ,
  • establishing a National Pollution Prevention Cen-
    ter at the University of Michigan where curricula
    are being developed  that incorporate  pollution
    prevention, lifecycle  analysis, and DfE principles
    into a variety  of disciplines, including business,
    engineering, accounting, and marketing.
     In DfE projects with businesses, trade associations/
and stakeholders in specific industry segments, the EPA

helps the industry gather and develop the information
and tools necessary to evaluate available or emerging
alternative chemicals, processes,  and technologies. It
does this by taking advantage of the EPA's risk manage-
ment methods and expertise. The DfE program can also
provide Other  incentives  for  industry participation,
including funding to develop and analyze critical infor-
mation for individual companies and the .general public
regarding environmentally beneficial alternatives.
     The  DfE  program  is currently  working  with
stakeholders  in the  PCB  fabrication and  assembly
industries. The project's goals  are consistent with the
work underway in the EPA's Common Sense Initiative
 iCSn.  a program in which EPA has brought together
Stakeholders  in several  other  industries  to  identify
opportunities for achieving cleaner, cheaper, and smarter
environmental protection in six major areas: current and
 tuture environmental regulations, requirements report-
 ing, environmental  compliance,  permitting,  pollution
 prevention, and environmental technology.

 Project Purpose
      In April 1993. the research consortium Microelec-
 tronics and Computer Technology Corporation (MCC)
 spearheaded a study entitled "Life Cycle Assessment of a
 Computer Workstation." In this ground-breaking study,
 the EPA, the U.S. Department of Energy,  and industry
 partners such as SEMATECH found that the production
 ut PCBs accounts for 79% of the energy used, 95% of the
 water  used,  and 95% of the hazardous waste associated
 with  computer manufacturing. The potential for im-
 provement in these areas led the EPA's DfE program to
 include environmental and public interest groups in its
 working partnership with the  printed  circuit  board
 industry.                                      '  •
     As the underlying- link between  semiconductors.
computer chips, and other electronic circuitry, PCBs are
an irreplaceable part of many high-tech products. In the
rapidly changing PCB industry, opportunities abound to
integrate environmental objectives into  emerging pro-
duction processes and  technologies.  However,  many
manufacturers are small businesses who are unable  to
invest in expensive environmental analyses and process
redesign. To facilitate the evaluation and implementa-
tion of affordable and environmentally beneficial alter-
natives, the EPA entered into a DfE programpartnership
to provide  assistance to the entire PCB industry.
     One short-term goal  is to generate interest and
participation in the DfE PCB project and to disseminate
information on viable pollution prevention ideas that the
industry can  implement immediately. Over  the long
term, the project seeks to  effect behavioral change to
improve the competitiveness and environmental perfor-
mance of PCB manufacturers. To reach these goals, the
DfE Project Team will:
  .• evaluate and  develop technical information  on
     pollution prevention technologies that reduce com-
     pliance costs, environmental releases,  risks to hu-
     man health, and chemical and natural resource use
   • develop industry -and regulatory profiles that identic
     fy barriers to pollution prevention .
   • facilitate technology transfer among PCB compan-
    •  ies to avoid duplication of effort and cultivate  the
      use of alternatives.
      Successfully accomplishing these project tasks will
 help to increase the international competitiveness of the
 industry through enhanced efficiency and streamlined
 operations—two common by-products of  pollution

 Subject Areas
      DfE's  work  with, the PCB  industry  and other
 stakeholders is .conducted  within three project  areas—
.- technical studies, communication efforts, and implemen-
 tation activities.
      Technical Studies. In  late 1994, the  DfE Tech-
 nical Workgroup mapped out the major steps in PCB
 fabrication  and chose four .major functional arero fcr
 further  evaluation, each  of  which includes  several
 process steps. The Workgroup  then identified the chemi-
 cals used in existing and emerging process alternatives
 for each of  the functional  areas  and  conducted a
  preliminary assessment of environmental  and  human
  health risks associated with each area.
       The DfE Project Team selected the functional area
  of making holes conductive (PTH) for detailed analysis in
  a Cleaner Technologies Substitutes Assessment  (CTSA)
  to be conducted by the EPA and the University of
'  Tennessee's  Center for  Clean  Products  and Clean
  Technologies. A CTSA contains information not only
  about the environmental impacts (e.g., releases to the
                                 Vol. 18, No. 4 April 1995 17

 ERA. and Industry
                                                                                  Environmental resources
                                           Selection of process step
                                                                                     Human health risks
      Environmental risks
                                                                                    Pollution prevention
                                                                                          survey  '
                                          ed decision by PWB manufacturers
Information and tools that contribute to environmentally informed choices.
environment, hazardous waste generation,  water and
energy  use,  and comparative risk)  of  existing and
emerging alternatives but also examines; their cost and
performance. As part  of the  assessment,  performance
demonstrations will-be carried out to test  the effective-
ness of alternative  technologies in  real-world settings,
providing crucial information about the cost and perfor-
mance of the alternatives under various conditions. The
information in the CTSA and other project documents
will allow the PCB industry decision-makers to evaluate
their existing processes and practices and identify viable,
cost-effective pollution, prevention options. The printed
circuit board CTSA is expected to be completed by the
summer of 1996.           ,
     The PCB  Project Workgroup is also developing a
number of other tools for use  by the  industry. The
"Industry and Use Cluster Profile" contains information
about the current economic status of the industry and the
current methods by which PCBs are manufactured. It
describes industry  demographics, board  types,  market
size, international trends and other industry characteris-
tics. It also describes basic  manufacturing steps and
 alternative technologies for each major process step.
      A "Pollution Prevention Survey," being conducted
 by industry participants, will  contain an in-depth analy-
 sis of pollution prevention technologies currently being
 used in the industry and  data on  chemical use, waste
 reductions,  and the savings  that  have  resulted from
 implementing  the  technologies. The: EPA has also
 developed a document to help  the industry assess the
 regulatory implications of current  and alternative tech-
 nologies titled, "Federal Environmental  Regulations
 Potentially Affecting the Computer Industry".
      Communication Efforts. Throughout the proj-
 ect, the EPA  and project stakeholders will  conduct
 outreach  activities to promote the awareness of the
 project and to generate interest in the project's technical
 and information products. The Project:Team has given

 18 Printed Circuit Fabrication  •              \            - --.
presentations at PCB trade shows, written.articles for
the trade press, distributed DfE information at booth
exhibits, and created project fact sheets. The strategy
developed by the' Communications 'Workshop includes
developing-pollution  prevention case studies that will
provide practical information  on  substitute materials
processes, technologies, and work practices. Based on
CTSA information and successful pollution prevention
experiences, the first two case studies are expected to be
completed by May  1995.
     Implementation Activities. An Implementa-
tion Workgroup will be established to provide assistance,
and a certification.program will be formed for individual
PCB manufacturers who implement the  alternative
technologies identified in the CTSA. This Workgroup
may also conduct additional demonstration projects and
workshops, create videotapes, and develop other training
materials.  •               .    '
 How Can I Get More Infot
    .  The DfE Project Team encourages all interested
 parties to participate in the project, either by joining the
 Technical or Communications Workgroups, by attend-
 ing project meetings, or by asking that the EPA include
 them on the  project  mailing  list. The  next project
 meeting will be held in San Diego on May 4, I995,  in
 conjunction with IPC-Expo.           v
      For more information about the DfE program, the
 DfE PWB Project, or to  be added to the mailing- list,
 contact EPA's Pollution Prevention Information Clear-
 ing  House  (PPIC), U.S.. Environmental  Protection
 . Agency, 401 M St., S.W. (3404), Washington D.C. 20460.
 Tel. 202/260-1023, fax -0178.                   ,BQB

 Katherine M'. Hart and Deborah L. Eager are environmental'
 protection specialists with EPA's Design for the Environment
 Staff, Washington D.C. Michael A.  Kerr is the environmental,
' safety & health manager at Circuit Center Inc., Dayton OH.