In its comments, IPC explains that the simultaneous restriction of the 20 substances identified in Chapter V, Schedule III of the proposed draft regulation will not contribute to the environmentally sound disposal of electronic products and proposes that a scientific evaluation of substances be conducted in order to ensure that alternatives provide a benefit to human health and the environment. “IPC urges the Ministry to implement a scientifically-based methodology for restricting substances that includes a full life-cycle assessment of the substances and possible alternatives in order to accomplish the goal of maximum human health and environmental protection,” says Fern Abrams, IPC director of government relations and environmental policy.
Several substances included in Schedule III have been proven to be safe for human health and the environment and should not be restricted under the Ministry’s proposal. For example, Tetrabromobisphenol-A (TBBPA), the most common flame retardant used in more than eighty percent of printed boards, has been safely used for decades. The World Health Organization and the European Commission Scientific Committee on Health and Environmental Risks (SCHER) conducted separate, comprehensive scientific assessments of TBBPA and both found TBBPA to be safe for human health and the environment.
Noting a study of lead-free solder conducted by the U.S. EPA, IPC warns of the environmental trade-offs when restricting substances and blindly substituting one for another. Following the European Union’s restriction of the use of lead in electronics under the RoHS Directive, the EPA study evaluated the environmental impacts of tin-lead solder versus lead-free alternative solders and found that the increased energy use associated with the higher operating temperatures required for manufacturing lead-free soldered electronics would cause greater negative impacts on the environmental than tin-lead soldered electronics. “There should be clear and compelling evidence that potential alternatives are available, are reliable and are preferable from a life cycle perspective,” cautions Abrams. “Until life cycle assessments are conducted proving that the environmental and human health impacts across the alternative’s life cycle are better than the substances being replaced, the Ministry should not restrict any substances.”
IPC also urged the Ministry to consider removing medical devices and monitoring and control instruments, Categories V and VI, respectively, from the list of product categories covered because of their extreme complexity and suggested the institution of a phase-in plan for medical devices and monitoring and control equipment, similar to that proposed for the revision of the European RoHS Directive. Along those lines, IPC asked the Ministry to harmonize the list of substances for restriction with the current RoHS Directives in the European Union and China to help Indian manufacturers compete globally.
To view IPC’s comments, visit http://www.ipc.org/Comments-and-Testimony.
IPC (www.IPC.org) is a global trade association based in Bannockburn, Ill., dedicated to the competitive excellence and financial success of its 2,700 member companies which represent all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test. As a member-driven organization and leading source for industry standards, training, market research and public policy advocacy, IPC supports programs to meet the needs of an estimated $1.7 trillion global electronics industry. IPC maintains additional offices in Taos, N.M.; Arlington, Va.; Garden Grove, Calif.; Stockholm, Sweden; Moscow, Russia; Bangalore, India; and Shanghai and Shenzhen, China