Effective today, the EPA has issued a temporary 180-day ‘No Action Assurance’ order and extended the public comment period to seek industry input on newly-raised issues associated with the March 8, 2021, compliance date for the prohibitions on processing and distribution of Phenol, Isopropylated Phosphate (3:1) (PIP (3:1)) for use in articles, and the articles to which PIP (3:1) has been added.
As stated in the EPA announcement, “Stakeholders recently informed EPA that the prohibition on processing and distribution of PIP (3:1) could impact articles used in a wide variety of electronics, from cell phones, to robotics used to manufacture semiconductors, to equipment used to move COVID-19 vaccines and keep them at the appropriate temperature. Stakeholders note that the complexity of international supply chains makes locating the presence of, and finding alternatives to, PIP (3:1) in components challenging. They assert that an extension to the compliance deadline is necessary to avoid significant disruption to the supply chain for a wide variety of articles. It was not EPA’s intent during the development of the rule to have such a broad disruptive impact. Thus, EPA is also announcing its expectation that this specific issue will be addressed as part of the broader re-examination of these rules.”
“ECIA continues to work with NAM to understand exactly how this will impact the electronic components industry and will inform members about how best to provide comments to the EPA,” noted Don Elario, ECIA Vice President of Industry Practices. “This chemical is not one that has been on most companies’ environmental compliance radar. We will be updating our members as the issue unfolds,” he concluded.
The EPA has issued a memorandum from Lawrence E. Starfield, EPA Acting Administrator outlining in detail the action taken today.
For a more complete list of resources about the EPA ban of PIP 3:1, please go to Issues & Practices (ecianow.org).
