IPC Testifies on EPA request for guidance on reopening DSW Rule.July 3, 2009 -
Supporting the Environmental Protection Agency's (EPA) 2008 Definition of Solid Waste Rule (DSW), IPC director of environmental policy and government relations Fern Abrams testified as to its environmental benefits. Her testimony focused on how the DSW rule removes regulatory barriers that inhibit the recycling of manufacturing wastes while simultaneously providing an environmental benefit by reducing waste. Based on such points, Abrams urged the EPA to deny Sierra Club's petition.
IPC Testifies on EPA Request for Guidance on Reopening DSW Rule
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IPC-Association Connecting Electronics Industries
3000 Lakeside Drive
Bannockburn, IL, 60015
Press release date: July 1, 2009
BANNOCKBURN, Ill., USA, July 1, 2009 - Taking a firm stance in support of the Environmental Protection Agency's (EPA) 2008 Definition of Solid Waste Rule (DSW), Fern Abrams, IPC director of environmental policy and government relations, testified on the environmental benefits of the rule at the agency's public meeting yesterday.
In January 2009, the DSW Rule came under attack by the environmental group, Sierra Club, with allegations of a "midnight regulation" and a petition to reopen the Rule. EPA requested the public meeting to seek guidance. If the Rule is reopened, the increase in recycling of valuable metals and other materials would be potentially lost. In addition, the $95 million dollars in savings per year that the current DSW rule would provide affected industries including electronics manufacturers, as originally projected by the EPA, would be in jeopardy.
Abrams' testimony focused on how the DSW rule removes regulatory barriers that inhibit the recycling of manufacturing wastes while simultaneously providing an environmental benefit by reducing waste. "This regulation provides a rare win-win situation for both industry and the environment. We urge EPA to reexamine the strong regulatory record it has amassed in support of this carefully calibrated rule and deny the Sierra Club's petition."
Sierra Club claims that the DSW rule does not provide an environmental benefit and that the requirements under the rule should be stricter. The group also expressed opposition to the transfer-based exclusion which allows secondary materials to be recycled off-site, outside of the Resource Conservation and Recovery Act's (RCRA) onerous hazardous waste regulations.
Although there are a number of materials that are likely to be recycled under the transfer-based provisions of the DSW rule, Abrams focused on one particular waste stream from the manufacture of electronics to exemplify the benefits of that provision. "Metal sludge, created through the treatment of wastewater from the electroplating of PCBs and other items, is one of the secondary materials that will more commonly be recycled under the provisions of DSW. [It] is one of the largest sources of untapped metal-bearing secondary material in the U.S.," said Abrams. The burdensome nature of the RCRA hazardous regulations have created monopoly-like conditions and monopolistic prices for the recycling of electroplating sludge. As a result, Abrams explained, it can be more costly to recycle electroplating sludge than to dispose of it in a landfill. "The transfer-based exclusion in the DSW rule empowers the marketplace to create new and cost-effective recycling options that produce a win-win situation in reducing the mining of virgin metals and saving money."
Abrams used her allotted seven minutes to emphasize the environmental benefits of the rule and stress the thoroughness of the EPA's regulatory analysis in support of the rule. "The EPA has been working on the DSW rule for more than a decade and it is grossly incorrect for Sierra Club to categorize it as a midnight rule," said Abrams. "The purpose of RCRA is to encourage resource conservation and reduce the amount of waste and the DSW rule accomplishes those goals."
IPC will provide a more detailed opinion in written comments that will be submitted separately. The deadline for written comments is August 13, 2009. For more information on the DSW rule or to view IPC's written comments, visit www.ipc.org/DSW.
Industry members are strongly encouraged to submit individual comments and may use IPC's comments as a template. Questions should be directed to Stephanie Castorina, IPC manager of environmental programs, at firstname.lastname@example.org or +1 703-522-0225.
About IPC 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; and Shanghai and Shenzhen, China.