EPA Signs Final MP&M Rule, Signifies Key Victory for U.S. PCB Industry


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Northbrook, Ill. -- IPC -- Association Connecting Electronics Industries announces that the Environmental Protection Agency (EPA) has recently signed a final rule on Metal Products and Machinery (MP&M) effluent limit guidelines.

The final is substantially different from the regulations discussed in the January 2001 Notice of Proposed Rulemaking (NPRM), which called for regulations that would have made wastewater discharge limits 95 percent more stringent for printed circuit board (PCB) manufacturers and introduced national discharge limits for electronics manufacturing services (EMS) facilities for the first time. The final rule does not contain any new regulations for the PCB or EMS industries.

In January 2001, EPA first proposed the MP&M effluent limitation guidelines and included a total annualized cost estimate of $147.1 million for the PCB industry or slightly more than $250,000 per facility. EPA also calculated that seven PCB facilities would be forced to close due to the costs of complying with the proposed MP&M guidelines, while an additional 301 facilities would have difficulty financing compliance investments or ongoing business investments as a result of the rule.

More than 30 IPC members and staff responded by testifying at various EPA public hearings across the country. Following the public testimony, IPC filed more than 300 pages of written comments in July 2001 that firmly detailed EPA's failure to properly evaluate its proposed rule's impact on the PCB industry and revealed the agency's overestimations of environmental benefits and underestimations of the immense costs for each PCB manufacturer. The comments also requested that EPA assess realistic PCB wastewater treatment capabilities, obtain a true estimate of the pollution expected to be removed by a proposed rule, obtain a more realistic estimate of the cost of compliance and correct the economic impact analysis.

In addition, Fern Abrams, IPC's director of environmental policy, testified before a U.S. House of Representatives Committee on Small Business, Subcommittee on Regulatory Reform and Oversight in November 2001 regarding EPA's failure to conduct adequate regulatory analysis.

EPA then issued a revised proposal in the form of a June 2002 Notice of Data Availability (NODA), which showed that the economic impact and cost effectiveness of the treatment options were actually much higher than originally projected. In the NODA, EPA predicted that between 28 and 55 facilities would be put out of business by the proposed regulation, a significant increase over the NPRM estimate of seven PCB company closures. The notice also drastically revised its estimate of the pollution removals attributable to the proposed rule from 1.1 million pound equivalents of pollution from PCB effluent to only 165,662-pound equivalents.

IPC then responded in August 2002 by filing more written comments on EPA's NODA that both praised EPA for the corrections and called for further changes to correct the rule's inflated environmental benefits.

IPC is a trade association dedicated to the competitive excellence and financial success of its more than 2,400 member companies, which represent all facets of the electronic interconnection industry, including design, printed circuit board manufacturing and electronics assembly. For more information, visit www.ipc.org.

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