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On October 18, 2015, IPC – Association Connecting Electronics Industries, the Association of Home Appliance Manufacturers (AHAM), the Consumer Electronics Association (CEA), the Information Technology Industry Council (ITIC), and the National Electrical Manufacturers Association (NEMA) filed joint comments on the U.S. Environmental Protection Agency’s (EPA’s) TSCA Work Plan Chemical Problem Formulation of Tetrabromobisphenol A and Related Chemicals Cluster (Plan).
IPC and its fellow commenters voiced concern that the EPA’s Plan contains incomplete and inaccurate information regarding the uses of Tetrabromobisphenol A (TBBPA). The comments discussed in its main application (approximately 90 percent), TBBPA is chemically reacted to the epoxy resin upon which printed circuit boards (PCBs) are built. The comments note that EPA failed to distinguish between the additive and reactive uses of TBBPA and recommends that EPA separately delineate and assess, within any consumer exposure scenario, exposure as a result of additive and reactive uses of TBBPA. The comments also note that EPA has incorrectly interpreted studies regarding the presence of TBBPA in children’s products.
The comments encourage EPA to revise its planned assessment to more accurately assess use and exposure to TBBPA.