On Tuesday, June 5, 2012, leaders of IPC’s Environment, Health and Safety (EHS) Committee met with senior U.S. Environmental Protection Agency, EPA, staff to discuss regulatory relief for printed board manufacturing. Uncertainty around the implementation of the 2008 Definition of Solid Waste, or DSW, rule, combined with the limitations of the EPA’s 2011 proposed rule, has inhibited the recycling of wastewater treatment sludges from electroplating operations (F006). IPC representatives urged Suzanne Rudzinski, director of EPA’s Office of Resource Conservation and Recovery, to encourage secondary materials recycling in the upcoming revision of the Resource Conservation and Recovery Act, or RCRA, DSW rule.
Wastewater treatment sludge from electroplating is one of the largest sources in the United States of untapped metal-bearing secondary materials amenable to metals recovery. Unfortunately, many of these materials continue to be landfilled instead of recycled due to the costly burdens imposed by EPA RCRA hazardous waste regulations.
According to IPC EHS Committee Chair Lee Wilmot, director of EHS, TTM Technologies, “In 2010, U.S. industries landfilled 9.7 million pounds of copper in various byproduct streams.” The changes to the DSW rule proposed by the EPA in 2011 would continue to inhibit the recycling of valuable secondary material by imposing unnecessary burdens. “The U.S. EPA needs to adopt user friendly rules if this landfill-instead-of-recycle result is to change,” continued Wilmot.
“I appreciated the opportunity to present our issues regarding the proposed 2011 DSW revisions to the Agency in person,” said Bret Bruhn, environmental engineer/operations manager, Viasystems. “Hopefully, the EPA will acknowledge our concerns and ensure that we are provided with effective avenues to increase domestic reuse and recycling of our valuable secondary materials.”
Moises Barona, EHS & security manager, DDi/Viasystems agreed, adding, “We urge the EPA to encourage the recycling of these valuable secondary materials, as it is best for the environment. It is time the EPA acted upon enacting sound policy that can have a positive impact toward sustainable materials management, our natural resources and future of recycling activities.”
During the meeting, IPC leaders emphasized the importance of key provisions that should be included in a final DSW rule, namely the transfer-based exclusion and remanufacturing exclusion.
More information on the meeting and the EPA’s proposed changes to the DSW rule is available online.