overview of lcpfac and pfoa regulations & impacts on the semiconductor industry · ·...

Overview of LCPFAC and PFOA Regulations & Impacts on the

Semiconductor Industry Laurie Beu

Laurie S. Beu [email protected]

512-351-3982on behalf of

The Semiconductor Industry AssociationApril 1, 2015

Presentation Outline� Background

� Proposed EU PFOA Restriction

� Proposed US EPA LCPFAC SNUR

� Use of LCPFAC in Semiconductor Lithography Formulations

� Potential Fluorochemical Use in Articles

� Articles Survey

� Anticipated Regulatory Timeline

� Impacts

� Summary

Semiconductor Industry Webinar - April 1, 2015 2

Long chain perfluoroalkyl carboxylates Background

� The US and European Union (EU) have both recently proposed regulations restricting certain long chain perfluoroalkyl carboxylates (LCPFAC) including perfluorooctanoic acid (PFOA) and PFOA substances

� Both proposed regulations restrict LCPFAC substances and articles containing certain LCPFAC� US rule does not contain threshold concentration limit

� EU proposed level is much lower than levels listed on SDSs and in product content tracking systems


LCPFAC Proposed EU PFOA Restriction

� On December 17, 2014, ECHA published a restriction dossier on "PFOA and PFOA related substances” http://echa.europa.eu/restrictions-under-consideration/-/substance-rev/1908/term

� Perfluorooctanoic acid (PFOA, CAS 335-67-1, EC 206-397-9), including its salts and any other substance having linear or branched perfluoroheptyl derivatives with the formula C7F15- as a structural element, including its salts except those derivatives with the formula C7F15-X, where X= F, Cl, Br and any other substance having linear or branched perfluorooctyl derivatives with the formula C8F17- as a structural element, including its salts, except those derivatives with the formula C8F17-X, where X= F, Cl, Br or, C8F17-SO2X', C8F17-C(=O)OH or C8F17-CF2-X' (where X'=any group, including salts)

� Official comment deadline is June 17, 2015; however, Risk Advisory Committee (RAC) and Socio-Economic Analysis Committee (SEAC) meet in early June.


LCPFAC Proposed EU PFOA Restriction

� PFOA and PFOA related substances:1. Shall not be manufactured, used or placed on the market

- as substances,

- as constituents of other substances in concentrations equal or above 2 ppb of a single substance,

- in a mixture in concentrations equal or above 2 ppb of a single substance

2. ARTICLES or any parts thereof containing one of the substances in concentrations equal to or greater than 2 ppb of a single substance shall not be placed on the market.

3. Paragraph 1 and 2 shall apply from (18 months after entry into force).

4. By way of derogation, paragraph 2 shall not apply to the placing on the market of second-hand articles which were in end-use in the European Union when the restriction becomes effective.


LCPFAC Proposed US EPA SNUR

� The US EPA has proposed a TSCA (Toxic Substances Control Act) Significant New Use Rule (SNUR) for long-chain perfluoroalkyl carboxylate (LCPFAC) substances http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2013-0225-0001

� EPA believes:

� Use of LCPFAC will be phased out by December 31, 2015 and any uses after that time are new uses

� All uses of PFOA and its salts were phased out by December 31, 2013

� Uses not already ongoing as of January 21, 2015, and ongoing uses that will be phased out by the end of 2015, would not be considered ongoing uses if they later arise, even if they are in existence upon the issuance of a final rule

� LCPFAC substances cannot be manufactured, imported or processed for any use in the U.S. Any uses that become known would be a “New Use” and would require approval under a “Significant New Use Notification” (SNUN)

� Rule proposes removing the current article exemption (40 CFR 721.45(f))


LCPFAC EPA Request for Comments

� EPA has requested comments on:� Whether any of the current uses of the LCPFAC chemical substances

listed in Table 1 will be ongoing after December 31, 2015,

� Whether there are any ongoing uses of those LCPFAC chemical substances listed in table 2, and

� Whether there are any ongoing uses, including use as part of articles, of any of the LCPFAC chemical substances.

� EPA also requests comments addressing the extent to which companies manufacturing specific LCPFAC chemical substances for particular uses are utilizing existing sources that are not dependent on the PFOA Stewardship Program member companies and that are expected to continue after December 31, 2015

� The comment deadline is extended to June 26, 2015.


LCPFAC Proposed SNUR and Articles

� Import of an article containing LCPFAC substances listed in Tables 1 and 2 (with the exception of PFOA (or its salts) that are imported as part of an aqueous dispersion or fluoropolymers as part of an article) would be considered Significant New Use and would require filing a Significant New Use Notification.

� No concentration threshold. SNUR applies to articles containing regulated substances in any quantity (except as an impurity).


LCPFACProposed Regulatory Thresholds

� EPA SNUR does not specify a minimum threshold concentration; REACH PFOA restriction proposes 2 ppb threshold

� Safety Data Sheets may not require listing of substances present in concentrations <0.1%

� Materials Declarations are typically not required for substances present in low concentrations

� IC makers are uncertain if regulated substances are contained in articles required for manufacturing and how long it will take suppliers to determine if present


LCPFACUse in Semiconductor Formulations

� LCPFAC proposed for regulation under the US EPA SNUR and European REACH restriction are found in lithography formulations� Resists� Anti-reflective coatings

� At 2ppb threshold proposed in REACH restriction dossier, PFOA and related substances are likely contained in formulations where LCPFAC have been replaced by short chain substitutes


LCPFACPotential Semiconductor Article Uses

Fluorochemistries are likely to be found in:

� Lining in tanks, valves, and pumps

� Chemical resistant pipes and tubing

� Chemical resistant wafer carriers, boats and trays

� Teflon coated parts and surfaces of process equipment

� Gaskets and o-rings

� Insulation for wire and cable


More information: http://fluorocouncil.com/PDFs/Industrial-Reliance-on-FluoroTechnology.pdf

LCPFACArticles Survey

� The Semiconductor Industry Association (SIA), European Semiconductor Industry Association (ESIA) and SEMI are currently conducting a survey of semiconductor equipment, component and ancillary suppliers to:� Raise supply chain awareness of proposed regulations and

their potential impact on the supply chain� Identify steps needed to determine if LCPFAC are present in

articles� Provide data for industry comments

� Link to survey: https://www.surveymonkey.com/r/LCPFAC-PFOA_Survey

� Survey closes on April 7, 2015 – contact [email protected] for more information


LCPFACAnticipated Timeline of Regulatory Actions


Date Action

after&January&21,&2015 US&EPA&Significant&New&Use&for&manufacturing&(including&Importing)&or&processing&of&other&LCPFAC

after&January&21,&2015 US&EPA&Significant&New&Use&for&manufacturing&(including&Importing)&or&processing&of&PFOA&and&its&salts

Week&of&March&9,&2015European&Chemicals&Agency&(ECHA)&Risk&Assessment&Committee&(RAC)&and&SocioNEconomic&Analysis&Committee&(SEAC)&begin&review&of&REACH&restriction&proposal&for&PFOA&and&related&substances

June&1N5,&2015 ECHA&RAC&Meeting&(likely&to&include&discussion&of&PFOA&restriction&proposal)

June&8N12,&2015 ECHA&SEAC&Meeting&(likely&to&include&discussion&of&PFOA&restriction&proposal)

June&17,&2015 Deadline&for&public&comment&on&REACH&restriction&proposal&for&PFOA&and&related&substances

June&26,&2015Deadline&for&Comments&on&US&EPA&Proposed&Rule:&&LongNChain&Perfluoroalkyl&Carboxylate&and&Perfluoroalkyl&Sulfonate&Chemical&Substances;&Significant&New&Use&Rule

September&7N18,&2015 ECHA&RAC&Meeting&(likely&to&include&discussion&of&PFOA&restriction&proposal)

September&7N11,&2015 ECHA&SEAC&Meeting&(likely&to&include&discussion&of&PFOA&restriction&proposal)

November&23&N&December&4,&2015 ECHA&RAC&Meeting&(likely&to&include&discussion&of&PFOA&restriction&proposal)

November&30&N&December&4,&2015 ECHA&SEAC&Meeting&(likely&to&include&discussion&of&PFOA&restriction&proposal)

after&December&31,&2015 US&EPA&Significant&New&Use&for&manufacturing&(including&Importing)&or&processing&of&LCPFAC&in&Table&1

March&1,&2016 European&Commission&will&issue&its&proposal&regarding&PFOA&restriction

AprilNMay&2016 REACH&Committee&vote&on&PFOA&restriction

MidN2016 Adoption&of&PFOA&Restriction

USEU

LCPFACImpacts

� Both US EPA and ECHA have proposed regulations restricting LCPFAC including PFOA and its salts – neither rule exempts critical semiconductor uses

� Proposed EPA SNUR designates uses not already ongoing as Significant New Use if they are in existence upon publication of the proposed rule

� Manufacturers must identify existing uses to EPA during comment period

� ECHA 2ppb threshold results in a de facto ban on short chain substitutes and fluoropolymers made without PFOA


Summary� Recently proposed chemical regulations have impacts

across the semiconductor industry supply chain

� Low or no minimum concentration thresholds put the supply chain at risk � What company requires disclosure of substances present at

0.0000002%?� Can these levels be measured with accuracy and

repeatability?

� Effectively addressing future chemical restrictions requires increased communication and cooperation across the semiconductor industry supply chain – IC makers welcome increased communication and cooperation with suppliers


Additional Information


LCPFAC SNUR Definition

� LCPFAC chemical substances are synthetic chemicals that do not occur naturally in the environment. The LCPFAC chemical substances identified in this unit, where 5 < n < 21 or 6 < m < 21: 1. CF3(CF2)n-COO-M where M = H+ or any other group where a formal

dissociation can be made.;

2. CF3(CF2)n-CH=CH2.

3. CF3(CF2)n-C(=O)-X where X is any chemical moiety.

4. CF3(CF2)m-CH2-X where X is any chemical moiety.

5. CF3(CF2)m-Y-X where Y = non-S, non-N heteroatom and where X is any chemical moiety.

� The category also includes the salts and precursors of these chemical substances. The precursors may be simple derivatives of PFOA and higher homologues or polymers that contain or may degrade to PFOA or higher homologues. These precursors include long-chain fluorotelomers.


EPA SNUR Table 1:LCPFAC Substances


EPA SNUR Table 2:PFOA and Example of Its Salts


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Disclaimer� The presentation material is intended for guidance

only and while the information is provided in utmost good faith and has been based on the best information currently available, is to be relied upon at the user’s own risk. This is not intended to be a comprehensive treatment of the subject matter and is not intended to provide legal advice or to serve as a substitute for legal counsel. No representations or warranties are made with regards to its completeness or accuracy and no liability will be accepted for damages of any nature whatsoever resulting from the use of or reliance on the information. You should consult legal counsel to determine the applicable law for your situation.

Semiconductor Industry Webinar - April 1, 2015

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