Please find the attached comments of the Semiconductor Industry Association (SIA).
Significant New Use Rule for Long-Chain Perfluoroalkyl Carboxylates and Perfluoroalkyl Sulfonates
Activity
Semiconductor Industry Association filed 7 comments on this docket between Feb 25, 2015 and Apr 28, 2020. 34 other organizations filed here. The comment window closed 2293d ago.
What Semiconductor Industry Association filed (7)
Grimaldi Law Offices Comments on Proposed SNUR
These corrected comments supersede the comments submitted on June 25, 2015 by the Semiconductor Industry Association (SIA).
ESIA - European Semiconductor Industry Association 11/13 rue de la Duchesse, B-1150 Brussels, Belgium Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave. NW. Washington, DC 204600001 June 26/6/2015 Re: Docket Identification (ID) number EPAHQOPPT20130225 The European Semiconductor Industry Association would like to endorse and support of the comments filed by the U.S. Semiconductor Industry Association (SIA) on the above-referenced matter. (Significant New Use Rules: Long-Chain Perfluoroalkyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances) The EPA proposal on Long-Chain Perfluoroalkyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances (80 Fed. Reg. 2885 (Jan. 21, 2015)) is of great interest to the European and global semiconductor industry. As stated in the SIA comments, the global semiconductor industry and our equipment and material suppliers have specific, ongoing uses of the chemicals covered by the proposal. The chemicals covered by this proposal continue to be used in the semiconductor industry in (1) the semiconductor manufacturing process, (2) in the complex equipment used to manufacture semiconductors, and (3) finished semiconductor devices and packaging. The global semiconductor industry utilizes a complex and integrated supply chain of equipment and material suppliers. Accordingly, this proposal has the potential to impact the global semiconductor industry, and we urge EPA to issue a final rule that exempts the specific, ongoing uses of the covered chemicals by the semiconductor industry. ABOUT ESIA The European Semiconductor Industry Association (ESIA) is the voice of the Semiconductor Industry in Europe. Its mission is to represent and promote the common interests of the Europe-based semiconductor industry towards the European Institutions and stakeholders in order to ensure a sustainable business environment and foster its global competitiveness. As a provider of key enabling technologies the industry creates innovative solutions for industrial development, contributing to economic growth and responding to major societal challenges. Being ranked as the most R&D intensive sector by the European Commission, the European Semiconductor ecosystem supports approx. 200.000 jobs directly and up to 1.000.000 induced jobs in systems, applications and services in Europe. Overall, micro- and nano-electronics enable the generation of at least 10% of GDP in Europe and the world.
Filed on regulations.gov — full text not in the inline record.
Filed on regulations.gov — full text not in the inline record.
See attached file(s). On behalf of the Semiconductor Industry Association (SIA), please find the attached request for an extension of time to file comments in this matter.
Abstract
EPA is proposing to amend significant new use rules (SNUR) for long-chain perfluoroalkyl carboxylate (LCPFAC) and perfluoroalkyl sulfonate (PFAS) chemical substances. This action would require persons subject to these SNURs to notify EPA at least 90 days before commencing any significant new use.
View on regulations.gov →Co-filers (34)
See everyone who commented →- Semiconductor Industry AssociationTHIS ORG7 filings · confidence 97%
- American Chemistry Counciltrade assoc.2 filings · confidence 97%
- EMD Performance Materials Corp.unverified attribution2 filings · confidence 70%
- Intel Corporationunverified attribution2 filings · confidence 70%
- 3M Companyunverified attribution1 filing · confidence 70%
- Aerospace Industries Associationtrade assoc.1 filing · confidence 97%
- Alliance for Automotive Innovationtrade assoc.1 filing · confidence 97%
- Alliance of Automobile Manufacturerstrade assoc.1 filing · confidence 97%
- American Coatings Associationtrade assoc.1 filing · confidence 97%
- American Water Works Associationtrade assoc.1 filing · confidence 97%
- Arkema Incunverified attribution1 filing · confidence 70%
- Arnold & Porter Kaye Scholer LLP on behalf of Chemical Users Coalitiontrade assoc.1 filing · confidence 85%
- Arnold & Porter on behalf of Chemical Users Coalitiontrade assoc.1 filing · confidence 85%
- Association of Metropolitan Water Agenciestrade assoc.1 filing · confidence 97%
- Brewer Science Inc.unverified attribution1 filing · confidence 70%
- Committee on Environment and Public Workstrade assoc.1 filing · confidence 85%
- Consumer Technology Associationtrade assoc.1 filing · confidence 97%
- Dynax Corporationunverified attribution1 filing · confidence 70%
- Environmental Defense Fundtrade assoc.1 filing · confidence 97%
- European Semiconductor Industry Associationtrade assoc.1 filing · confidence 85%
- Global Industry Council for FluoroTechnologytrade assoc.1 filing · confidence 85%
- GLOBALFOUNDRIES U.S. Inc.unverified attribution1 filing · confidence 70%
- Grimaldi Law Offices on behalf of SEMI and the Semiconductor Industry Associationtrade assoc.1 filing · confidence 85%
- Hewlett-Packard Companyunverified attribution1 filing · confidence 70%
- High Speed Wax Companyunverified attribution1 filing · confidence 70%
- Keller and Heckman LLP on behalf of Plastics Industry Associationtrade assoc.1 filing · confidence 85%
- Keller and Heckman LLP on behalf of the Plastics Industry Associationtrade assoc.1 filing · confidence 85%
- Motorcycle Industry Counciltrade assoc.1 filing · confidence 85%
- Outdoor Industry Associationtrade assoc.1 filing · confidence 85%
- Outdoor Power Equipment Institutetrade assoc.1 filing · confidence 85%
- Renesas Electronic Corporationunverified attribution1 filing · confidence 70%
- Responsible Science Policy Coalitiontrade assoc.1 filing · confidence 85%
- Retail Industry Leaders Associationtrade assoc.1 filing · confidence 85%
- Taiwan Semiconductor Industry Associationtrade assoc.1 filing · confidence 85%
- Texas Instruments Incorporatedunverified attribution1 filing · confidence 70%