Kelly Scanlon – why collection and dissemination of chemicals data is a top priority for electronics

Kelly Scanlon is the EHS policy and research director at global electronics industry association IPC, where she works with the organisation’s government relations and EHS committees, and its wider membership "to develop a robust environmental policy agenda and a plan to achieve that."

IPC brings together all the players in the electronic interconnection industry: designers, PCB manufacturers/fabricators, assembly companies, suppliers and OEMs. Its members serve many other economic sectors including aerospace, defence, automotive, telecomms, industrial and medical.

In her work, Ms Scanlon represents the organisation before policy makers and industry coalitions. She took time out to speak with Chemical Watch’s editorial director Geraint Roberts.

Geraint Roberts: How has your professional background prepared you for the role of EHS policy and research director at electronics industry association IPC? 

Kelly Scanlon: My background is in public health science, but I also have experience in biology, chemistry and environmental health and worker safety – from on-the-ground, practical decisions about how to keep people safe to science policy, meaning how to bring evidence and data that's peer reviewed or otherwise consensus-based to policy makers to make better policies. My current role is my first time working on a government relations team, but it’s a natural evolution of my experience.

GR: When did you first become immersed in the world of chemicals management?

KS: I was an industrial hygienist at a university. My department managed the hazardous waste on campus, the asbestos management programme and the laboratory safety programme – keeping the campus and its inhabitants safe.

GR: Prior to joining IPC you worked at the Department of Defense (DOD). What was your role there?

KS: It was very similar to what I do now at IPC, taking an in-depth look into the regulations or policies around chemicals, the full lifecycle of a chemical and how that alters our understanding of the purchase, use, or disposal of that chemical. We examined new policy initiatives affecting the defence industry. If there was a chemical regulation coming down the pipeline, maybe even five to ten years from now, we examined the possible impacts on the DOD.

Likewise, at IPC, we use scientific evidence to help the industry make better decisions about the chemicals used in electronics, and to advocate for the electronics industry when it comes to new and emerging chemical regulations.

GR: Since you joined IPC in April 2019, what have been the key chemicals-related issues for your membership?

KS: What comes to the top again and again is the need to identify and collect data and information that can be used to inform and educate policy makers. We see a growing need to have more information available globally on hazards and exposures across the lifecycle. For example, under TSCA, the US EPA is beginning to evaluate conditions of use through the lifecycle. 

GR: What about members who are being asked to provide this kind of information in different jurisdictions so they have to manage a global patchwork?

KS: One of our advocacy goals is to minimise the patchwork of requirements for the design or maintenance of electronics. However, the existing patchwork is not going away so we need to aim to make use of data for multiple policies. For example, hazard and exposure information on one chemical may be useful to the EPA as it does its TSCA risk evaluation, and to Echa as it evaluates the science behind an updated occupational exposure limit.

It gets harder and harder, especially when you have these complex products that are built from complex, dynamic supply chains. Where are the PFAS, the phthalates, the flame retardants in that complicated product?

GR: The need to identify and collect data is an important, broad challenge. Are there other issues that fall outside that?

KS: That's primarily where I'm focusing my attention – the identification, collection and dissemination of information, along with looking into the value chain across the lifecycle of a product. IPC’s members span the whole supply chain of electronics. We have the companies that are making the laminates, and we also have the OEMs and every company in between.

GR: How do you see those key issues developing over the next few years?

KS: My job is to "monitor the temperature" on these different policy activities and to engage effectively when and where we can. We see many new and emerging policy requirements for chemicals management: the amended TSCA, the EU circular economy action plan, the EU chemicals strategy for sustainability, even the general review of the EU RoHS Directive. We are engaging in these frameworks in real time. But I don’t know how to predict what’s going to happen in a few years, especially given the dynamic political landscape in these jurisdictions, in particular in the EU and US.

In Asia, we’re keeping an eye on several RoHS-like and REACH-like regulations. As those evolve, we're keeping track of those changes and what that may mean. You mentioned the word "patchwork", and we’re very sensitive to that, because you don't want to have ten different RoHS-like regulations; you want to have ten that say the same thing and aim towards the same environmental goals, all based on commonly accepted, good science. 

GR: Europe is driving towards a circular economy. Is there a similar trend emerging in North America or Asia?

KS: In terms of circular economy, Europe is out in front. But there are some interesting things happening in the US. I was at a recent meeting with the National Association of Manufacturers, of which IPC is a member, and they had a professional staff member from the House of Representatives talking about a US circular economy action plan, looking at it through the lens of heavy industry, and looking at things like energy efficiency and zero waste. It’s not as extensive as Europe right now, but interesting that professional staff are starting to lay the groundwork. 

The other interesting thing is the Sustainable Chemistry Act. There are two bills, one in the House and one in the Senate. The Senate bill is getting some traction, so we’ll track that and see what happens. 

GR: Is IPC, or its members, working with downstream sectors on projects to find viable alternatives to particular chemicals of concern?

KS: Our members represent the entire electronics supply chain, and part of my role in EHS and with our IPC standards development team, is to engage with members across sectors and alert them to new and emerging policies, for example on flame retardants. So we're always working with representatives from the auto, aerospace, defence, telecom and medical sectors. It’s important to mention that, through the IPC standards development activities, we have hundreds of committees, subcommittees and task groups – and you don't even have to be an IPC member to be part of these – that are working to make electronics better.

So there are many opportunities within IPC to explore ecodesign, reliability, and more. My role at these standards development meetings, as an IPC government relations team member, is to say, "Hey, this is why your standard would be helpful, because we have a policy issue we're addressing, and instead of worrying about compliance against the regulation, let's have some sort of standard that drives you to a better design or something that doesn't require compliance against a regulation."

GR: Are any of your members that make consumer products under pressure from the public to report on their chemical management activities? Are they looking to minimise use of hazardous chemicals where that's feasible?

KS: Ridding ourselves of hazardous chemicals is a grand ambition that we can strive for, but there are times when we need to use them. For example, we recognise lead is a bad actor, but it’s predictable and provides a necessary function in some electronics applications. Efforts to find safer alternatives are ongoing, but there are still legitimate uses of lead in electronics, especially in aerospace and other high-performance areas. So how do we do a trade-off analysis and find safer ways to work with a known hazardous chemical? By the way, IPC staff are actively involved in coordinating the Pb-free Electronics Risk Management Council made up mainly of aerospace and defence industry representatives – producing position papers, guiding research and development, and setting goals for how to achieve lead-free in critical electronics applications. 

GR: You're asking your members for better information on where PFAS and brominated flame retardants are used, which uses are critical, and which aren’t. How’s that progressing? From what you hear, are your members looking at potential substitutes?

KS: It can be very, very tricky to determine criticality. It's also tricky to determine uniqueness. Is this PFAS or flame retardant used in consumer products only, or are they in automotive products, defence applications? If manufacturers were to stop making that chemical, what would the impact be on that product or component or process? 

We are most active on alternatives to lead in electronics. We support the need for alternatives assessment and standardised methodologies to look for safer alternatives, and weigh that against the potential for exposure, the need for their performance and function, all those things. So, for example, that sustainable chemistry bill in the Senate – if it doesn’t pass this time and goes around for another cycle, we'd probably want to consider whether our members should say, "Yes, we support more research in this direction." I think the challenge is grouping together the best technique for determining criticality, uniqueness and when alternatives are needed.

For example, the PFAS screening study we completed in July was a review of what we know already about their uses in electronics, and we asked our community if we got that right. Are we properly summarising and synthesising everything we already know? And then you go from there to say, is this unique to electronics, or is this something that's found in a lot of places? And can we find a better way to do this? 

GR: Other than PFAS, brominated flame retardants and lead, are there chemicals which you are keeping a particularly close eye on that are relevant to the electronics industry?

KS: Well, the categories you mention are big categories – it’s about which particular PFAS, which phthalates, which flame retardants. With PFAS, there are more than 4,700 on the OECD list. Same with metals: It’s not just lead; there are a lot of metals of concern, including their oxides and salts. So it's not about another chemistry; it's within those chemistries. It's narrowing down which PFAS are of greatest concern, or which metals and even which form of the metal, like nano-sized materials. 

GR: As part of its circular economy action plan, announced earlier this year, the EC is talking about a "right to repair" for electronic equipment, and there's also a planned circular electronics initiative. It seems clear that the ecodesign Directive, which has mainly looked at energy efficiency, could be given a much bigger role. Is that something you and your members are gearing up for?

KS: Absolutely. We are engaging with expert advisers within the Commission’s directorates to learn more about these roadmaps and policy initiatives. While IPC has not yet been active in the ecodesign space, we are exploring what it means for our members and the products they make. That's part of the excitement of the circular economy action plan – new opportunities, for example on topics like product passports and extended producer reliability.

GR: Is there a lot of research going into tools like blockchain and product passports given that the supply chains for electronics are so complicated? Is this a direction that the industry is going to go in?

KS: The product passport concept is tucked within the circular economy action plan, specifically around product sustainability and the need to communicate information. And ICT is one of the sectors that the plan explicitly mentions. And so it's, "How do you green that sector?" But then there's the other side of that, which is, "How do you actually use electronics to make things better?" It's an interesting dynamic.

Ideally, these passports will contain a lot of information that helps manufacturers manage hazard, exposure, circularity of materials across the lifecycle of that product, especially at the end of life, when you can say, "I know how I can circularise, repurpose, reuse, recycle this thing." But that is still formative, at best, and I know that multiple directorates within the Commission will be working on it.

GR: It sounds like something for which a standard format will be required, because otherwise you could have one supply chain saying its product passport uses this kind of tracing technology and it's best in class, and it isn't. And their competitors may spend a lot more money and hard work producing something better.

KS: Exactly. I think we're going to see that dynamic with the product passport and other tools like the product environmental footprint. There are a lot of questions about how to improve the reliability and usability of these tools to help people make good decisions.