The U.S. Environmental Protection Agency (USEPA) recently established the PFAS Low Volume Exemption Stewardship Program (for perfluoroalkyl and polyfluoroalkyl substances), encouraging all PFAS Low Volume Exemption (LVE) holders to withdraw the LVEs or submit Pre-Manufacturing Notice (PMN) applications in order to continue to manufacture and/or import the substances in the U.S. The PMN application process could potentially trigger prohibitions on releases of these substances into wastewater and importation limits, and lead to costly testing requirements to avoid additional restrictions.
The potential cost of the PFAS program to semiconductor photolithography suppliers is significant and could include payments for PMN fees ($16,000 per substance), legal and consulting services, and testing. If water releases are prohibited, the downstream costs of this program at semiconductor fabrication facilities would also be substantial, since this would require the capture, treatment and disposal of wastewater streams.
To reduce the financial burden, semiconductor lithography suppliers and fabs must coordinate on this new USEPA policy in order to help ensure standardized PMN restrictions or testing requirements, and to leverage the influence of SEMI to explain the importance of these substances in the U.S. manufacturing of semiconductors.
The SEMI PFAS Low Volume Exemption Working Group was established to identify strategies that minimize supply chain risks and impacts to downstream users stemming from the PFAS Low Volume Exemption Stewardship Program.
The PFAS Low Volume Exemption Working Group scope will include the following:
- Acting as a central repository for organizing agency communication related to the program for supplier and fabs
- Identifying where cooperation may be possible among suppliers for structurally similar PFAS PMN submissions
- Information sharing among PMN submitters on USEPA proposed restrictions and/or testing requirements
- Facilitating the procurement of consulting and/or legal assistance as necessary to facilitate advocacy with the USEPA
The working group invites your participation. To join the group, please email ehs@semi.org.
Robert Bonderer is Senior EHS Manager at JSR North American Headquarters.