Health & Environment
I3A works with global communities and agencies to resolve environmental issues around the world. Together with these groups, I3A addresses worldwide health, safety and environmental issues that affect the imaging industry. I3A also collaborates to develop strategies for joint approaches to solving HSE issues in a timely and cost-effective manner, utilizing existing regional trade organizations or regional photographic industry committees to provide implementation capability and to ensure that all photographic product manufacturers can access any of the resulting initiatives.
I3A has a history of successful efforts toward reducing the impact of our industry on the environment. In the 1990s, I3A, (then PIMA) was the organizer of the Silver Coalition that developed a Code of Management Practices (CMP) for Silver Dischargers, containing recommendations on technology, equipment and management practices for controlling silver discharges from facilities that process photographic materials.
I3A members monitor the actions and developments of the Registration, Evaluation, and Authorization of Chemicals (REACH) program in Europe, and pay close attention to the European Commission’s ongoing reviews of REACH. The EC has been tasked with conducting a review within the first 18 months of a new regulation going into effect. More information may be found on the REACH Guidance website of the European Chemicals Agency (ECHA) at http://ec.europa.eu/echa/home_en.html.
Emerging Issues and Regulatory Issues in China/Asia
The members of the I3A E&H Committee also keep an eye on emerging issues in China and Asia.
They have recently met to discuss the Chinese government’s five -year plan whichthat focuses on policies that are environmentally friendly, and energy efficient. The Chinese government’s goal is to make “environmental protection” a principal (national) policy and to incorporate public involvement in making all future new laws and regulations. There are currently nine environmental laws under consideration in the following areas:
- Environmental Protection Law,
- Water Pollution Prevention ,
- Promotion of Sustainable Development,
- Waste Discharge/Emission Permits,
- Environmental Management on Free Trade Zones
Perfluorinated Materials
In October 2000, the U.S. Environmental Protection Agency published a proposed Significant Use Rule, or SNUR, that would prevent all import or manufacture of perfluorinated materials, currently referred to as perfluoroalkylsulfonates (PFAS). Because PFAS materials have critical uses in the manufacture of imaging materials and all semiconductor products (i.e., digital cameras, printers, scanners, photoprocessing equipment controls, etc.), an industry response was clearly required.
Interested I3A member companies formed a working group to assess and respond to the proposed rule. Over the next two years, the I3A PFAS Working Group made public comments, met with the USEPA to discuss its concerns and respond to questions, and developed an extensive package of information to demonstrate to the EPA that PFAS materials were critical components of analog and digital imaging. Working Group member companies also worked during the comment period to significantly reduce PFAS use.
As a result, on December 9, 2002, the USEPA published a final SNUR for 75 PFAS materials that provides an exemption to the imaging industry for continued import and manufacture of these materials for critical analog and digital imaging purposes. The details of the SNUR and the exemption can be found in volume 67 of the Federal Register (December 9, 2002) on pages 72854-72867. Significantly, in providing the SNUR, the Agency commended I3A for the significant steps made in reducing use of PFAS chemicals and for the efforts expended in providing the Agency with the information it needed to make a decision on the exemption.
Regulatory activity affecting PFAS chemicals is evolving in Japan and Europe, In November 2002, a risk assessment on PFAS chemicals was completed by the Organization for Economic Cooperation and Development and agreed upon by member countries. In The Netherlands, a risk assessment document on PFAS chemicals in the environment has recently been completed, and the United Kingdom and Sweden have made a recommendation for inclusion of PFAS and related chemicals under the OSPAR Convention. Interested I3A member companies are actively working with international agencies on a global extension of the exemption granted by the USEPA.
Get Involved
All I3A members are welcome to join this group. Contact I3A to join this group.