On March 11, IPC responded to a US Environmental Protection Agency (EPA) request for public comment. EPA’s request for comment was regarding its embryonic National Framework for Electronics Stewardship.

IPC responded by first saying that it appreciated the opportunity to comment on EPA’s Solicitation of Input from Stakeholders to Inform the National Framework for Electronics Stewardship (Docket ID # EPA-HQ-RCRA-2011-0185).  Then:

IPC believes that EPA’s goal of encouraging the design, manufacture, procurement, and use of greener electronics should begin with a definition of a green electronic product.

This is in fact an excellent point.  At a recent high-level symposium for “Green Chemistry,” roughly 500 managers and executives gathered to share ideas on the subject of green chemistry.  In my working group, 250 well-educated individuals sat in a large conference room to discuss the business implications of Green Chemistry.  Very quickly it came to light that almost no one present agreed on what Green Chemistry meant.

Definition of green in manufacturing. Some, myself included, thought “green chemistry” would be a topic as defined by Paul Anastas and J.C. Warner, and a discussion of green product manufacture would be about materials and finished goods screened against the original 12 principles of Green Chemistry.  A few folks thought we would discuss law in terms of state-level green chemistry legislation, risk and litigation.

The slight majority in the room had never heard of the 12 principles of Green Chemistry; these folks thought Green Chemistry was synonymous with Sustainability, itself an undefined term.

Truly:  no definition is correct until we define these terms once and for all, and then continue to define our terms consistently as we go along.  Upshot:  the conference collateral and agenda should have defined Green Chemistry on every page.  In fact, every Sustainability conference or paper ought to do the same until we all know the definitions without thinking.

With that said, we can only applaud IPC for its sensible call for definitions of “green electronic product,” as the term will be used in the new national framework for electronics stewardship.

IPC’s letter to EPA on electronics stewardship. The IPC letter articulated that before developing a framework for electronics stewardship, the EPA ought to establish a definition for a green electronic product. Defining a green electronic product, it said, ensures that all impacted stakeholders will be working from a common starting point. Yes!

There is no need to recreate the entire document here, but there is a second particularly relevant point:  the need to consider the fact that some attributes may be less damaging to the environment in one way, say sourcing or end of life, but be more damaging in another way such as in processing emissions and waste. In IPC’s words:

For example, as shown in EPA’s lead-free solder study, the substitution of tin-lead solder for lead-free solder resulted in increased energy use associated with the higher operating temperatures required for manufacturing electronics with lead-free solder.  This increase in energy use was projected to cause higher air pollution, acid rain, stream eutrophication and global warming impacts.

That study serves as an important reminder that there are environmental trade-offs when substituting one substance for another. The EPA must lead the way in determining what attributes are of most importance in defining a “green electronic product.”

IPCs letter is signed by Stephanie Castorina, manager, Environmental Programs for IPC.  The entire document may be viewed here.

Green manufacturing index. Perhaps a hierarchal, ranked, feature set matrix would be a good start.  If the major electronics associations, industry consortia, EPA, and the new Task Force for Electronic Stewardship could agree on a ranking system to establish a green index in manufacturing, that index could be used to determine and define “green electronic products,” also to ensure that one evil wasn’t swapped for another.

With a Green Manufacturing Index we could move forward with a unified theory of electronics recycling, which would simplify a lot of things. Stay tuned.