SIA ISSUE BACKGROUNDERS

ENVIRONMENTAL MANAGEMENT

Issue: Environmental Management has become an important factor in the production and delivery of semiconductor components to end users. Considerations include the traditional issues of controlling and minimizing waste products from manufacturing, as well as the issue of meeting customer expectations that the products they purchase will meet their requirements for environmental soundness

Importance: The SIA offers a unique forum for addressing environmental issues that may impact manufacture or sale of semiconductors domestically and internationally. The key SIA committee for Environmental Management is the Environment Committee, made up of senior technical and management representatives from SIA member companies and charged with reviewing domestic and international environmental issues. Based on its assessment, sub-teams are established to bring focused, central response to identified issues, allowing issues to be addressed by SIA as an organization and avoiding the need for companies to address issues individually. This process is an effective way to deal with common issues from the standpoint of cost effectiveness and identification of consistent, consensus approaches.

SIA Position/Action: Among our key initiatives are the following:

• Voluntary agreement to reduce emission of PFC's: Perfluorocarbons (PFC’s) find widespread usage in the production of semiconductor devices, both as source gases for plasma etch and for cleaning deposition chambers. After losing chlorofluorocarbons (CFC’s) through an international regulatory edict, the industry was faced with the potential loss of  another key manufacturing chemical.  SIA companies forged a voluntary agreement with the USEPA which enabled the industry to continue its use of PFC’s, while at the same time committing to a reduction program which targets the reduction of PFC emissions by 2010 to a level 10% below the level of emissions in 1995.  This represents an on-going effort on the part of SIA, which includes annual submission of aggregate emission data to the EPA.  In conformance with another MOU requirement, in 2005 International SEMATECH under the guidance of SIA MOU Partners will prepared a state of the technology report which was provided to the USEPA.  This report describes how the industry is using cost effective new technology to meet the MOU PFC Emission Reduction Goal. Emission results to date indicate that the SIA PFC Emission Reduction Partnership is performing better than expected against the industry goal. In fact, as of the 2005 data recently compiled and sent to the USEPA, SIA Partners are 22% below the 2010 target.  SIA members worked with the Intergovernmental Panel on Climate Change (IPCC) to update the PFC emission inventory process to better reflect methods underway to reduce PFC emissions.  It is expected that the new methodology published late last year will be incorporated into the WSC PFC annual emission reporting process.  Additionally, in accordance with a decision made by the WSC, SIA has been posting the WSC PFC Emission Reduction data, indexed to the baseline year on its public website on an annual basis.
  
  
• Copper: The advent of chemical mechanical planarization (CMP) and the use of copper for the interlayer conductor material resulted in a need to redefine how discharge of copper from plating and CMP was interpreted by the EPA. Typically, these types of wastes would be considered as metal finishing, in spite of their application to semiconductor manufacturing. As metal finishing wastes, it would have been extremely difficult to meet discharge requirements under the Clean Water Act. However, through a concerted company information gathering effort about the processes in question and the amount of copper waste generated, SIA was able to convince EPA that this process was truly semiconductor manufacturing and not metal finishing. EPA issued an interpretive guideline which noted that waste discharges from semiconductor manufacturing processes containing copper were considered to fall under the semiconductor effluent guideline (which does not have a copper limitation) and not metal finishing.
  
  
• Environmental Metrics Program: SIA, through its Environment Committee, has established an Environmental Metrics Program which now includes 17 companies and 40 facilities. The parameters being benchmarked are as follows:
  • Total water supplied
  • Total ultrapure water used
  • Hazardous waste generated
  • VOC emissions
  • Electricity used
    

  This information can be used by member companies for comparative purposes with others engaged in similar activities and for comparison with international operations. This information, in part, is also contemplated for potential use by SIA in development of quantitative targets under the World Semiconductor Council ESH program.

• Perfluorooctyl Sulfonates/Perfluoroalkyl Sulfonates (PFOS/PFAS): In late 2000, SIA became aware of an effort on the part of the EPA to ban the production and importation of PFOS/PFAS materials through the Significant New Use Rule (SNUR) process, based the allegation that they were persistent bioaccumulative toxics (PBTs).  These materials are critical constituents of leading edge photoresists (photoacid generators and surfactants) and anti-reflective coatings.  Faced with the threat of losing these materials, SIA formed a team of technical and non-technical (e.g. legal, public policy, and communications) participants to address the issue promptly.  Early in the process, it was decided to join with SEMI and the affected photoresist manufacturers to work together to address this critical issue with the EPA.  Through the efforts of this partnership, a number of significant inputs were provided to the EPA, including the following:
  
  
  • Verification of the criticality of these materials, including socio-economic impact
  • Verification of limited quantities used
  • Demonstration of environmental control and management
  • Verification that employees were not exposed
  • Provision to the EPA of a mass balance model for evaluating the environmental impact of chemicals.
    

  As a result of this cooperative effort, EPA was able to do the following:

  • Reinstitute Low Volume Exemption process for introducing new PFOS/PFAS chemicals
  • Include an exemption for photolithography applications when the final SNUR was published in December, 2002
  • Champion the use of the mass balance model in international activities such as Organization for Economic Cooperation and Development (OECD) as a means of evaluating materials believed to be persistent, bio-accumulative and toxic (PBT).

  Currently, the industry is joining with SEMI under the leadership of ESIA to address a new challenge to the use of PFOS in critical lithography applications.  This time, the challenge is coming from Europe, in particular from the UK, where banning of PFOS is being considered.   This new coalition is in the process of providing input to proposed European Union activities with an expectation that an understanding similar to the one reached in the U.S. can be reached.  PFOS action is also being reviewed at the WSC level.  Each association was charged with evaluating a proposed voluntary commitment to eliminate the use of PFOS in non-critical photolithography applications and to expedite its elimination in critical applications.  After much review and discussion, the WSC approved a Voluntary Semiconductor Industry Commitment at its May, 2006 meeting in San Francisco.  Further discussion of the commitment can be found in the WSC update.

Going Forward: SIA's Environment Committee continues to focus on chemical issues with global significance. In particular, the SIA is following and providing input on behalf of the US semiconductor industry on the following issues:

• The European Chemicals Policy (REACH) and its potential impact on products sold in Europe;
  
  
• A new effort was undertaken in 2003 to standardize requirements posed to the industry with respect to hazardous constituents in semiconductor products, through the use of a uniform materials declaration. This Materials Composition Declaration Guideline program was adopted globally in mid-2005. Currently, the association is joined with other associations in trying to identify a database approach for accumulation of composition data;
  
  
• Activities related to the potential regulation of PFAS and Perfluorooctanoic Acid and its Salts (PFOA);
  
  
• Harmonization of domestic and worldwide RoHS-like programs in support of the European RoHS;
  
  
• The SIA is taking a leadership role in a new program which would support China's State Environmental Protection Administration (SEPA) efforts to bring existing worldwide regulatory standards to China's electronics industry by mid-2006.
  
  
• SIA has also become active, along with ESIA, SEMI and, most recently, JSIA, in trying to keep PFOS from being regulated out of existence through world-wide POPs (persistent organic pollutants) programs including the Stockholm Convention and LRTAP (Long Range Trans-boundary Air Pollution) Convention.