1. World Semiconductor Council EHS-PFOA
February 21 & 22, 2011

2. PFOA Definition
PFOA: Perfluorooctanoic acid is a fully fluorinated, eight-carbon chain carboxylic acid (C8) (CAS RN ) sometimes used to refer to the anionic salt form.
PFOA-related: Chemicals which may be salts of PFOA or chemicals that can degrade to PFOA. These related chemicals include, but are not limited to: carboxylates, amines, ethers, iodides, phosphonic/phosphinic compounds, alcohols, esters, phosphates, sulfonates, siloxanes, thioethers, urethanes, and acrylates

3. U.S. EPA Long-Chain Perfluorinated Chemicals (PFCs) Action Plan
The long-chain PFCs comprise two sub-categories: perfluoroalkyl sulfonates (PFAS) and perfluoroalkyl carboxylates (PFAC).
The PFAS sub-category includes perfluorohexane sulfonic acid (PFHxS), perfluorooctane sulfonic acid (PFOS), other higher homologues, and their salts and precursors.
The PFAC sub-category includes perfluorooctanoic acid (PFOA, sometimes called C8), other higher homologues, and their salts and precursors.
Some of those potential PFAC precursors include chemicals known commercially as fluorotelomers.

4. U.S. EPA Long-Chain Perfluorinated Chemicals (PFCs) Action Plan
“Since 2000, the Agency has taken various actions to help minimize the potential impact of PFCs on human health and the environment, including the publication of three Significant New Use Rules on perfluoroalkyl sulfonate (PFAS) chemicals and the review of substitutes for long-chain PFCs as part of its review process for new chemicals under EPA's New Chemicals Program. Although such actions are important steps to reducing exposure to these chemicals, EPA continues to be concerned with long-chain PFCs. Consequently, EPA intends to propose actions in 2012 under the Toxic Substances Control Act (TSCA) to address the potential risks from long-chain PFCs.”
“A rule addressing the PFAS sub-category could expand beyond the reach of the SNURs that the Agency has promulgated over the past decade. For example, the rule could address PFAS-containing articles. A rule addressing the perfluoroalkyl carboxylate (PFAC) sub­category could expand the reach of the 2010/15 PFOA Stewardship Program beyond the eight participating companies and further address the concerns for potential PFAC exposure through the use of PFAC-containing articles.”

5. U.S. EPA Long-Chain Perfluorinated Chemicals (PFCs) Action Plan
“Since 2000, the Agency has taken various actions to help minimize the potential impact of PFCs on human health and the environment, including the publication of three Significant New Use Rules on perfluoroalkyl sulfonate (PFAS) chemicals and the review of substitutes for long-chain PFCs as part of its review process for new chemicals under EPA's New Chemicals Program. Although such actions are important steps to reducing exposure to these chemicals, EPA continues to be concerned with long-chain PFCs. Consequently, EPA intends to propose actions in 2012 under the Toxic Substances Control Act (TSCA) to address the potential risks from long-chain PFCs.”
“A rule addressing the PFAS sub-category could expand beyond the reach of the SNURs that the Agency has promulgated over the past decade. For example, the rule could address PFAS-containing articles. A rule addressing the perfluoroalkyl carboxylate (PFAC) sub­category could expand the reach of the 2010/15 PFOA Stewardship Program beyond the eight participating companies and further address the concerns for potential PFAC exposure through the use of PFAC-containing articles.”

6. Typical Lithography Process Life Cycle
Chemicals arrive at Receiving 1
Chemicals placed in Secure Storage
Rooms 1
Chemicals Delivered
to Tool via Dispense
Units 2
ARC / Coat Modules and Wet Strip to Solvent Exhaust  Thermal Oxidizer
TARC/Develop/Etch/Ash to Scrubbed Exhaust
ARC applied
via
Spin Coating 3
Resist applied via Spin Coating 4
Top ARC
Applied 5
Pre-expose Bake 6
Expose 7
Post-expose Bake 8
Develop 9
ARC, Resist and Wet Strip Wastes To Solvent Waste Tank  Disposed via Fuel Blend/Incineration
Developer and TARC Wastes to IW Drain
Chemical Receiving/Storage
Etch/Ash
Etch/Ash 10
Wet Strip 11
Chemical Delivery/Dispense
Wet Strip
Process may or may not be utilized
Lithography Process Steps
Effluents

7. PFOA Uses in Semiconductor Manufacturing
Based on JSR chemical knowledge of the photolithography process, we suspect PFOA could be used as a surfactant or a monomer of a long chain polymer in the following process areas:
Top or Bottom Antireflective Coatings-Surfactant
Photoresists- Surfactant and/or Polymer
Developer- Surfactant
Etchants-Surfactant
Edgebead removers-Surfactant
Wet Strip- Surfactant

8. JSR PFOA Uses in Semiconductor Manufacturing
JSR has used PFOA materials in Top Antireflective Coating (TARC) as a surfactant and in older generation I-Line Photoresist.
JSR performed an exhaustive search throughout all of our production chemicals and does not use PFOA in any new chemicals.
JSR Corp does not allow development of new chemicals that contain PFOA or PFOS.
JSR supports existing customer uses of existing technology nodes that contain PFOA and PFOS.
JSR believes that our competitors have followed this approach to PFOA and PFAS but it is unconfirmed
Mitsubishi Chemicals announced the end of PFOS production in 2008

9. JSR Policy Change for Global Compliance of EHS regulations
EHS screening was implemented in design review system from the beginning of material development in R&D stage (Stage Gate)
JSR Corporation (Japan) HQ EHS group was centered in responsibility of compliance to Global EHS regulations.

10. JSR Stage Gate System for New Products
Stage at Customer
JSR Business Stage
R&D  Production Transition
Design Review
EHS check items
Research
Discovery
Feasibility 1
-Production regulations
-Product liability
Development
Feasibility 2
Business Establishment
Manufacturing
Deployment
Production
-Process risk assessment
-Process changes I.e. raw material supplier change
Research
DR-1
Development
DR-2A
Sample provided to customer
-Inventory check (including impurities)
-Global regulation check
-Hazard and toxicity check
DR-2B
POR / Baseline
Selection
Repeat sample evaluation by customer
DR-2C
T-1
DR-3
-Process risk pre-assessment
-Review of DR-2(A,B,C)
T-2
T-3, T-4
HVM
DR-4

11. EHS Check Process Table
EHS check item
Confirmation item
After confirmation
DR-1
-Production regulations
-Product liability
-Confirmation of production regulations
-Product liability check prior to designing based on customer requirements.
-R&D can start designing in lab.
DR-2 (A,B,C)
-Global inventory check
（improved system)
-Check global existing chemicals lists.
-The substances which are not listed on inventory are registered.
-Global regulation check
-Check global regulations for designed samples.
-R&D group can export conforming samples.
-HQ can provide MSDS.
-Hazard and Toxicity check
-Check hazard and toxicity of designed samples.
DR-3
-Production process risk assessment
-Check production process risks prior to a scale-up manufacturing test.
-The plant can start a scale-up manufacturing test.
DR-4
-Safety review of scale-up test
-Process Chnages
-Check safety of scale-up test.
-Check raw material process changes
-The plant can start high volume manufacturing.
-Ensure that internal proccess change do not effect HVM

12. Global Regulation Investigation
Nation or Region
Regulation
USA
OSHA HAZARD COMMUNICATION STANDARD, 29 CFR ; CERCLA/SUPERFUND HAZARD CATEGORY;SARA 313 INFORMATION;TOXIC SUBSTANCES CONTROL ACT (TSCA)
CALIFORNIA PROPOSITION 65;TRANSPORTATION AND HAZARDOUS MATERIALS DESCRIPTION
U. S. DOT PROPER SHIPPING NAME;IATA PROPER SHIPPING NAME; IDENTIFICATION NUMBER(UN#) STATE AND LOCAL ENVIRONMENTAL REGULATIONS; RCRA HAZARDOUS WASTE REGULATIONS;CLEAN WATER ACT; CLEAN AIR ACT EU
Directives 67/548/EEC & 1999/45/EC
UN number, CLASS, PROPER SHIPPING NAME, Packing group, EINECS#
Marine Pollutant
Korea
Hazardous chemical substance control act, Industry safety and health law, ECL#
Taiwan
Occupational safety and health law, toxic substance list
China
Hazardous chemical substance control act, Existing chemical substance list
Malaysia
Poisons Act, Occupational Safety and Health Act
Singapore
Factories Act
JAPAN
Chemical substance control law, Safety and health law, Poisonous material control law, Fire production law, etc.

13. JSR EHS check system Improvements
All new chemical substances (including impurities) are investigated at the first stage of R&D.
Improved System
System before improvement 1
In the new system, all new raw materials including their impurities are thoroughly investigated. The R&D group identifies new chemicals and impurities in chemical substance table and specifies the countries to which the sample is exported. The R&D group then informs of the new chemicals to the safety group on weekly report.
In the old system, the JSR R&D didn’t check new chemicals beyond their knowledge. 2
In the new system, new chemical substances are checked against global regulations. JSR Corp (HQ) checks the regulations, and INC/NV (local offices) confirm them. If the new chemical substance is not listed on inventory, JSR Corp/INC/NV start a registration process based on local laws and regulations.
In the old system, the responsibilities weren’t clear. 3
A strong communication system between three JSR sites (INC(USA),NV(EU), JSR Corp (Asia)) was established to improve regulation check and information sharing.
EH&S involved with the approval of process changes after HVM has started
The communication system between three JSR sites was weak.
EH&S was not involved in process changes or approvals

14. EHS check during process change
product
Stage
EHS check
New product
Design review
HVM
Chemical substance table created (including impurities)
Inventory check, regulation check, hazard and toxicity check.
Ongoing process changes
Process change check and approval
HVM
EHS checks and approves
- When there is a process change made to an existing product, EHS will ensure that the product after process change conforms to laws and regulations.
- JSR purchase contracts to suppliers saddle notification of change control in their production. Periodic audit to suppliers also encompass any process changes affect to EHS concerns.
- EH&S Group must sign off for any changes
EHS communication with specialized groups

15. Communication System for Global Regulation Check
INC
USA
　Consultant/Lawyer:
　Consultant/Lawyer:
EHS information sharing system
Consultant/Lawyer:
Korea: Chemtopia
Taiwan: Lee and Lee
Singapore & Malaysia: Rodyk & Davidson Gerald 　 China: Chemical Industry Information Center
Corp
Asia NV EU
Corp investigates the regulations in the USA & EU.
INC & NV confirm the investigation results.

16. Next Steps for IC Manufactures and PFOA
Form a Industry coalition of the IC manufactures and the Chemical Suppliers across the supply chain
Perform a complete survey of