the lead ban in solder, without appearing to do so.  

It's going to be an environmental nightmare because of increased mining
and shortened product life leading to more waste.  It's going to be an
enforcement nightmare because of the temptations to cheat by smaller
companies that can't afford lead-free and by many companies who care about
serving their customers with reliable equipment.  Sooner or later, there
will be embarrassing lawsuits, that will blow the lid on the unthinking
way the lead ban was incorporated in RoHS with no attempt to balance risk
versus reward.

Here are 3 ways that the EU can put things right without admitting a
mistake:
1. Raise the limit for lead in homogeneous material or just for printed
circuit board assemblies, from 0.1% to 5%.
2. Require vendors of equipment who exceed limits for lead to be
responsible for recycling that lead.
3. Exempt printed circuit board assemblies from the lead ban.

The last is essentially John Burke's Stakeholder Application #15 now on
the EU's table for consideration, signed on to by over 300 engineers from
all over the world.

Harvey Miller

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