This scares the hell out of me. But it is not surprising. There are just
so many things I would want to warn EMPF about even attempting to do
this.
But based on past history, I have learned you cannot tell them anything
they do not want to hear.
Here are the questions I have after reading the article:
1. If military hardware is already exempt, why the hell are they even
trying to do this?
2. Do they understand that just because they come up with a process that
"will document the electronics manufacturing processes requirements
needed to produce hardware which meets IPC J-STD-001C Class 3 and
IPC-A-610 Class 3 specifications" only means they can meet quality
standards, not necessarily reliability requirements?
3. "It is inevitable that military and aerospace hardware will be forced
by sheer commercial availability to manufacture with Lead Free solders
and materials." Sez who? EMPF? What preposition is such a ridiculous
statement based on?
4. It is ironic that the "no Pb" symbol should be used on this article,
because this really is a Pork Barrel project if I ever saw one.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: Thursday, November 02, 2006 12:55 PM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
So we should be through this by about 2010.......8-)
What really worries me is this item:
http://www.empf.org/programs/leadfree.htm
My personal opinion is that if you take a military weapons system
(fighter aircraft etc) and make it lead free the safest place to be in
order of preference would be:
1 A long way away from it
2 Above it
3 Behind it
John
John
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner
Sent: Thursday, November 02, 2006 10:37 AM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
And the written-off parts get sold to brokers, and they sell them to
other brokers, and so on, and eventually somebody remarks them and
counterfeits the packaging to identify them as compliant so they can
sell them so some poor soul desperate for allocated compliant parts...
Mike
-----Original Message-----
From: Timothy McGrady [mailto:[log in to unmask]]
Sent: Thursday, November 02, 2006 10:24 AM
To: [log in to unmask]; (Leadfree Electronics Assembly
Forum)
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
Mike:
Yes, I agree, the mixing of parts has been a big problem. Some
companies have written off entire inventories of non-compliant parts for
just that reason.
Tim
----- Original Message -----
From: "Michael Kirschner" <[log in to unmask]>
To: "Timothy McGrady" <[log in to unmask]>; "(Leadfree Electronics
Assembly Forum)" <[log in to unmask]>
Sent: Thursday, November 02, 2006 12:56 PM
Subject: RE: [LF] EU Not Busting for RoHS Violations Yet
> Tim,
>
> Excellent point regarding standards. Unfortunately we are generally
> seeing just the opposite occur around the world: regulations beget
> standards rather than the other way around. Having the standard in
> place first ensures that industry understands how to actually
> accomplish something and can actually do it.
>
> In my humble opinion the primary risk for one of the big companies
> likely to be a target is the production problem of mixed parts, rather
> than improper or inadequate testing (I absolutely agree there are labs
> that are not using the right tests out there; but I think that's a
> second order issue). There have been, and continue to be, many reports
> of not-compliant parts shipping as, being stocked as, or being used as
> compliant parts.
>
> Mike
>
> -----Original Message-----
> From: Timothy McGrady [mailto:[log in to unmask]]
> Sent: Thursday, November 02, 2006 9:16 AM
> To: (Leadfree Electronics Assembly Forum); Mike Kirschner
> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>
>
> Thanks for that link, Mike.
>
> When an enforcement authority finally does make the decision to go
> ahead with a prosecution, they better make sure they've done their
homework.
> There are very few standard methods for analysis of RoHS substances
> and there are few reference materials with which to validate those
methods.
> That is not to say they cannot come up with a solid case - I'm saying
> that they should chose that case wisely and make sure they can support
> their findings with solid, validated methodology. It will have to be
> a "no brainer" - an obvious violation. But of course, the EU would
> prefer to catch a high-profile company in non-compliance. And it is
> likely they want to catch a company originating in a developed nation
> such as Japan or the US - picking on a developing nation might not sit
> right with public opinion.
> That might not be so easy, given the amount of attention paid to RoHS
> by the big boys. None of them wants to be the next Sony, and they
> certainly do not want their company name or product name in the media.
>
> That being said, there has been a lot of testing done using methods
> that are inappropriate and can result in false negatives. So there's
> a chance that a relatively big company placed faith in a lab or used
> inappropriate methods themselves to overcheck results from independent
> labs. Even so, there's also a good chance that EU enforcement
> authorities will also use inappropriate methods to determine
> non-compliance (or conversely, compliance). The lack of properly
> developed standards hurts all involved:
> enforcement authorities and producers alike. That is why standards
> must be in place before technical legislation such as RoHS go into
> effect.
>
> The example I use to illustrate this problem concerns a government
> developing a regulation stating that all children age 14 and under
> must wear a helmet while riding a bicycle. Let's say that no
> standards for helmets were developed prior to the regulation going
> into force. A kid is observed riding a bicycle wearing a baseball
> cap. Is that kid in violation of the law? Not without a standard
> defining a helmet and laying out the technical requirements necessary
> to protect the head in case of an accident. Now let's say the
> givernment developed extensive requirements for the helmet and a
> standards development body developed a standard for such helmets. The
> resulting helmet would protect the head in every case, but it would
> cost $2000. Would it be fair to expect a poor child riding a cheap
> bike to wear a $2000 helmet? Again, the answer is no. But if the law
> went into effect, there would likely be plenty of violations to go
> around. Fakes of standard helmets would quickly become available. In
> that case, the government should have taken their requirements to the
> standard developers and experts and get their feedback before putting
> the law on the books. If the law was too costly to implement, the
> regulation would have to be altered. In either case, it is necessary
> to have standards developed prior to the regulation going into force.
>
> That is why the World Trade Organization Technical Barriers to Trade
> Agreement (TBT) is so important. Here is a quote from the TBT:
>
> "
> With respect to their central government bodies:
>
> 2.1 Members shall ensure that in respect of technical regulations,
> products imported from the territory of any Member shall be accorded
> treatment no less favourable than that accorded to like products of
> national origin and to like products originating in any other country.
>
> 2.2 Members shall ensure that technical regulations are not prepared,
> adopted or applied with a view to or with the effect of creating
> unnecessary obstacles to international trade. For this purpose,
> technical regulations shall not be more trade-restrictive than
> necessary to fulfil a legitimate objective, taking account of the
> risks non-fulfilment would create. Such legitimate objectives are,
> inter alia: national security requirements; the prevention of
> deceptive practices; protection of human health or safety, animal or
> plant life or health, or the environment. In assessing such risks,
> relevant elements of consideration are, inter alia: available
> scientific and technical information, related processing technology or
> intended end-uses of products.
>
> 2.3 Technical regulations shall not be maintained if the circumstances
> or objectives giving rise to their adoption no longer exist or if the
> changed circumstances or objectives can be addressed in a less
> trade-restrictive manner.
>
> 2.4 Where technical regulations are required and relevant
> international standards exist or their completion is imminent, Members
> shall use them, or the relevant parts of them, as a basis for their
> technical regulations except when such international standards or
> relevant parts would be an ineffective or inappropriate means for the
> fulfilment of the legitimate objectives pursued, for instance because
> of fundamental climatic or geographical factors or fundamental
> technological problems.
>
> 2.5 A Member preparing, adopting or applying a technical regulation
> which may have a significant effect on trade of other Members shall,
> upon the request of another Member, explain the justification for that
> technical regulation in terms of the provisions of paragraphs 2 to 4.
> Whenever a technical regulation is prepared, adopted or applied for
> one of the legitimate objectives explicitly mentioned in paragraph 2,
> and is in accordance with relevant international standards, it shall
> be rebuttably presumed not to create an unnecessary obstacle to
international trade.
>
> 2.6 With a view to harmonizing technical regulations on as wide a
> basis as possible, Members shall play a full part, within the limits
> of their resources, in the preparation by appropriate international
> standardizing bodies of international standards for products for which
> they either have adopted, or expect to adopt, technical regulations.
>
> 2.7 Members shall give positive consideration to accepting as
> equivalent technical regulations of other Members, even if these
> regulations differ from their own, provided they are satisfied that
> these regulations adequately fulfil the objectives of their own
regulations.
>
> 2.8 Wherever appropriate, Members shall specify technical regulations
> based on product requirements in terms of performance rather than
> design or descriptive characteristics.
>
> 2.9 Whenever a relevant international standard does not exist or the
> technical content of a proposed technical regulation is not in
> accordance with the technical content of relevant international
> standards, and if the technical regulation may have a significant
> effect on trade of other Members, Members shall:
>
> 2.9.1 publish a notice in a publication at an early appropriate
> stage, in such a manner as to enable interested parties in other
> Members to become acquainted with it, that they propose to introduce a
> particular technical regulation;
>
> 2.9.2 notify other Members through the Secretariat of the products to
>be covered by the proposed technical regulation, together with a brief
>indication of its objective and rationale. Such notifications shall
>take place at an early appropriate stage, when amendments can still be
>introduced and comments taken into account;
>
> 2.9.3 upon request, provide to other Members particulars or copies of
> the proposed technical regulation and, whenever possible, identify the
> parts which in substance deviate from relevant international
> standards;
>
> 2.9.4 without discrimination, allow reasonable time for other Members
> to make comments in writing, discuss these comments upon request, and
> take these written comments and the results of these discussions into
account.
>
> 2.10 Subject to the provisions in the lead-in to paragraph 9, where
> urgent problems of safety, health, environmental protection or
> national security arise or threaten to arise for a Member, that Member
> may omit such of the steps enumerated in paragraph 9 as it finds
> necessary, provided that the Member, upon adoption of a technical
regulation, shall:
>
> 2.10.1 notify immediately other Members through the Secretariat of
> the particular technical regulation and the products covered, with a
> brief indication of the objective and the rationale of the technical
> regulation, including the nature of the urgent problems;
>
> 2.10.2 upon request, provide other Members with copies of the
> technical regulation;
>
> 2.10.3 without discrimination, allow other Members to present their
> comments in writing, discuss these comments upon request, and take
> these written comments and the results of these discussions into
account.
>
> 2.11 Members shall ensure that all technical regulations which have
> been adopted are published promptly or otherwise made available in
> such a manner as to enable interested parties in other Members to
> become acquainted with them.
>
> 2.12 Except in those urgent circumstances referred to in paragraph 10,
> Members shall allow a reasonable interval between the publication of
> technical regulations and their entry into force in order to allow
> time for producers in exporting Members, and particularly in
> developing country Members, to adapt their products or methods of
> production to the requirements of the importing Member."
>
> The EU has always argued that because their regulations such as RoHS
> are for protection of human health and the environment and because
> they impact their companies in the same way as they impact importing
> companies, there cannot be a trade barrier (see paragraphs 2 and 5
> above). But paragraph 2 can be argued in the case of RoHS. I contend
> (as I think many of you do) that RoHS is much more trade restrictive
> than necessary, taking into account the actual impact the directive
> will have on human health and the environment.
> Had the proper standards been in place, billions of dollars would have
> been saved. If RoHS had not been implemented or had been delayed, I
> doubt many lives would be negatively impacted, if any at all. In
> fact, the argument can be made that RoHS can negatively impact human
> health, because there is high probability that a safety related part
> or system will fail due to the wholesale redesign of products and
> materials.
>
>
>
> Tim McGrady
>
>
> ----- Original Message -----
> From: "Mike Kirschner" <[log in to unmask]>
> To: <[log in to unmask]>
> Sent: Thursday, November 02, 2006 12:05 AM
> Subject: [LF] EU Not Busting for RoHS Violations Yet
>
>
>> Rob Spiegel spoke, at our behest, to Steve Andrews to get a clear
>> response on why we haven't seen any visible cases of non-compliance
>> in the EU yet.
>> He
>> has more credibility on this topic than just about anyone, even DCA
>> ;o)
>>
>> You can read his story, entitled "EU Not Busting for RoHS Violations
>> Yet", at
>>
>> http://www.designnews.com/article/CA6387098.html
>>
>> So the bottom line is that they're trying to find that first case to
>> go public with.
>>
>> Mike Kirschner
>> Design Chain Associates, LLC
>>
>> ---------------------------------------------------------------------
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>
>
>
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