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March 2010

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Subject:
From:
Bob Landman <[log in to unmask]>
Reply To:
Bob Landman <[log in to unmask]>
Date:
Tue, 16 Mar 2010 11:01:53 -0400
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John,

Thanks for the reply.  I didn't intend to trash NIST so please forgive me if that appeared to be the case. NIST (and NBS) and I go back a long ways.  I was active in SEMI for many years.  I know the fine work the agency does (have toured NBS/NIST labs in MD and CO). 

I meant more specifically the Dept of Commerce and other Federal agencies - State in dealing with the EU, EPA for not standing on their own feet, Defense for not knowing soon enough what impact of RoHS would be, etc. 

You mentioned that "high reliability electronics requirements of the aerospace community where they still demand some Pb in their solder, and the absence of pure Sn, Zn, and Cd coatings."  What about the many other industries who need it, such as implanted medical devices, nuclear power plants, atomic bombs? (if the world's atomic arsenal goes lead-free.....)  
 
I did wonder (hence why I asked what NIST did when the EU proposed the lead ban) what our nations first national laboratory in the physical science of materials, did when the EU proposed to remove lead as surely NIST knew that would have profound affects on American manufacturers?
 
Did NIST advise the Commerce Dept Secretary that it was a very bad idea and would cripple our defense and industry?  That it was a ticking time bomb (as Toyota may finally illustrate)?   
 
I read this page at NIST today http://www.metallurgy.nist.gov/solder/  I don't see the words "tin whiskers" anywhere yet I know Maureen Williams is studying them. Where is it stated that the agency has concerns similar to NASA (who has done a fantastic job of being the resource on the subject?  NASA is very clear where they stand.  What is NIST's position on the technology?

Did NIST tell Commerce, Congress, the White House and the DoD that it was a very bad idea to go no-lead and that FIRST the R&D has to be done THEN the solders are used, not the other way around and that NIST would do the R&D with industry THEN it would be safe to proceed?  

The EU has it bass-awkward, so it seems to me, don't you agree?  Who in government then has the responsibility to raise the alarm if it's not NIST?
 
Your mission on the website says:
 
Founded in 1901, NIST is a non-regulatory federal agency within the U.S. Department of Commerce. NIST's mission is to promote U.S. innovation and industrial competitiveness by advancing measurement science, standards, and technology in ways that enhance economic security and improve our quality of life.
 
If NIST didn't speak out, then NIST didn't follow it's mission, to "help our economic security and quality of life", don't you agree?

Sincerely,

Bob Landman
H&L Instruments, LLC


-----Original Message-----
From: Sieber, John R. [mailto:[log in to unmask]] 
Sent: Monday, March 15, 2010 9:45 AM
To: (Leadfree Electronics Assembly Forum); Bob Landman
Subject: NIST Role in

This is in response to Mr. Landman's question about NIST, which was embedded in his statement that he has heard DoC has been of little help in dealing with EU environmental and chemical safety regs.

My goal is to provide information about NIST activities in which I participated over the past six years.  NIST is a technology agency with a mission to help U.S. companies, agencies, etc. meet the measurement challenges they face.  In addition to our science and reference materials programs, we get involved in international standards development, and we provide technical consultation to all parties involved in development of regulations.  My involvement has been mostly with RoHS-type regulations as I am an analytical chemist specializing in inorganic chemical metrology (XRF primarily, but my team also includes various ICP, GD, and IC methods).  I am a US Expert in the US Technical Advisory Group to IEC TC111.  I am a co-author of IEC 62321, the test methods standard for RoHS-type measurement requirements.  I am also a charter member of ASTM International Committee F40 chaired by McGrady.  The US TAG to TC111 is managed by NEMA and meets at the NEMA offices in Rosslyn, VA once a year, in addition to our many conference calls.  The activities of the US TAG to TC111 are a good way for any organization to become involved in the technical aspects of dealing with RoHS, REACH, and the other international regs.  I can provide contact information to interested parties.

In all these capacities, I have provided technical input to the activities of the DoC International Trade Administration (ITA) and to the office of the US Trade Representative at the White House.  My colleague Eric Simmon of the NIST Electronics and Electrical Engineering Laboratory, has joined me in this advisory role.  Throughout, we have been guided by the NIST Standards Services Division.  In our advisory capacity to DoC ITA, Eric and I have been able to provide information on the difficulties of making measurements and the complexities of documenting compliance.  Eric is an active member of IPC and has done much to develop IPC standards and to harmonize them with similar standards from other nations and regions.  I have tried to provide DoC and others with a basic understanding of the number and complexity of tests necessary to perform due diligence and to minimize risks to a corporation, plus the availability of tools needed to accomplish the analysis jobs.  Some of these discussions have been open to representatives of affected businesses.  In addition, NIST has hosted technically oriented public meetings in Gaithersburg, MD so that we may learn about the technical needs of US manufacturers.

Armed with this knowledge, we are able to contribute to IEC, IPC and ASTM standards and to develop certified reference materials for validation of the test methods included in the standards.  A few years back, I covered the applicability of existing NIST SRMs to RoHS in an article in American Laboratory News.  Since 2007, I have been the project leader for development of SRM 1124 Free-Cutting Brass containing RoHS elements and SRM 1728 Sn-Ag-Cu Solder (Pb-free), both of which will be available this year.  One of the newest SRM projects is SRM 1729 97Sn-3Pb alloy for the high reliability electronics requirements of the aerospace community where they still demand some Pb in their solder, and the absence of pure Sn, Zn, and Cd coatings.  Other new projects include Pb in paint for children's products and restricted elements in PVC, both sponsored by the US Consumer Product Safety Commission, to help deal with the CPSIA law enacted in 2008. This is just the inorganic side.  Our Organic Chemical Metrology experts have contributed to measurement science of brominated flame retardants, and all the chlorinated compounds that have made it into the environment, to name just two topics.

There are other NIST activities with bearing on RoHS, etc.  The NIST Materials Science and Engineering Laboratory has long been involved with issues of solder composition (the name Handwerker was in a recent posting), and I think they continue to have a role in association somehow with iNEMI activities.  There is also the Manufacturing Extension Partnership, which has extension offices across the nation.  They are now expanding their presence in Detroit as a pilot of a larger role across the country.  Check out our website at www.nist.gov/.

In closing, let me emphasize again that NIST has a technical role (did I use that word enough already?) that includes development of reference materials, standards for test methods and data handling, and provision of technical advice to other government agencies at their request.  In this message, I've tried to give you the flavor of my involvement in such things.  I monitor this email discussion group because it offers an opportunity for a chemist to monitor technical discussions in areas where I have no expertise.

Sincerely,

John Sieber
NIST Analytical Chemistry Division





-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bob Landman
Sent: Saturday, March 13, 2010 6:21 PM
To: [log in to unmask]
Subject: Re: [LF] More importantly.... 8 new substances proposed for REACH control

Incredible tale Tim, all the more so as Chris Robertson's group, for all your efforts, was unaware of your sound, science-based protestations (not that it was his fault, rather it was the bureacracy that did not disseminate your critique).

Would you do that level of effort again? I'm sure the cost to your company was not insubstantial.

 From what I've heard from Gordon Davy, the US Dept of Commerce was of little help (did that includes NIST)?

What was your impression of Commerce's role as the EU brought forth these regulations?  Did they try to dissuade their Euro counterparts or did they do as they did with CEMark, simply accept what was proposed?

I found that my local Commerce rep told me I had no choice but to comply with whatever was proposed, that they could not even help me get a ruling on exemptions.  That our products did not fit the categories was not her problem.

Bob Landman
H&L Instruments, LLC




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