In his latest Leadfree posting, Dr. Levoguer says that I tenuously (and
quite incorrectly) extrapolated his personal beliefs and allegiances and
distorted his views. If that is true, then I am sorry. My goal was to
restate his position in terms I could understand. However, after reading the
rest of what he said, I am still not clear on what exactly I said that is an
incorrect representation of his position, unless it is that he really does
want industry to run environmental impact studies on the continuing use of
the materials that they have been using all along, and prove (I assume to
the environmentalists' satisfaction) "that they are acting responsibly."

Perhaps Dr. Levoguer would like to state what exactly he means by
"responsibly", and what it would take for a company to convince the
environmentalists that it is acting responsibly. What he is asking for
sounds to me like guilty until proven innocent, with no way of  knowing what
it takes to succeed. Does convincing a majority of environmentalists that
you have been responsible do it, or is it necessary to convince them all?
What if they change their minds later, or others come along who didn't vote?
Who is to say that the environmentalists will be responsible in reaching
their consensus? Is responsibility in the eye of the beholder? There is no
recognized environmental court, which means, as I said in my previous
posting, that environmentalists are free to make whatever claims they feel
like, with no one to hold them accountable for acting responsibly. Libel
laws only protect people, not materials.

In any case, since conducting an environmental impact study costs money, it
is critical that before such a study be started a prior agreement would have
to be reached on what will happen based on the outcome. The agreement needs
to be like this: if the study shows that the environmental impact, as
measured in this agreed-upon manner, of discarding electronics with each of
these elements is below this threshold, then the environmentalists agree
that it is not irresponsible for manufacturers to continue using these
elements, and to stop demanding that they be removed from electronic
products; if the impact is above this threshold for one or more of the
elements, the industrialists agree to start phasing those elements out of
their products. Without such a prior agreement of how to interpret the
results, the industrialists are at risk of being told after the fact that
they didn't do (or interpret) their study correctly, and hence of wasting
their resources. Frankly, I have trouble imagining that there would ever be
such an agreement. I fully expect that environmentalists will keep on
chastising industry for using materials that they, using their own beliefs,
don't approve of, and that was the point of my previous posting.

What conceivably could be achieved is a list of currently used materials
that environmentalists intend to start pushing for elimination from
electronic products, once they have won on lead, cadmium, mercury,
hexavalent chromium, and halogenated flame retardants. (Based on the
oft-repeated sentiments I see appearing in this forum, it is a foregone
conclusion that they will win and a waste of time to try to derail the
bandwagon.) I don't want to extrapolate Dr. Levoguer's personal beliefs on
these matters, but since he has called for industry to be proactive and to
provide a "complete and  objective assessment of the hazard posed by lead
and other 'harmful' materials in electronics", perhaps he would like to let
us in on what these other materials are that he thinks industry should be
studying or eliminating. Having a complete list will allow the greatest
proactivity and the least waste. I have mentioned the list from the Nordic
Council of Ministers which includes copper, nickel, tin, antimony, zinc, and
the remaining forms of chromium. (Remarkably, they have failed to mention
beryllium, but no doubt they will eventually include this.) Perhaps he (or
others who agree with him) will have a suggestion on how low a risk has to
be before it is "responsible" to continue to use it. (After all, if the risk
has to be zero, there's no point in running the study.) Perhaps he will have
a suggestion on how to keep environmentalists from acting irresponsibly,
such as claiming that tree sap is in the top 10 percent of hazardous
materials.

Gordon Davy
Northrop Grumman ESSS
Baltimore, MD
[log in to unmask]
410-993-7399
The author's views expressed here are not necessarily those of his employer.

################################################################
Leadfree E-Mail Forum provided as a free service by IPC using LISTSERV 1.8c
################################################################
To subscribe/unsubscribe, send a message to [log in to unmask]
with following text in the body:
To subscribe:   SUBSCRIBE Leadfree <your full name>
To unsubscribe:   SIGNOFF Leadfree
################################################################
IPCWorks -October 25-28 featuring an International Summit on Lead-Free Electronic
Assemblies.
Please visit IPC's Center for Lead-Free Electronics Assembly
(http://www.leadfree.org ) for additional information.
For technical support contact Gayatri Sardeshpande [log in to unmask] or 847-790-5365.
################################################################