Dan, I don' t have any comments directly to your points. I feel that they
are reasonable, logical and sound. But I have been on this listserv for
over one year and have seen various different parties argue and discuss this
point extensively (sometimes professionally and sometimes emotionally) and I
am surprised that it continues.
Whether politically or scientifically motivated, the directive has been
written and discussed. Most of my customers have adopted it, some more
willingly than others. The market is aggressively moving to meet the
mandates and more countries are hopping aboard. Materials that are high
temperature tolerant, RoHS and "green" compliant are becoming more and more
available. Many companies are rolling these material sets into their new
product development as a precaution to what is perceived as being
inevitable. The new materials are currently more expensive, but chances are
the costs will drop to acceptable levels by the time the products using them
ramp to volume.
If you don't meet the mandates, you run the risk of losing market share to
those who do. If you wait until the last minute, you run the chance of
being overwhelmed by competing with resources for others who have waited.
If you meet the mandates early, you can have the potential to reap the
rewards of some good marketing.
I don' t know if the EU Parliament cares if it is considered honest and
credible to people knowledgeable on this subject, as much as they care about
the opinions of the general population they represent. At this point, I
believe that this is no longer an argument of right or wrong. I believe the
issue has reached sufficient momentum that it is now a reality that we need
to deal with as best we can.
Yes, I may not agree with the science behind the directives, but I realize
the reality of the current environment.
Mike
-----Original Message-----
From: Kallin, Dan [mailto:[log in to unmask]]
Sent: Thursday, March 11, 2004 12:48 PM
To: [log in to unmask]
Subject: [LF] paragraph 11 and Articles 5,6 and 7
I am forwarding this observation to this list as well in response to Joe's
comments copied below.
++++++++++++++++++++++++++
I really don't like being so cynical but I am deeply disturbed by the
general
lack forthrightness in this matter. Call leadfree "legislatively mandated"
if
you will, but don't call it "green" or "environmentally friendly" without
providing proof of the same. Thus far all evidence I have seen is that
traditional solders will win both of those latter titles, especially if
there is intent,
at the end of the day to require recycling.
Some simple advice to the EU Parliament it they want to be considered honest
and credible... Wake up and look at the data and make informed and reasoned
rather than emotional decisions for the betterment of your society and the
world.
++++++++++++++++++++++++++++++
Perhaps those with more experience in EU law can explain why there is no
activity to argue that removing lead solder will be more detrimental to
human health and environment?
There appears to be a process in the directive to provide the data so the
parliament can make informed and reasoned decisions.
Any thoughts?
Dan Kallin
-----Original Message-----
From: Kallin, Dan
Sent: Tuesday, March 09, 2004 10:29 AM
To: 'Environmental Health and Safety Compliance'
Subject: RE: exemptions
My understanding is that wording is there to allow modification of the list
of chemicals or the annex, not for use on a product or product line basis.
Articles 5, 6,and 7 describe the process for this modification.
However, following that logic, the entire requirement to remove lead from
solder should not be a part of the directive. The majority of the technical
and scientific evidence I have seen suggests that the "....negative
environmental or health impacts caused by substitution are likely to
outweigh the human and environmental benefits of the substitution"
I have not heard of anybody or group trying to apply this reasoning and
modify the list of chemicals or exemptions.
The first review is supposed to happen before 13 February 2005 (Article 6)
Dan Kallin
-----Original Message-----
From: Carolla, Don [mailto:[log in to unmask]]
Sent: Tuesday, March 09, 2004 9:40 AM
To: [log in to unmask]
Subject: Re: [CN] FW: Transition of WEEE and RoHS
Paragraph 12 of the RoHS directives has these words. If it is not
technically feasible to go lead free, there is an option.
Exemptions from the substitution requirement should be
permitted if substitution is not possible from the scientific
and technical point of view or if the negative environmental
or health impacts caused by substitution are
likely to outweigh the human and environmental benefits
of the substitution
Don Carolla
Product Responsibility Specialist
SEMS Technology Center
Product Safety Group
3M Center/Bldg 235 1F-38
St. Paul, MN 55144-1000
[log in to unmask]
Tel: 651-733-7999
Fax: 651-737-1035
|---------+----------------------------->
| | "Davy, Gordon" |
| | <[log in to unmask]
| | OM> |
| | Sent by: |
| | ComplianceNet |
| | <ComplianceNet@IPC|
| | .ORG> |
| | |
| | |
| | 03/08/2004 01:36 |
| | PM |
| | Please respond to |
| | Environmental |
| | Health and Safety |
| | Compliance |
| | |
|---------+----------------------------->
>---------------------------------------------------------------------------
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| To: [log in to unmask]
|
| cc:
|
| Subject: Re: [CN] FW: Transition of WEEE and RoHS
|
>---------------------------------------------------------------------------
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Phil Bavaro has asked about complying with the WEEE and RoHS restrictions
with a tin-lead plated J-leaded component which he already has on hand and
will need for producing systems well past the July 2006 deadline. My
comments have to do not so much with interpreting the rules as with finding
a technological fix. If the J-leads were dipped in two pots of molten tin
(or tin-copper, or tin-silver-copper, etc.), the Pb remaining in the finish
should be at an adequately low concentration. A dynamic wave would promote
the dissolution and removal of the Pb. It would also be possible to remove
the tin-lead plating chemically, and then dip the leads in tin. (I'm sure
that there are companies that perform this sort of service, and I really
expected to see someone from such a company mention this - maybe they
aren't
monitoring this forum.)
Not that this benefits the environment, of course, but it would allow Phil
to sell into Europe.
Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399
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