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November 2006

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Subject:
From:
John Burke <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Wed, 15 Nov 2006 22:28:09 -0800
Content-Type:
text/plain
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text/plain (689 lines)
Could someone PLEASE enlighten me about why Airbus is even concerned with
this non issue?

Aircraft are the epitomy of the need for safety requirements. Over even a
car and here is the reason why.

Car carries few (but individually irreplaceable) people. Car electronics
stops, best case car rolls to a stop - passengers get out.

Airbus electronics fails on critical system, airbus stops, and falls 32000
feet carrying hundreds of people.

I believe the only possibility of an airbus turning up in the waste stream
is if it crashed into a recycling center.

John



-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Timothy McGrady
Sent: Wednesday, November 15, 2006 10:15 PM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet

Here's a clip from an article in today's newspaper out of China:

The first A380 will be delivered to Singapore Airlines in October 2007,
almost a year behind schedule. Sources said the airline would first use the
superjumbo to fly routes to Sydney and London.

Airbus attributed the delivery delay to problems with installing onboard
wiring systems.

_________________________________________



Hmmm...




----- Original Message -----
From: "Stadem, Richard D." <[log in to unmask]>
To: <[log in to unmask]>
Sent: Monday, November 06, 2006 8:45 AM
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet


Airbus planes are indeed quieter and more comfortable.
They never leave the ground, thanks to their ecological, lead-free
electronics that are much easier to recycle.
No engine noise, none of that infernal buffeting from the wind.......

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of David Suraski
Sent: Friday, November 03, 2006 8:38 AM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet

Why should we presume that Airbus isn't making their suppliers prove to
them first that the new (lead-free) design meets all requirements? Maybe
the hoops they're making their suppliers of lead-free products jump
through are even more challenging than those Boeing would have their
suppliers jump through?  Just because they have a hokey ad campaign
about lead-free electronics doesn't mean that they're not doing their
homework before implementation.

I'm not an Airbus-backer or Boeing-detractor (though I do think that
Airbus' planes are quieter and more comfortable), nor do I have any idea
what these companies are REALLY doing about lead-free, but how much can
we really take from that article? Not too much, IMO. All we can is hope
that they're acting responsibly.

Dave

-----Original Message-----
From: Kane, Joseph E (US SSA) [mailto:[log in to unmask]]
Sent: Friday, November 03, 2006 9:16 AM
To: (Leadfree Electronics Assembly Forum); David Suraski
Subject: RE: [LF] EU Not Busting for RoHS Violations Yet

We're a supplier to Boeing, and they've made it clear that they won't
accept lead-free solder unless we prove to them first that the new
design meets all requirements.

As a high-technology company, they have to be interested in this
development, but they're not going to allow lead-free solder without
making the supplier jump through some hoops.

And they have not made a splashy corporate announcement about making a
"lead-free airplane" for silly and unfathomable reasons.  This will be a
comfort to me the next time I'm flying in an aluminum tube 7 miles up at
Mach 0.8.

-Joe


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of David Suraski
Sent: Friday, November 03, 2006 9:04 AM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet


Tim,

How do we know that Boeing will not use RoHS-compliant electronic? I
have heard information to the contrary, not to mention the quote from
the article you cite that states (capitalization mine): "Industrial
Advisory Board (IAB) members, BOEING, Rockwell Collins, ITT, Raytheon,
and Lockheed Martin, have individually and collectively performed
research and development tasks on Lead Free solders. Together, it is
proposed that a new Lead Free Program be initiated."



Best regards,
David


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Timothy McGrady
Sent: Friday, November 03, 2006 8:50 AM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet

Brian:

Go back and read the link provided.  It states that the A-380 will have
RoHS-compliant electronics.  Boeing will not do that, nor will anyone
else making aircraft except Airbus (and now, it seems, NATO and a few
others).
The unknown reliability of RoHS-compliant products causes me to not want
to stake my life on an Airbus A-380 or any other plane that accepts
equipment with unknown longterm reliability.  No Airbus A-380 for me.
Period.

Tim
----- Original Message -----
From: "Brian Ellis" <[log in to unmask]>
To: "(Leadfree Electronics Assembly Forum)" <[log in to unmask]>; "Timothy
McGrady" <[log in to unmask]>
Sent: Friday, November 03, 2006 7:49 AM
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet


> What's so different between an A380 and any other plane? Boeing and
> Airbus have a common programme for all flight electronics techniques
> and lead-free.
>
> Brian
>
> Timothy McGrady wrote:
>> And they fire lead-free bullets as well.  That's right - they used
>> depleted uranium!  Much better for the environment and human health.

>> No chance of getting lead poisoning if one of those bullets lodges in

>> your brain.
>>
>> I will not fly on an A-380. Period.
>>
>> ----- Original Message -----
>> From: "John Burke" <[log in to unmask]>
>> To: <[log in to unmask]>
>> Sent: Thursday, November 02, 2006 1:54 PM
>> 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
>>>>>
>>>>> ------------------------------------------------------------------
>>>>> -------
>>>>>
>>>
>>> -
>>>
>>>> -----Leadfee
>>>>
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>>>>>
>>>
>>> -
>>>
>>>> -----
>>>>
>>>>>
>>>>
>>>>
>>>>
>>>
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