The thing that bothers me is the assertion by EMPF that "...it is
inevitable
that military and aerospace hardware will be forced by sheer commercial
availability to manufacture with Lead Free solders and materials."
Why wouldn't tin/lead solder continue to be available for as long as
anyone
wants it?
And as long as existing designs still require use of tin/lead solder
without
expensive and time-consuming requalification, at least some military
electronics
will continue to be soldered with tin/lead.
As for new designs, are there other justifications for making the
switch?
There could be a technical reeason, like longer solder joint life in
particular
environments, but it is pretty clear that tin/lead will still be
superior for
some applications. Anyone know of any other justifiable reasons why the
U.S. military would want to specify lead-free solder?
-Joe
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Timothy McGrady
Sent: Thursday, November 02, 2006 2:20 PM
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
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
>>>
>>>
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>>
>>
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