There are many ignorant buggers who latch onto buzzwords like a terrier
to a rat and shake them about until they are killed. These are often
so-called NGOs who can be described only as ecopolitical disaster
organisations with little-to-zero scientific knowledge.

CFCs and halons are banned because they are ozone-depleting and are
controlled substances under the Montreal Protocol. But your "blacklist
generators" let other ozone-depleting (and halogenated) substances slide
through (e.g., n-propyl bromide, aka nPB or 1-bromopropane -- check the
MSDS of any organic solvent you use).

As for halogenated flame retardants, you will find TBBPA in all normal
FR-4, but this is not restricted by RoHS.

PVC is the one of the biggest idiocies perpetrated by NGOs but,
fortunately, they have not succeeded in banning it. They had two
arguments. The raw monomer is vinyl chloride, a very toxic gas. They
therefore argued that the polymer must contain some of the monomer and
is therefore dangerous. The fact that the polymer goes through several
transformations at elevated temperatures (adding fillers and pigments,
plasticising, pelleting, extrusion etc.) appears to have escaped these
morons and, even if the raw product did contain trace quantities of the
very volatile gas, it would long have disappeared in the finished
product. The other argument is that incineration produces some nasty
gases, such as hydrogen chloride and carbonyl chloride. This is true if
done indiscriminately in poor equipment (there was, in the 1950/60s, an
incinerator ship anchored in the North Sea, in international waters,
especially to destroy excess PVC, cheaply, unregulated and with no fume
treatment and they did a service in stopping this abuse). In modern
incinerators, these by-products of combustion are removed. However,
today, ~40% of PVC is recycled (could be more). I won't discuss here the
chemical instability of PVC as a component in electronic equipment,
other than to say that it can be very useful depending on the
application, but also potentially dangerous in other cases.

However, I never hear of bans for other halogenated plastics and
co-polymers, which suffer from analogous disadvantages, such as PTFE
(e.g. Teflon), PTFCE (e.g., Kel-F, Hostalon) etc. And most
non-halogenated plastics used extensively in electronics, such as
polyimides (e.g., Kapton), polycarbonates, polyesters etc., may be doped
with halogenated flame retardants to a greater or lesser degree.

As for arsenic, it is found in many semiconductors as a doping agent for
silicon, not just GaAs, which appears to be an intermetallic compound.
So, a ban on arsenic would mean no electronics, as we know it today, and
we would all be out of a job and we would have none of the amenities we
enjoy today (maybe a ban on computers and, above all, cellphones
mightn't be a bad idea :-) ).

A few days ago, I made a plea for the use of commonsense in our
industry. I make the same plea towards those who, in their dire
ignorance and stupidity (and I include the authors of RoHS in this
category), try to exclude the use of substances which are either
mandatory in our business (such as arsenic or fluoropolymers) or are
desirable but harmless in normal use (such as TBBPA). It is up to us to
demonstrate the errors of their ways to those idiots who desire to
restrict their use.

 From this, do not conclude I'm a reactionary redneck: I'm not. I have
worked for decades promoting sound environmental practices in the
electronics industry and have contributed, on an international scale, to
a number of essential changes over the years.

Brian

Genny Gibbard wrote:
> We are getting more and more of these surveys which ask us about our use
> of restricted {black list} and controlled {grey list} substances in not
> just our products, but also in our manufacturing processes.  They often
> have a compliance statement they want us to sign.  These surveys seem
> much more restrictive than the RoHS directive.
> For example, things like CFC's, halons, and arsenic on "black" list, or
> halogenated flame retardents on the grey list.  Or questions about the
> use of PVC.
> Many of these things are not in common use any more, I believe, but I
> feel like I have to be a chemical engineer to know where to look for
> this stuff.
> Does anyone know what is driving this?
> Does anyone know any good place to look for resources to track down
> where these substances might be found?
> And finally, does the arsenide in GaAs diodes and transistors count
> towards the "black list" arsenic?
> Thanks in advance,
>
> Genny
>
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