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April 2004

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Subject:
From:
"Kallin, Dan" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Fri, 9 Apr 2004 16:53:51 -0400
Content-Type:
text/plain
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There was recent discussion regarding enforcement.
This is excerpted from the Moss Dore's posting earlier.
[LF] Ireland - WEEE/ROHS Taskforce Report 5th April 2004.
Dan

Enforcement must be a priority and the penalties for non-compliance with the
Regulations must provide a real and proportionate deterrent.
  Local authority and EPA personnel with the necessary knowledge of the EEE
industry and specific technical expertise will be required for the purposes
of
these Directives. A strong commitment to the provision of training for
enforcement staff will be required on an ongoing basis.
  A clear, consistent methodology for conducting audits, particularly for
RoHS
compliance needs to be developed and provided to those responsible for
undertaking them.
  Enforcement of RoHS could be facilitated by a system of self-reporting,
with
producers responsible for ensuring records are kept and are available upon
request. However, inclusion on the register of producers should be dependent
on the manufacturer furnishing proof of compliance with the requirements of
the RoHS Directive. Non-compliers with RoHS based outside the EU should
be prohibited from placing EEE on the Irish market or otherwise bringing EEE
into Ireland until compliance can be demonstrated.
  To minimise the effect of "free-riders", registered producers and members
of
any collective WEEE scheme(s) in particular should be encouraged to report
any non-compliers. Enforcement actions should be taken in a timely and
consistent manner. Authorities should audit operations/facilities or inspect
products upon receipt of a complaint and fines for non-compliance should be
at a level, which would make compliance a more economically viable option.


__________________________________________
Dan Kallin           Environmental & Safety Engineer
   Bose Corporation       Framingham, MA 01701
                 [log in to unmask]
                 508-766-7136  (phone)
                 508-766-7086   (fax)
__________________________________________

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