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November 2000

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From:
Fern Abrams <[log in to unmask]>
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Date:
Tue, 14 Nov 2000 15:51:16 -0500
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As you may (or may not) know, last May IPC, IEEE and EIA sent a letter to
the Environmental Protection Agency expressing interest in and support of a
Design for the Environment (DFE) project to study environmentally preferable
substitutes for tin-lead solder.  There is significant concern on the part
of our industries that if all environmental aspects of replacement solders
are not carefully considered, the replacement of lead solder could have a
net negative effect on the environment.  We are concerned that companies
could invest large sums of money changing to an alternate solder only to see
it being targeted for environmental concerns and/or regulation in the next
decade.

As you know, when it comes to lead-free solder, there is no time to be
wasted.  The DFE project is funded by EPA's Office of Pollution Prevention
and Toxics (OPPT).  It is our understanding that this years budget is still
in play, but the time is critical.  On Monday November 27th we will be
meeting with Dr.William H. Sanders, III, Director of OPPT to request funding
for this critical project (see letter below).  The meeting will be much more
effective if we are able show industry commitment through the presents of an
EMS company.  Please contact me by email or telephone and let me know
if you would be available for this important meeting.

IPC has successfully completed two DFE projects with EPA for the PWB
industry.  The result of these projects has been a leveraging of govt. and
industry knowledge and funding for the benefit of industry (and the
environment).


Fern Abrams
Director of Environmental Policy
IPC- Association for Interconnecting the Electronics Industry
1400 Eye Street, Suite 540
Washington, DC  20005
202-638-6219
202-638-0145 fax
[log in to unmask]

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                                                                        November 6, 2000

Dr. William H. Sanders, III
Director, Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (7406)
Washington, DC  20460

Dear Mr. Sanders:

We are writing to request a meeting to further discuss and follow up our May
11, 2000 letter to Ms. Kathy Hart in your Design for the Environment (DfE)
program.  In that letter, we expressed, on behalf of the electronics
industry, interest in and support of a DFE project to study environmentally
preferable substitutes for tin-lead solder.  As we mentioned in our May
letter, there are legislative and regulatory initiatives underway in several
regions of the world that seek to ban lead materials in consumer and other
electronics.

Since our May letter was sent, pressures to remove lead from electronics
have increased, both domestically and abroad due to alleged environmental
concerns posed by leaded solders.  A number of companies and organizations
have begun to investigate the physical properties and performance
capabilities of alternate solder compositions.  As of late, these groups
have shown interest in examining the environmental impacts of the
alternatives.  There is significant concern on the part of our industries
that if all environmental aspects of replacement solders are not carefully
considered, the replacement of lead solder could have a net negative effect
on the environment.  For example, there is concern that silver-based solders
may leach more readily than leaded solders and bismuth-based solders may
impede recycling. Unfortunately, most of the policy discussion to date
focusing on leaded solders has been based on a paucity of information and
lack of understanding regarding the environmental life-cycle of leaded
solders and their alternatives.

This issue is crucial to the continued environmental improvement of the
entire electronics industry.   An EPA-sponsored,  DfE life-cycle assessment,
focusing on natural resource utilization, risk assessment, and end-of-life
disposition would be an integral component of a thoughtful, informed
evaluation of alternate solder compositions.  This work is crucial to ensure
that the industry does not invest a significant quantity of resources to
develop and implement new solder technologies that may, in the long run,
pose their own environmental concerns,

Our organizations are fully committed to working with EPA in the partnership
mode made possible by the EPA DfE Program.  We hope that you will take the
time to meet with our representatives to further discuss the importance of
this proposed project.

Sincerely,

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