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December 2000

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From:
"Davy, Gordon" <[log in to unmask]>
Reply To:
Leadfree Electronics Assembly E-Mail Forum.
Date:
Mon, 4 Dec 2000 12:48:46 -0500
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Over the weekend Brian Ellis, Guenter Grossmann, and Mike Fenner responded
to my posting in which I appealed for substantiation of non-obvious claims
of the environmental hazards of nickel and noble metals as used in
electronic products, and expressed concerns that nameless people will
continue to add to the list of forbidden elements. Although they don't say
so, I gather that these people concur with Mr. de Kluizenaar that tin - at
most - is the only environmentally acceptable finish and that those working
on other finishes should switch. I would like to thank these men for the
effort they made in preparing their responses, but after reading them I can
see that I failed to make my points adequately. I'd like to try again.
First, I did not mean to imply that Mr. de Kluizenaar is one of the nameless
people who are trying to adjust reality at will, and if that is how it came
across, I am sorry. After all, I know his name! My concern was rather that
he repeats the assertions of such people without providing the technical
basis. (I was glad to see Mr. Grossmann's reassurance that "most of us,
including Eric, never forget to mention how doubtful we are about the sense
of the lead ban when we are at conferences or meetings.")
Second, while I am glad that Mr. Grossmann gives us the name of one of the
nameless people: Margot Wallstrom, the EC Commissioner for environment, he
does not refer us to anything that she has to offer in support of her agenda
so that we can assess its validity. Asserting that the juggernaut can't be
stopped is a self-fulfilling prophecy. To the extent that the market is
demanding electronic products free from a growing list of elements, it does
so on the basis of beliefs that persist because no one seems to think that
it is worth while to challenge them. That itself is a belief.
Third, Mr. Ellis has asked that before I challenge statements I do my
homework and research the data. My point was that people who make
non-obvious statements have the burden of proof. I think that that is a
fairly common expectation in the world of scholarship. This whole business
of adjusting reality comes from some people being relieved from that
responsibility (because of the nobility of their cause?) - they are right ex
officio. Taken to its extreme, it is superstition and demagoguery, which
seem to persist even in a scientifically sophisticated age.
Finally, although Mr. Ellis offers two reasons for restricting the use of
nickel and noble metals in electronics, something essential is still
missing.
Mining. He says "the recovery of all metals from ore is environmentally
hazardous." Mr. Fenner makes the same point. Does it follow that since all
mining makes a mess, all mining should be banned because obviously we don't
want a messy world? (Even though tin mines must be messy, too, Mr. de
Kluizenaar seems willing to continue using tin.) It would serve the
discussion better to offer some sort of cost-benefit tradeoff assessment,
and some analysis of how to reduce the environmental impact of mining. I
doubt that even Ms. Wallstrom and her colleagues will be successful in
shutting down mines around the world, even if that is what they would like
to do. (Incidentally, if that is what they would like to do, they should say
so openly, so people can respond.) It is, on the other hand, quite likely
that mining operations might be improved. Two hundred years ago, my
namesake, Humphry Davy, was made a baronet in England as a reward for
inventing a lamp that miners could use so that their candles would not
ignite an explosion in coal mines. As bad as mines may be today, I'm sure
that many of them have improved significantly. In any case, we need to know
how much less of an environmental impact there would be from reduced mining
due to the proposed cessation of use of the prohibited metals in electronic
products, and whether that benefit outweighs the associated costs.
Health. Mr. Ellis tells us that "higher nickel alloys are on the way out"
and suggests that even stainless steel may be "frowned upon" (by whom? - he
doesn't say! It's that passive voice again.) The reason he offers is that we
are learning more about nickel's toxicology and epidemiology. He also says
"we owe ourselves the luxury of a scientific assessment of every material we
use in the electronics industry from all standpoints and the potential
cradle-to-grave risks of using it." I wouldn't call it a luxury - it's the
very necessity I have been asserting. But apart from Mr. Grossmann's
observation that some people are allergic to nickel and Mr. Ellis' question
"can this be good to health?", we are not offered such an assessment for any
of the metals. Just what is it that "we are learning about its toxicology
and epidemiology" that shows that it's a bad idea to use it in electronic
products? Until we are told we cannot perform the scientific assessment of
the risk to people - or the environment in general - of using nickel in
electronic products, and compare it with the costs of learning to do without
it.
It is exactly this kind of broad indictment that I am trying to bring
attention to. It should go without saying (but evidently doesn't) that
there's a huge difference between cooking in a copper pot and using copper
for carrying current. (Incidentally, based on Mr. Ellis' expressed distaste
for copper, my concern that it might some day be added to the list seems to
have been well founded.) Just because we all agree that lead in paint and
gasoline is bad doesn't mean that lead in electronic products is bad. We
have data to show elevated blood lead levels deriving from the first two
uses. I did my homework and have presented in this forum data showing the
lack of risk from the last one - which if Mr. Grossmann is correct, everyone
agrees with.
At the risk of being too obvious and abrasive (I really don't want to be), I
am asserting that it is irresponsible for those who believe that people (or
fish or trees, for that matter) are being harmed from the use of these
elements specifically in electronic products not to produce the data that
leads them to that belief. Arguing by specious analogy and offering mere
generalizations about "what we are learning" isn't enough - for me, and I
would hope, for most others. My thanks to attorney Chuck Dolci for his
supporting comments. As he points out, the issue is partly one of the rules
of evidence and proper reasoning.
I am reminded of the goal-statement of one environmentalist: he wants to
"remove hazardous materials from the biosphere". Were he to succeed, the
world would be a very different place, and I'm not sure it would be very
pleasant.

Gordon Davy

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