Hi, all!
A few days ago, the name of Herr Karl-Heinz Florenz came up in this
netlist. I took the bother of researching him and found he was a Member
of the European Parliament (i.e. a politician) and rapporteur of the
WEEE commission. Nothing ventured, nothing gained, I wrote to him and
have since had an exchange of messages between his assistant handling
the WEEE affair, a Mr Axel Eggert. The whole thing is too long to send
to here verbatim, but I'll extract some salient points.
12 March BE>KHF
... I quote:
"The EU chemicals policy has to ensure that all risks stemming from
chemical substances are eliminated or, at least, limited to a level that
excludes any risk
to human health. In cases of uncertainty, the EPP/ED Group is
determined to make use of the precautionary principle to define limits
or bans. However,
the precautionary principle should not be abused by political
decision makers to defend the taking of arbitrary measures. The
precautionary principle shall
only be applied if the scientific risk assessment results in the
conclusion that a chemical substance or preparation could threaten human
health." [BE comment: the EPP/ED is Herr Florenz own parliamentary
group]
There has been no sound scientific or epidemiological study that has
proved that lead in solder or cross-linked tetrabromobisphenol A in
electrical or electronic waste "could threaten human health". Therefore
the "precautionary principle" cannot be applied, in this case.
...
There is a further environmental consequence of removing lead from the
soldering of electronics assemblies which I believe has not been
studied. About 30% of such assemblies, manufactured worldwide, require
to be cleaned after soldering. The most popular method, today, is some
form of aqueous cleaning (probably 95%). Metallic salts resulting from
the chemical reaction between solder, oxides and the flux are therefore
dissolved in the wash water, including, of course, lead salts. Current
legislation in most countries is, rightly, draconian that these be
removed before the water is discharged. In most countries, the permitted
level of residual lead salts is about 5-30 times less than that for tin
(the other major one) or copper. Waste water treatment is therefore
currently very tightly controlled. If lead were eliminated from the
equation, then this would be a green light for a poorer quality of
treatment with consequential major increases in the other metals
occurring. This would be exacerbated by the fact that the substitute
lead-free solder would have almost 50% more tin than before. As
developing nations (as defined by Article 5(1) of the Montreal Protocol)
convert to water-cleaning techniques, so the quantities of potentially
hazardous metals in water-soluble form entering the environment will
increase, as a result.
Furthermore, the soldering temperature of lead-free alloys is typically
30°C-40°C higher than for conventional soldering alloys. This will
result in considerably higher energy requirements, invariably electric.
In those countries which rely on fossil fuels for electricity
generation, this will increase the carbon dioxide emissions, thereby
this proposed directive would have a direct impact on climate change. I
estimate that there are over 100,000 wave soldering, hot-air levelling
and reflow machines in service in the electronics industry today,
consuming an average of about 18 kWh each per day. This would rise to
about 24 kWh to provide the extra energy. The total extra energy
required per annum would therefore be about 132 MWh. This would
represent a considerable increase in CO2.
...
Herr Eggert replied 13 March:
...
In his report on end-of-life vehicles Mr Florenz
tabled an amendment that would have required risk assessment. But
unfortunately this was neither
accepeted by Parliament nor Commission and Council. Thus we cannot find
any majority for such an
approach on the follow-up directive on WEEE and ROHS.
...
[BE comment: in other words, as it is admitted that there has not been a
risk assessment, the precautionary principle is invalid. This leads the
thing wide open to being classed as arbitrary as many of us feel it is.]
BE>AE 13 March
...
I am extremely surprised, even shocked, that any legislation could be
proposed, which could have such a negative impact on European industrial
competitiveness for exports and technical reliability of manufactured
goods without a thorough scientific risk assessment having been made,
with a "cradle-to-grave" approach. This can only be described as
arbitrary. Because it will apply also to imports, eventually it will
have an impact on extra-European manufacturers. The only people who will
be pleased are the tin producers, who will see their sales expand
significantly with high tin alloys (unlike lead, solder is a major tin
consumer). I frequently visit Malaysia and I'm always shocked to see the
devastation of large tracts of primary rain forest (for ever) caused by
tin mining. This legislation will help destroy further areas of this,
the world's oxygen lung, and probably countless species, all because of
a hypothetical and unproven risk of a comparatively small amount of lead
may, some day, enter into a water system (no case has yet occurred, to
my knowledge) from a landfill.
...
In the meanwhile, I reassert my support of recycling and encouragement
of reducing the risk of lead entering the environment unnecessarily, but
I must oppose a ban of lead in solder until such time as a
"cradle-to-grave" scientific risk assessment has been made and proves,
without doubt, that all the long-term environmental effects of lead in
solder are worse than the long-term environmental effects of forbidding
it. With the present evidence, it would seem unlikely.
...
Mr Eggert has given me to OK to reproduce this correspondence which, I
believe, introduces a new facet to the arguments.
Apparently, there is a deadline of 19 March for constructive comments to
be made to the proposed WEEE and the draconian amendments that Herr
Florenz has proposed. I therefore invite anyone with such comments to
send them to him at Karl-Heinz Florenz <[log in to unmask]> as
soon as possible. Unfortunately, I cannot attach any documents here, but
if you Google Karl-Heinz Florenz, you will find all the documents you
need.
Best regards
Brian
PS If anyone wants our full correspondence, please e-mail me off list.
This includes a number of other matters which are less revolutionary.
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