Mike
I am he from the Island of Love! Thanks for the compliments. I don't
really know how we can do anything useful. My best suggestions are:
a) write to KHF and all the other members of the commission, stating
that legislation based on arbitrary non-science is totally unacceptable,
especially as there are such large negative economic and technical
issues involved.
b) write to every MEP, explaining the situation, and asking them to
postpone any parliamentary decision on the matter until such time as a
scientific risk assessment of the environmental benefits and drawbacks
has been made by an independent body of scientists.
c) write to the European Commissioners individually, explaining that the
current process of environmental regulation-making has been shown to be
flawed and asking for a revision of the procedures, so that no directive
can be passed until it has been shown scientifically that it is
beneficial or, if based on a precautionary principle, a full risk
assessment has been made, taking into account both positive and negative
effects.
d) make sure that the politicians are made aware, in particular, that
there are vested interests deeply implicated.
e) write to the national Minister(s) involved, along similar lines.
In other words, kick up such unholy stink that, at least, matters may be
delayed for more ripe reflection and that, at the best, the whole thing
gets discredited. The question is whether 1000 individual letters or a
petition with 1000 signatures would be more effective. I think I prefer
the latter approach.
The real problem is that KHF and Co. are the equivalent of the Rt. Hon.
Jim Hacker while Sir Humphrey Appleby heads the DTI and other such
organisations throughout Europe. I have little doubt that there are
technocrats who play the role of Bernard, without a clue as to what they
are doing, but in all good faith, living on the information and
disinformation they are fed by the NGOs and vested interests.
Unfortunately, the 10 or 20-man SME, which would be the hardest hit by
such measures, may even be forced into bankruptcy if it cannot meet the
technical and economic challenges. Unfortunately, 20 voters here or
there would have little clout with the politicians (except, perhaps, in
Florida), whereas the Siemens, Nokia, Alsthom, Olivetti, Marconi-GEC and
so on of this world, with large numbers of voters employed, have both
the technical and economic capability of living with such changes. The
politicians and technocrats perhaps do not even realise that about
60-70% of the production workforce in the electronics manufacturing
industry work in production units with less than 50 persons employed.
I recently was in the Far East, discussing with the Sir Humphreys and
Bernards of several countries the problems of reaching the electronics
industry within their respective countries, to ensure that environmental
and health and safety regulations were being complied with. In one
country (Philippines, to not name it), I was told there were six very
large companies (>3,000 employees), which were easy to reach; about 20
medium-sized ones (>500 employees), 80 small-medium ones (>50
employees), all of which were identified and controlled, but they
estimated there were over 1,000 small companies (<50 employees) and
probably as many again in the informal sector (1 and 2 men unregistered
affairs working spare time in a garage or shack). The latter two
categories were absolutely impossible to identify, let alone control. I
believe that this problem is not unique to developing nations but is a
reflection of developed ones, as well.
Anyway, where do we go from here? All views welcomed!
Brian
Mike Fenner wrote:
>
> If you are the Brian what lives in Cyprus, then this is and excellent
> initiative and good work. Is there anyway we can endorse your efforts.
> I'm not entirely sure I know what I mean, but if 1000 industry people
> all said they agreed some how would this do anything?
> Of course if you are some other Brian then you will have no idea what
> this is about. Please ignore.
>
> Mike
>
> ----- Original Message -----
> From: "Brian Ellis" <[log in to unmask]>
> To: <[log in to unmask]>
> Sent: Thursday, March 15, 2001 1:37 PM
> Subject: [LF] URGENT WEEE
>
> 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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