Harvey,
        the European Parliament proposal was not attached to your email when
I received it - can you send me a copy or let me have its' web site address
(if there is one)?
        David Albin

-----Original Message-----
From: Harvey Miller [mailto:[log in to unmask]]
Sent: 10 March 2001 23:13
To: [log in to unmask]
Subject: [LF] Draft WEEE document (proposal), now official -- re
lead-free electronics


My interpretation of the attached proposal of the environmental committee of
the European Parliament follows.
I would defer to Jennifer Guhl of the AeA for a more definitive
interpretation
She tells me that a vote in the European Parliament is scheduled for mid
May,
2001.
(I am working on a project to assess reliability and economic impacts of
lead-free solder and very much desire all inputs).

Pages 6 and 11 merit your main attention.

Page 6 again stipulates that electronics using lead in solder should be
banned in manufactures by "Member States". The ban seems to be mitigated in
following pages and very significantly excludes Medical Electronics.  The
impact after exemptions is on the board level electronics supply chain, from
chips to board fab to board assembly. Note that the effective date for
elimination of lead has been moved closer-- to Jan 1, 2006, from 2008.

Page 11 cites Herr Karl-Heinz Florenz' "justification" for wishing to ban
lead in solder -- the only real issue. He believes that even recycling does
not obviate the necessity to eliminate lead in solder because of residual
amounts. The statement provides a very interesting view into the thought
processes that have turned the world electronics into a frenzy of no-lead
and
pro-lead activity.  Above all, it reveals the complete ignorance of
electronic manufacturing by individuals who seem to have life or death power
over its future.  No-one who knows anything about the complexities of
electronic manufacturing believes that such a major transition is possible
--
let alone whether it be desireable--in less than five years. I think that
Herr Florenz has been deceived by many in our own industry

Exclusion of Medical Electronics raises interesting questions.  Why?  Is
there a possible inference that lead-free solder connections  may be less
reliable?  Or that higher temperature processing might affect component
reliability? Then why not exempt aircraft black boxes, communications
equipment, test equipment, industrial electronics, defense electronics,
automotive drive train electronics.  Application to Consumer Electronics may
translate to shorter product life-- more boxes in the dump or recycling
facility-- an infrastructure item that is only beginning to be built. (And
that is a major, major project)
 Dual production lines are one of the potential manufacturing nightmares.
Supply chain disruptions are another.  The list goes on and on.

These are times that call for the best in all of us-- beyond opportunism and
narrow competitive advantage that will be very temporary at best.  After all
the shouting is over, such opportunism may be remembered.

Please let me know if you wish to be deleted from future messages.

Harvey Miller

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