David Bergman has posted a proposal for a life-cycle assessment study of
leaded and lead-free solders and asked for support. He provides background
information with a number of assertions that themselves need to be
scrutinized: that lead bioaccumulates, that "lead is released into the air
or groundwater during mining, treatment of waste, and disposal", and that
"worker safety issues" have been raised.

I can offer three recommendations for this project:

1. Don't take every assertion as a given. In particular, does lead
bioaccumulate, how much lead is being released into the air and groundwater,
and what data exist for worker exposure to lead? I happen to know of
repeated studies looking for increased blood lead levels in people who
solder for a living. The results of all studies I have seen is that there is
no increase. (To a toxicologist, "exposure" means getting it inside you, not
touching it.) If money is going to be spent on this project, then it will be
important to keep it scientifically sound, and not settle for appeals to
intuition and repetitions of vague allegations made by irresponsible
environmental activists who have a vested interest in frightening people.
Superstition did not disappear after the seventeenth century - nor did
opportunism.

2. For the Scope, include as a deliverable, a prediction of the number of
cases of lead poisoning that will be avoided by switching to a lead-free
solder. (My prediction: zero). If someone thinks that there are benefits
other than preventing cases of lead poisoning to be obtained from switching,
he should be up front and specific about what he thinks that they will be.
EPA data show that blood lead levels in the US have been dropping since the
mid-seventies when lead was removed from gasoline, and that the remaining
cases are attributable to children eating peeling lead-containing paint.
(Don't overlook the fact that the lead that was put into gasoline for all
those decades didn't cease to exist when the gasoline was burned. It's still
right there in the top layer of soil, in every part of the world where
leaded gasoline was sold. Compare the risk of disposing of a TV or cell
phone in a landfill with the risk from lead in the ground in your garden.
Just imagine - the whole world as a Superfund site!)

3. For the leachability test, assess the predictive value of the test that
is selected. A test solution designed to maximize lead solution does not
match at all the composition of ground water anywhere in the world, and is
therefore inappropriate for any purpose. The test gives you a number, but
what does that number mean? Real ground water is full of sulfate and
carbonate, which prevent lead leaching. No one has yet produced a case of
elevated lead in ground water attributable to mining, treatment of waste, or
disposal, anywhere in the world. A couple of years ago I posted the web site
address of a scuba diving school that is conducted in an abandoned lead mine
- surely a likely spot for elevated lead levels if that were a risk.

In conclusion, while I am glad to see the proposal for the study, I am
concerned that the topic is so politicized that it will take quite a bit of
effort to ensure that the outcome is not predetermined and that it will
actually make a difference. How many Leadfree forum subscribers believe that
if the study shows that lead in electronics is not a threat to the
environment (an assertion that is still part of the IPC Board of Directors
position statement), there will be any change in Europe or Japan? If it were
my money that were being spent on this project, the first thing I would want
to know is the prospect for a favorable outcome influencing the course of
events. How much money is being budgeted to broadcast the results and to get
powerful people to change their minds? In fact, as a final recommendation,

4. Start the project by deciding whether enough movers and shakers could be
induced to change their position, if the outcome of the project supports a
change, to warrant the effort. Otherwise, at best the whole project will
turn out to be an "academic exercise", a phrase of opprobrium at the company
where I work - equivalent to "a waste of money and time".

Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399

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