Keith

Thank you for your clear descriptions of lead-free soldering programs and
implementation in Japan.  Although you took the time to address me, I believe
that others in the list may be interested  in your thoughts re the following
2 questions. Others may come up with more questions.

In a previous correspondance you stated that an extra levy on lead bearing
electronics at recycling centers is an important incentive for manufacturers
to go lead-free.  The reason for the extra levy is the cost of recycling lead
in solder, you stated.  You may anticipate that raises some questions.

Assuming that we are talking about the (A) recycling route rather than (B)
landfills or (C) incineration--

1. Presumably the boards are being recycled for tin, copper, and precious
metals, since they have more value.  But recycled lead is a byproduct of this
process. Noranda and ACS Refining in N. America are separating out or
recovering lead this way every day.  What is the economic justification for
an extra levy on lead bearing solder?

2. The costs that you have so ably referred to for setting up lead-free lines
far, far outweigh the cost of recycling lead on boards. (Add the additional
energy, capital equipment, and training costs.)  As you pointed out, the
smelting capacity is already in place to serve the battery industry.  If the
logistics of collection are being put in place, what is the economic or
environmental justification for lead-free solder?

If we are assuming landfill disposal, then we are back to the necessity to
separate out the other toxic metals, where we began.

If incineration is the route, electrostatic precipitation and bag houses
eliminate over 99% of heavy metal particulate release.  That's why OSHA has
certified all N. American installations.  I am sure that Japan is at least as
advanced.

Re statements that the rest of the world would be advised to follow any
unilateral mandate emanating from any source-- that raises a host of other
questions.  I won't go down that path for now-- hope someone else does.

I look forward to the day when all parties will participate in a scienific
risk assessment, birth to death, of all solder alloys.  The IPC-EIA - EPA
initiative sould be joined by every concerned company and government, all
over the world.

Harvey Miller

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