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August 2001

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From:
"Davy, Gordon" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Mon, 6 Aug 2001 18:11:08 -0400
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Over two years ago, when IPC first announced its initiative to get the
electronics industry to go leadfree, it acknowledged that there was no
technical basis for it, but cited rather competitive (read Japan) and
legislative (read EU) pressures, and asserted that since it could be done,
it should be done. Shortly thereafter the Board of Directors issued a
position statement (excerpt below) that stated this. Given major attention
back then was a Japanese mini-disk player, which, it was claimed, solely on
the basis of going lead-free (solder only, it turned out), increased its
market share in Japan by a factor of three (from 4.8% to 15%, it turned
out). No other example was produced, but apparently that was enough to make
believers of the Board members.

Since that time, as predicted we've seen a lot of activity in Europe with
the proposed legislation that will make it illegal (starting in 2007) to
sell many kinds of electronic products if they contain lead, and will
restrict the freedom of consumers on how they dispose of their end-of-life
electronic products. We have also seen lots of activity in Japan to bring
lead-free electronic products to market. What we have not seen is much
discussion about competitive pressures in Japan based on public demand. We
have heard no more about the mini-disk player and its current market share,
nor have we heard any more about the increase in market share of any other
lead-free electronic product in Japan in support of this notion.

Now we have some valuable new information. Bob Willis recently referred in a
posting to the trip that the SMART Group took to Japan last spring. If you
follow the link that he provided, you can get to an article on the trip that
was published in Electronics Manufacture and Test. (I believe that he gave
us this link once before; I don't recall its being discussed on the Leadfree
forum at the time.) I have excerpted the parts of the article (see below)
that show that the competitive pressure doesn't exist - there is no clamor.

I strongly suspect that the incorrect belief about Japan's public demand for
leadfree was no simple mistake. It was another modern-day or urban myth -
propaganda - dished up to us to serve someone's agenda. We were deliberately
deceived. (My thanks to the Group for telling the truth.) The article makes
clear that the real reason that Japan is going lead-free is not public
demand but electronic manufacturing companies there that have high-level
executives who make that kind of decision without a commensurate
responsibility for the bottom line. As Malcolm Warwick points out in the
article, "it is all about belief in what they are doing." Regardless of how
we might feel about people acting according to their beliefs instead of the
budget, in this case, it isn't science and technology - the correct term is
superstition.

(It is worth noting that the economy of this country has been in a slump for
over a decade, and its prospects for improvement don't appear too bright
yet. Maybe there's a connection to the way companies in this country are
run. I'll leave it to the economists to investigate the influence of
superstition on profitability.)

The information from the SMART Group's trip to Japan is important because it
is repeatedly asserted, including in this forum, that the leadfree movement
is unstoppable due to public demand - either through the marketplace or the
legislature. It may be that by, say, 2010 leadfree will be a done deal (and
certainly prudence demands preparing for this eventuality), but something
else needs repeating: no one knows the future except God. That should now be
obvious to all those people who were sure that the NASDAQ would continue its
climb indefinitely, and that fiber optic networking was a great investment.

So much for Japan; how about Europe? 2007 is still a long way off, and the
EU and its currency aren't doing all that well, either. Lots of things can
happen to make people rub their eyes and say, "What could we have been
thinking? and "How could we have been so misled about lead?" Harvey Miller
has been predicting this for a long time.

(As an aside, for those who are tempted to liken leadfree electronics to
leadfree paint or leadfree gasoline, consider this critical distinction:
there was ample evidence in those cases that lead in those products was
causing lead poisoning. Removal of lead from those products drastically
reduced blood lead levels. No one has stepped forward to offer any evidence
in the case of lead in electronics. It is just guilt by association,
exploited by irresponsible environmental activists.)

Just a couple of weeks ago  the European Commission adopted a 35-page White
Paper on European Governance
http://europa.eu.int/comm/governance/index_en.htm, which proposes changes in
the EU policy-making process to incorporate more "openness, accountability,
and responsibility." The first three paragraphs from the Executive Summary
to that white paper appear below.

        Today, political leaders throughout Europe are facing a real
paradox. On the one hand, Europeans want them to find solutions to the major
problems confronting our societies. On the other hand, people increasingly
distrust institutions and politics or are simply not interested in them.
        The problem is acknowledged by national parliaments and governments
alike. It is particularly acute at the level of the European Union. Many
people are losing confidence in a poorly understood and complex system to
deliver the policies that they want. The Union is often seen as remote and
at the same time too intrusive.
        The Irish "no" highlights the impact of these problems on many
people. This was reflected not only in the final outcome of the referendum,
but also in the low turnout and quality of the debate which preceded it.

It has been stated before that the average European citizen's level of
interest in leadfree is quite low (a lot lower in some countries than in
others). Certainly no one has asserted - let alone offered any data to
suggest - that it is higher anywhere in Europe than in Japan. Suppose that
the European public had been told the truth: that lead in electronic
products is not a threat to anyone's health, that recycling electronic
products doesn't benefit the environment, and that leadfree and recycling
would increase the cost of electronic products. Suppose they then had the
opportunity to vote on this instead of having the decision made for them by
anonymous (closed, non-accountable, irresponsible, by the Commission's own
admission) bureaucrats. (These bureaucrats even voted to make it illegal to
tell the public  - whom they purportedly are serving - how much recycling
was costing them. How's that for openness?) What would the outcome have
been? The white paper acknowledges "serious problems of governance." The
authors are hopeful in their recommendations, but there is no way to know
what the EU in 2007 will be like, or for that matter, that it will even
exist. (How many people foresaw the demise of the Soviet Union?) Certainly
the above suggests cracks in the infrastructure, and the history of the
region suggests that major disagreements could erupt that would render the
EU leadfree and recycling directives totally irrelevant.

As an example of not being able to know the future, I remember back in the
late 1980s when bureaucrats in the US Navy, with its "Weapons Spec" WS-6536
Rev E, introduced sweeping new restrictions on the way that soldering was to
be done on any electronic product sold to it, purportedly to ensure high
reliability. These restrictions then appeared in DOD-STD-2000, which applied
to all "high-reliability" military electronic hardware. At the time,
contractors were told "no tailoring: accept it as written or don't bid", and
the prospects for relief looked very bleak. Yet a few years later, a much
relaxed MIL-STD-2000 was issued, and of course today with US military
acquisition reform even that is gone. What brought about the change? The
military brass eventually found out the truth: field failure of solder
connections was rare (most of those that did fail were due to design errors,
not the soldering process). They concluded that such draconian measures were
unwarranted, and reigned in the bureaucrats. Some of those who had been most
prominent in throwing their weight around vanished.

It would be hard for a person who did not live through those years to
imagine how much anguish contractors went through to comply with
requirements based on the intuitions of these officious souls. It should be
recognized that like Japanese companies and the European Commission already
mentioned, and as in bureaucracies everywhere, the Navy had appointed people
who were charged with minimizing risk - to electronic hardware in this case
- but with no responsibility for the cost to their employer - US taxpayers
in this case - resulting from the rules they invented. Rules based on an
urban myth prevailed for years, but not indefinitely.

To me leadfree and recycling together are like a house of cards (although
not yet showing any signs of collapse), because, as the IPC position
statement makes clear, there is no technical justification for all this
activity. What keeps this house erect is urban myths propagated by
irresponsible environmental activists to frighten people into contributing
to their organizations, and irresponsible bureaucrats in positions of power
who have no motivation to challenge them, and many of whom no doubt believe
them.

If just one percent of the money now being spent by electronics
manufacturers to figure out how to respond to these myths by producing
leadfree products were spent on telling the public (particularly in Japan
and Europe) the truth, as suggested above (that lead in electronics is not a
threat to anyone's health, that recycling electronic products is a waste of
money, and that they have been lied to by self-serving organizations
masquerading as public-spirited groups concerned about the environment),
that house just might collapse, and quickly. People usually aren't too happy
to find out that those they trusted have lied to them.

To my way of thinking, the potential benefits of this truth-telling outweigh
the risk of failure. We don't know how it would work out because no one has
tried. It is to be hoped that the decision makers at the companies that have
agreed to pay to support the upcoming EIA-IPC life-cycle assessment study to
find the truth about leadfree have not themselves been deceived by the
propaganda and that they are responsible for the bottom line. If so, and if
the assessment itself is conducted in a scientifically rigorous manner
untainted by superstition and dogma, perhaps they will be willing to
allocate some of those funds to telling the truth they find to the rest of
the world, even if it turns out to be politically incorrect.

In any case, the next time you read a claim made on this forum or elsewhere
that the future of leadfree is a foregone conclusion, just remember how
limited any of us is at knowing the future. Remember that leadfree and
recycling are unsupported by truth, and ponder the long-term prospects for
such a situation. It has lasted for over two years; can it last for ten?

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

Excerpt from "Japan Progresses Down the Lead-free Path", Electronics
Manufacture and Test, April 2001, pp. 25-30.
        This was a SMART Group mission supported by the [Department of Trade
and Industry]'s International Technology Service. Its purpose was to
establish the status of leadfree soldering in Japan. An important step
before embarking on the trip was to identify preconceptions about what the
team would find. The principal one of these was that market forces were
pushing along the move to lead-free manufacturing. A hunt round Tokyo's
shops soon dispelled this theory. It became clear that vendors were unaware
of the environmental benefits of individual products. More surprisingly,
there was very little information on the product packaging. Many companies
have environmental logo's based around a 'green leaf ' theme, but there is
no universally accepted symbol. Moreover, these symbols only indicate that a
product conforms to its manufacturers environmental code of practice. This
may include the use of lead-free solders but only a small number conveyed
this on the packaging. It was obvious from this that adoption of lead-free
is not market driven. A new TV advert for a Panasonic mini-disc player is
the first to mention lead-free as a selling point, even though a lead-free
version of the product had been available for two years. Nick Jolly
commented: "Most of the companies we looked at did mention lead-free in
their brochures, and usually had separate brochures on their environmental
policy and performance, but for whatever reason they did not decide that it
was necessary or appropriate to market this to the consumers."
        Nor has legislation played a significant role, not Japanese
legislation anyway. It is true that the added impetus for the abolition of
lead was driven by the first draft of the European WEEE directive back in
1998. The slipping back of a European lead ban from 2004 to 2008 [the date
that was proposed at the time of writing], has not altered the roadmaps of
the Japanese companies who planned to work well within the initial date.
There is a limited amount of indirect pressure from Japanese legislation.
Lead is only permitted in certain types of landfill site which carries a
cost premium, and there is also new legislation concerning recycling that
requires companies to take back products, although there is no specifics as
to how much of them is recycled.
        Instead the initiative has been taken up by the individual
companies. 'Corporate Environmental Consciousness' was a term that recurred
at many of the companies visited and it was this that left the most profound
impression on the returning mission team. Philip White explained: "They have
senior level directors who are responsible for the environmental programme,
which includes lead-free, and having this at such a high level, it is then a
case of it will be done and so just getting on with it. Lead-free is not a
stand-alone issue, it just forms part of the overall environmental package."
Malcolm Warwick took up the theme: "They have a completely different
philosophy. In Europe we say 'How much is it going to cost you?' in Japan
they decide they are going to do something and then decide the most
efficient and profitable way of going about it. It is all about belief in
what they are doing."

Excerpt from the IPC Board of Directors Position Statement
        The US electronic interconnection industry, represented by the IPC,
uses less than 2% of the world's annual lead consumption. Furthermore, all
available scientific evidence and US government reports indicate that the
lead used in US printed wiring board (PWB) manufacturing and electronic
assembly produces no significant environmental or health hazards.
Nonetheless, in the opinion of IPC, the pressure to eliminate lead in
electronic interconnections will continue in the future from both the
legislative and competitive sides.

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