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August 2001

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From:
"Davy, Gordon" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Tue, 14 Aug 2001 08:03:51 -0400
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My thanks to those who have responded to my recent posts regarding
environmental activists with expressions of approval or concern. I
especially appreciate the thought-provoking response by Seth Goodman,
including his observation that had it not been for past actions by greedy
irresponsible industrialists (my words, not his), the public would not be
interested by what environmentalists are claiming today. That is no doubt
true. Bev Christian refers to lead in gasoline (petrol); I commend to all
forum subscribers a fascinating story by Kitman of how it got there: "The
Secret History of Lead"
http://past.thenation.com/cgi-bin/framizer.cgi?url=http://past.thenation.com
/issue/000320/0320kitman.shtml. It's enough to make anyone upset, it makes
it easy to understand why people would be suspicious of anything that was
issued now by the Lead Industries Association, and it's worth pondering how
the industrialists were able to get away with what they were doing for so
long. We owe a great deal of gratitude to those environmentalists who over
decades made people aware of serious problems that needed to be corrected,
and persevered in getting them corrected. I should have said so publicly
before now. Had it not been for them we might all have much higher blood
lead levels.
However, the environmental activists are to some extent the victims of their
own success. Rivers that previously caught fire now have fish in them, the
air is cleaner, and blood lead levels are dramatically reduced. Assuming
that they don't want to change careers, what do they do next? They have two
choices:
1.      Move on to less pressing problems, and continue to present data and
appeals to reason (with our continued approval), or
2.      Create (discover?) sensational new problems, and support them with
allegations of risk, misleading information, disparagement as irresponsible
of those who oppose them, dire warnings, appeals to intuition, and proffered
"solutions".

Misleaders
I have been attempting to get people to believe that there are those who
have succumbed to temptation and taken the second option. (Those who have
chosen the first option seem loathe to criticize them.) I suppose that lays
me open to the charge that I am a conspiracy theorist on this issue. That's
OK if there really is a conspiracy. If I am right that such people exist,
they know that what they are saying is untrue (or simply don't care whether
it is true or not as long as it useful), but are willing to exploit the
public's concern for the environment for their own ends, while masquerading
as acting in the public interest. It's legal, but is it legitimate?
A second - and rarer - kind of misleader is the industrialist whose motive
to market a product as leadfree is to gain market share, again exploiting
people's concerns by implying that lead-bearing products are a threat to the
environment. It's legal, but is it legitimate?
Whether unprincipled activist or unprincipled industrialist, they are not
misled, they are misleaders. The activists in particular are high-visibility
con men, and while generally we should try to avoid polarization, in this
case I see no more reason to be concerned about their feelings than those of
any other con man. (Perhaps they at one time really did believe that what
they were doing was noble, but if they persist in the face of evidence to
the contrary, then their motives are now different.) There is a dictionary
term for this kind of person: demagogue. The term exists because they have
existed throughout history, and I can think of no reason why they wouldn't
today. Compared to being an ordinary con man, being a demagogue is better:
more rewarding and it's legal.
Here's another way of looking at it: a demagogue needs a good cause to
arouse people's support. If you were an aspiring demagogue, what cause would
you choose? I think that I mentioned before the book Eco-Scam that discusses
the matter:
http://www.amazon.com/exec/obidos/ISBN%3D0312086989/002-7453864-1080009. See
also Apocalypse Not (book review at
http://i2i.org/SuptDocs/Enviro/enaponot.htm).
If I am wrong, that there are no such people at work, but just energetic
public-spirited souls who truly believe in what they are fighting for, then
let someone offer an alternate explanation of how leadfree electronics got
started. Just an honest mistake by over-enthusiastic advocates because they
didn't have all the facts? As I have argued in many previous postings and
again below, the facts are plenty clear today, so if anyone continues to
promote this cause, one must question why.
If I am right, people need to know. Call it polarizing and fomenting
distrust if you like. When you're dealing with a con man, trust and
cooperation are bad and distrust and opposition are good. Do not expect to
hear the truth when a con man tells you what he does for a living. If
there's anything good about this situation it is that if the misleaders
prevail, no one gets sick or dies. We just lose money, superstition
prevails, and they continue to pursue their craft.
In the past, certain industrialists were able to suppress the facts about
lead for a long time (because people trusted them and they wielded a great
deal of power), but the activists eventually got the facts and presented
them, and lead was removed from paint and gasoline. Today, the activists who
are trying to make issues out of lead in electronics and recycling consumer
electronic waste have a great deal of power and they do not want us to
notice that they have no facts. How long will it take for most people to
find this out and respond accordingly?
As Edward Szpruch says, "the electronic industry is the target of the 'lead
free' crusade just because we are an easy target and not because we are the
main contributor to lead contamination." In past postings, I have tried to
alert people to the prospect that if the misleaders get what they are after
with lead, they won't go away and leave us alone. They enjoy what they are
doing and don't want to change careers, so they will just move on to the
next item on their agenda, gloating that they, as million-dollar Davids, are
able to confound (if not fell) billion-dollar Goliaths. Already, as a
warm-up, they are active in state legislatures all over the US attacking a
smaller target, electronic products that contain mercury. (They don't
present any data for their concerns here, either, other than pointing out
that mercury is a poison. Mercury poisoning is at least as rare as lead
poisoning, but so what? What legislator is going to stick his neck out for
mercury?)
I want to counteract the misleaders' misrepresentations and to get forum
subscribers to consider the extent that these people have already influenced
the way we all think about the situation. These people have been amazingly
adept at directing our attention away from their motives (a thirst for money
and power) and tactics (deception) and towards their goals by posing as
experts and watchdogs for the rest of us. Rather than accepting at face
value their claims, we need to start holding them to the same level of
accountability as we do anyone else.

Misled
I do not think that most people who fail to present data to support their
claims are out to mislead us, although the outcome, regardless of motive,
can be the same: wrong beliefs and bad policy. We must make a clear
distinction here. Most just not have done all their homework and have been
misled. The critical distinctions between a misleader and one who is misled
are his motives and how he regards the evidence. The misleader is motivated
by a desire for power and money and doesn't care about the evidence; the
misled are motivated by a desire to do the right thing and are willing to
change their position based on the evidence.
I am not looking to upset anyone by what I am saying, but it is the nature
of deception that the one who is deceived does not know it, and anyone, no
matter how smart, is at risk of being deceived about matters outside his own
area of specialization. Misleaders don't follow the same code of behavior as
the rest of us, and the fact that demagogues are very good at what they do
and are busy misleading makes us all vulnerable. Anyone can fall for a
con-man's scheme.
Because all are at risk, let me suggest that you ask yourself these
questions:
*       In the area of electronics and the environment, do I believe, as
Davy asserts, that demagogues are active? If they are, what should be done
about it - expose them (with consequent polarization) or appease them (with
what consequences)? If they are not, how can I demonstrate the truth of the
matter?
*       Why do I think that lead in electronics and disposal of end-of-life
electronics are significant issues?
*       How good am I at distinguishing propaganda from facts on these
issues?
*       Recognizing that I'm not an expert in such matters as providing
drinking water or waste disposal services, to what extent have my present
beliefs and attitudes about them been influenced by unsubstantiated
allegations (such as that lead in landfills ends up in drinking water or
that we're running out of room for landfills) instead of data and reasoned
discourse? Might I be deceived? How would I react if I began to suspect that
I am - acknowledge it or suppress it? (No one enjoys having to admit to
having been wrong, but better that than persisting in error.)
*       Have I passed along as truth plausible-sounding assertions that I
did not verify because I trusted the source? Did the source have a vested
interest in my believing him? Was the source possibly misled?
It is unfortunate that, when it was so easy for the SMART Group to discover
that there is no consumer pressure for leadfree electronics, no one thought
to check out the allegation (whose?) two years earlier, before a position
statement was issued that said that there is. A great amount of effort has
been expended based on that premise being true - effort that might have been
otherwise directed had it been known that it wasn't true. Incidentally, if
the motive for introducing leadfree products was to increase market share,
it now seems not to have been very successful, but it's too late - the
Japanese companies have started something that will be very difficult to
reverse. (The reason that they give today is that it's the right thing to
do.) Of course if all products are leadfree, there can be no market benefit.
As I argued recently, the only reason these issues are issues is because of
paternalistic bureaucrats in Europe who do not represent the concerns of
most citizens on the matter but are empowered to tell them what they can and
can't buy based on their own beliefs about what's good for them, and
powerful businessmen in Japan who are not responsible for the bottom line
but by banding together are able to pressure their suppliers into giving
them whatever they ask for, again based on their beliefs about what is good.
It is the misleaders who are behind those beliefs.

Victims
There are many people who have become involved in trying to accommodate the
demand from European bureaucrats and Japanese businessmen for leadfree
products. For them, whether the demand is legitimate or not has become
irrelevant. I can see that a forum subscriber who for business reasons is
focussed on "how" rather than "why" could be irritated to have the value of
his endeavors implicitly challenged by my attacks on the legitimacy of the
need to go leadfree, and would prefer to have me keep quiet. If the leadfree
bandwagon were to turn out to have been a house of cards and not a
juggernaut, then there could be a bunch of people who are experts in alloys
and processes that suddenly are of greatly reduced commercial interest. Some
of those people might not mind (it was interesting work), but for others,
that is not a pleasant prospect, and yet another consequence of misdirected
zeal.
While I am sympathetic to their feelings, I believe that it is important to
consider the evidence critically and to arrive at a correct statement of the
situation. The money that continues to be spent on an unwarranted project
(one that adds cost beyond its value) has to come from somewhere, either
taxpayers or consumers, which means that we are all victims.

Evidence
Even though the misleaders don't have evidence, when real info from
independent sources (CDC, the City of New York) are presented by the
(despised) LIA, people challenge it - if not for validity then for the
messenger's credentials (and I suppose by extension, my willingness to
accept and post it). Brian Ellis says "[The LIA] shows the good and hides
the bad." Perhaps other subscribers had similar thoughts. The good that they
show is good indeed. In spite of one's misgivings about the LIA, the only
reason I can think of to attack the data they present would be if one
suspected that they had been altered somehow, and this seems to me to be
highly unlikely, given the opportunity for independent corroboration. (I
assume that the data I posted earlier from the US OSHA are not suspect,
since they came directly from their web site and not via any other
organization.).
Consider the asymmetry in the stakes: if leadfree electronics succeeds, the
lead industry loses two percent of its business. If all electronic products
get recycled, the landfills lose one percent of their business (and most
landfills are not for profit anyway). On the other hand, if the push for
leadfree electronics and recycling were to collapse, it would be because
people lost their faith in the misleaders, who might then have to change
careers because fewer people would believe them about the next
"environmental problem" that they discovered. (Amazingly, some of these
people have made very wrong predictions many times before, but they are so
good at what they do that they manage to continue anyway.) Who has a greater
interest in influencing our thinking - the forces of the status quo or the
misleaders? Who is trying harder?
If there is relevant bad info about lead that is not being told to us by the
LIA (they're in no position today to suppress anything), I would think that
we'd have seen it presented by the activists. Instead, we keep hearing about
"risks" (like lead from landfills getting into the public water supply, and
leaching tests that have no connection to what happens in a landfill)
without any substantiation. It's one thing to consider the risk of doing
something that hasn't been done before, but people have been putting lead in
the ground for a very long time, and if there were a problem from doing
that, we'd already know about it. To talk about risk in this situation is
misleading.
(Just consider the risk and imagine how many objections would be raised if
allowing the dispensing large volumes of a highly flammable liquid by
untrained people at millions of locations worldwide were being proposed as
something new today. There would no doubt be a great deal of opposition -
and even if approved would have lots of imposed restrictions. Those
restrictions are not imposed because as it turns out and contrary to
intuition, there is no need, and the benefits of having readily available
gasoline far outweigh the risk.)
The way that I read the data (from multiple sources), cases of lead
poisoning have almost vanished, and the ones that remain have nothing to do
with electronics. They will not be affected by any decisions people in our
industry make on lead in electronics or recycling. If a forum subscriber has
a different interpretation of these data or other data, please don't hold
back - share it with us. The goal here is not to win the debate - it is to
arrive at the right answer. I'm willing to be shown wrong. But I've been
seeking data to support the activists' assertions on this forum for a long
time now, and it seems only reasonable to conclude that we've already seen
all that exist, and that their assertions were arrived at by some other
process than critical analysis.

Dealing with the misleaders and the misled
As I have already implied, the way to deal with misleaders (exposure with
criticism) is entirely different than the way to deal with the misled
(warning with gentle persuasion), because they have entirely different
motivations. I have no way of knowing whether "vilifying" the misleaders for
their irresponsible behavior will have an influence on the outcome or not,
although I continue to hope that my postings will benefit those forum
subscribers who are concerned about policy issues.
My reason for "derogatory name calling," as Mr. Goodman refers to it, is not
to make myself feel better - it doesn't. It should be obvious that I feel
strongly about the matter, but I am not being emotional in what I say. I
enjoy provoking thought but not hostility. My goal is to exemplify the
behavior that I'm calling for: critical analysis supported by relevant
evidence. My motivation is a sense of old-fashioned duty: to express as
carefully as I can the truth as I see it, even at the risk of generating
opposition. I'm willing to apologize for being insufficiently insensitive to
people's feelings in the way that I express myself (a weakness I
acknowledge), but until I'm shown to be wrong, not for what I'm saying.
The terms for misleaders that I used in previous postings I simply and
deliberately selected, in an attempt to get people thinking, as  the very
ones that they have used to characterize their opponents (and because they
fit their behavior). And I weighed the risks before deciding to introduce
new terms for them in this posting. If we have difficulty dealing with a
doctrinaire activist, it may not be because he is upset with how he has been
labeled (anyway, I haven't used anyone's name) but because he needs an issue
and knows that he can't prevail when decisions are to be arrived at
logically.
I believe that it is desirable to risk spending some money (whose?) to take
the whole issue directly to the public (mount an advertising campaign) to
tell people that decisions are being made for them by vested interests who
don't know, or don't want them to know, the truth - to try to undercut the
misleaders' base of support. It took decades to reveal the truth about lead
in gasoline and paint; who knows how long it will take to counteract the
present generation of misleaders? Forever, if no one tries. This may be a
call for altruism, with little chance of success, but I'm expressing it
anyway. Nothing ventured, nothing gained. Maybe someone will have a bright
idea on how to get free publicity outside the leadfree forum. Maybe we can
find (or convert) our own demagogue!
The EIA Environmental Issues Council is right now negotiating with advocates
for recycling end-of-life consumer electronics. They claim that in so doing
they are being proactive. (I don't agree, because if it weren't for the
misleaders having created the "problem" in the first place, no one would be
considering it.) What they mean is that the advocates are promoting
recycling and product takeback in a number of states, and since the EIA
figures that the advocates will be successful in at least some of them and
it would be very inconvenient to have to deal with a bunch of different
rules, they are working with these people so they can at least choose their
poison. (The EIC is also fighting the mercury brush fires that I alluded to
above, started by the same misleaders, by lobbying in state legislatures.)
No doubt many of the EIC participants really believe that recycling benefits
the environment. In any case, they may very well be right in saying that
recycling and product takeback laws are coming and that their negotiations
to come up with a standard USA-wide approach are necessary to minimize the
risk to their member companies.
In any case, it seems unlikely that consumers in any state will have a
chance to make the decision about electronics recycling by any sort of
referendum (any more than in Europe), yet they are the ones who will of
course end up paying for it in taxes or fees. I don't see consumer interests
on this matter being represented in legislatures or anywhere else. Whichever
way recycling ends up being subsidized, the costs will be imposed on
customers of all companies that provide electronic products. Thus there will
be little economic hardship on any one company, and hence little incentive
for a company to oppose their imposition.
Some recycling of electronic products occurs today, because it makes
economic sense without being subsidized. See for example,
http://www.enviroinc.com. The critical question has to do with requiring
consumers to recycle their unwanted TVs and computers (instead of just
sending them to the landfill) whether they want to or not. Instead of asking
us to take it as obvious that such recycling is noble and good for the
environment (and it's merely a question of how to make it happen), let those
who want the rest of us to pay (voluntarily or by coercion) for the schemes
they come up with present us a reasoned cost-benefit analysis - numbers, not
just rhetoric. Show that the benefit to the environment is worth the extra
money that must be spent.
I've made this appeal for data before. Every analysis I've seen so far does
not support the notion. Let them not try to impress us with the number of
tons per year of electronic waste but give it to us as a percentage of
municipal solid waste so we can put it into perspective. Yes, the amount of
waste electronics might increase - to two percent instead of one. So what?
If they are going to predict a "large economic hardship in the
not-too-distant future," then let them show how they arrived at that
prediction and consider all the alternatives for avoiding it (let me mention
again that where it has been implemented, the EPA's "pay-as-you-throw"
option to ensure that waste disposal is not subsidized has substantially
reduced the flow of waste into landfills) instead of presenting recycling as
the solution whose merits are so self-evident that they need no
documentation.
Mr. Goodman says that it will be a long time before cost-benefit analyses on
recycling can be performed. He doesn't tell us why he says that, but since
he apparently has not seen such an analysis, he must have arrived at his
belief by some other means, and wants us to do so, too. Maybe we just
haven't consulted the right (impartial, non-dogmatic) experts in waste
disposal. I mentioned before the work of Prof. Clark Wiseman done years ago.
If the need to "do something" about the perceived problem is great enough,
it should be possible to find the funds to arrive at the proper decision in
the proper way. Beware the activist who says, "We haven't got time to
deliberate. We must act now!" Let's get the analysis first, and then make
recommendations for change based on it rather than the other way around.
If I am right, subsidized recycling of used consumer electronics will turn
out to be not noble, not even neutral, but a waste of resources - a bad
idea. As I argued previously, should it start to make economic sense, no
committees, no appeals, no voting, and no coercion will be needed. Recyclers
will start paying for the stuff, and it will happen all by itself overnight.
I recently suggested that when you hear a speaker allude in Slide 1 to the
"risks" that are prompting going to leadfree, to ask him what data he has to
support the allegation of risks. While this may sound rude or
confrontational, the motive is not to embarrass him but to prevent bad
thinking and decision making. There's too much at stake not to be thorough
in our analysis, even if it unavoidably produces some embarrassment. (This
problem should go away once people realize that they need to support their
ideas with facts instead of appeals to intuition.)
For example, the EPA, with IPC cooperation, has been looking for "cleaner
alternatives" to hot air solder leveling. Did they establish a baseline of
HASL "uncleanness" before embarking on the search for alternatives, or
proceed on perception and intuition that the uncleanness was obvious? OSHA
has not found elevated blood lead levels in electronic manufacturing
workers, so how will anyone suffer if people ignore the EPA-IPC contribution
and continue with business as usual? Will the decrease in the level of
suffering, if any, justify the costs of abandoning HASL? If they have these
data, perhaps they'd be willing to share them in this forum, or in their
report at the fall meeting.
I will close by mentioning that the IEEE Computer Society's Technical
Committee on Electronics and the Environment has announced the 2002
International Symposium on Electronics and the Environment, to be held May
6-8 in San Francisco. I just received the announcement in the mail, and it
isn't shown yet on the committee's web site (http://computer.org/tab/ehsc),
but subscribers may be interested to know about it. I went to the 1999
Symposium when this was all new to me and got exposed to a bunch of
activists!

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

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