Mr. Santhakumar

As a professional environmentalist and recycler, I am increasingly in
agreement with Joe and Harvey about the lead-free legislation.   

First, the release of metals is rarely most important at the point of solid
waste recycling or disposal.  For example, more mercury is produced by gold
mining than is produced by mercury disposal and mercury mining combined.
Legislation which results in mercury-free products with increased gold
content would result in more kg. of mercury released into the environment.
(As a caveat, I have not had the time or found anyone else putting time to
research the amount of lead which may be released by changes in tin mining
and copper mining which will result.  If it's shown that mining and
exploration will decrease as a result of lf then I may change my vote).

Second, if the point of recycling (and secondarily, disposal) is the narrow
focus of the lead measurement, then it is true that we recyclers will
produce less lead as a by-product by shredding lead-free boards.  However,
we are pretty unconvinced that there will be any measurable change in our
incoming stream over the course of the next 10 years as a result of lead
free (since so much of the used material we receive is "historical").   For
the amount of money it will take to eliminate that portion of the lead, we'd
rather see it invested in recycling or increasing repairablity and reuse,
which are the main source of our income.  (We'd be alarmed if the lead-free
boards were to be less repairable, though we've been told that's not an
issue in previous answers to our posts on this forum).

For me, the single most suspicious thing about lead-free legislation is that
its national support seems to correlate in countries with older, more
depreciated, manufacturing lines, as opposed to countries which have newer,
less depreciated lines.  In other words if a country's OEM is thinking about
retooling anyway, it's less of a concern if competitors with newer plants
are forced to retool sooner. 

If the environmental benefits are demonstrated (point 1 and 2 above), we
environmentalists are not opposed to this type of "raising the bar" by
executive fiat.  But if it's absent, we see it as squandering the
opportunity to leverage a more meaningful environmental activity... Put that
energy into energy conservation or something.

Robin Ingenthron
802-382-8500
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