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January 2005

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Subject:
From:
"Davy, Gordon" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Fri, 7 Jan 2005 10:57:14 -0500
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A number of forum participants have been expressing rather pessimistic feelings about what can be done about the EU's desire to protect us from dangerous substances, regardless of the consequences. And Kay Nimmo has mentioned that "Every metal, and the risk from every use of it, will be evaluated under the EU's new draft chemicals policy that will come in to effect around 2007." (Incidentally, it isn't necessary to consider risk from materials that have long been in use - just look at consequences.)

It has become commonplace in this forum to express contempt for the supposed public servants that brought us RoHS and WEEE. Forget protecting the world from hazardous materials - who will protect us from the legislators? That seems difficult to achieve, as the EU government seems to be so undemocratic and elitist, answerable to no one.

I think the situation, though discouraging, is not hopeless. It does require some vision. Certainly we forum subscribers are virtually powerless to deal with the situation. Even our employing companies - the manufacturers who are affected -  aren't really in a position to do much about it acting individually. But the industry associations can have, and have had, an influence.

In the early 1990's, when Senator Reid from Nevada proposed lead-free electronics legislation in the US, the industry associations sprang into action and were successful in derailing it. However, when WEEE was first announced as being under development in the late 1990's (RoHS was split off from WEEE later) for whatever reason the industry associations, while acknowledging that there was no scientific merit for the restrictions, mentioned "market forces" (never substantiated and apparently accepted as inevitable) and essentially sat on the sideline. They advised their members "come to our seminars to learn to live with it." (At least efforts to promote halogen-free board materials have been resisted as nothing more than marketing.)

I have stated before, and will state again, that had one percent of the money spent getting ready to comply with RoHS been spent on a marketing campaign in the EU countries, attempting to alert the citizen-consumers to the fraud that was being perpetrated at their (ultimate) expense for their purported benefit, the legislation might never have been passed. The industry associations should have been able to formulate a vision and a plan and get the buy-in of the member companies to mount such a campaign. But they didn't.

It may still not be too late. The growing awareness of the lack of scientific evidence that the legislation will save any lives, and of the implications of higher soldering temperature and tin whiskers for product reliability (increasing the WEEE stream) make it possible that a grass-roots revolt by ordinary European citizen-consumers could be successful. One percent is a small risk to take, I'd say, for the benefit that would accrue. 

Yes, a great deal of money has already been spent preparing for RoHS, and that can't be recovered. But the prospect of continuing efforts to ensure conformance, of litigation over alleged nonconformances and field failures, and of further irrational prohibitions - bismuth, silver, nickel, copper, more halogenated flame retardants - mean that our industry's vulnerability to arbitrary actions by a hostile environmental-activist legislature remains. The problem, as I see it, is lack of vision. Or nerve.

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

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