Gordon
Whereas your desire to foment a revolt may be laudable, I cannot believe
that it would have any positive effect. Europe has, unfortunately, never
listened to its own electorate (does that sound familiar?) and life is
not that simple. There are roughly 125,000 Directorates and other
regulations that each of the 25 member-states are supposed to implement
within their own rule making. If my arithmetic is correct, that makes
over 3 million regulations. Do you really think that anyone would even
bother to consider changing a fait-accompli at this stage? There are
many more important fish to fry, such as the curvature of cucumbers,
considering that the amount of lead involved is so small.
There is much precedent for this. RoHS is not just one rule, it is a
different rule for each of the 25 countries, each with different
potential sanctions, interpretation etc. It is an extremely rare
occurrence (if it has ever happened) for Europe to change horses in
mid-stream, even in cases where errors have been made. Some of the
results would have been laughable, if it weren't so sad and pathetic. I
can quote a number of equally bad decisions, but they are totally
unmoveable.
I'm sorry, but you would be better simply to accept the decision with as
good a grace as you can muster. I have done this, although it doesn't
stop me ranting over the sheer stupidity of the situation.
Anyway, you ain't seen nothing yet: a non-negligible section of the
European chemical, chemical-importers and chemical-users industries is
condemned to death when REACH shows its teeth. It will evolve so that
the choice of products available will be very limited in number, simply
because the cost of registering each molecule will be prohibitive. The
German chemical industry, alone, estimates it will cause a drop of
employment of ~35,000 to 50,000, representing over 25% of the workforce
and that is just in one country. It will result in a massive export of
processes to countries which don't have such severe regulation.
Brian
Davy, Gordon wrote:
> 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
>
>
> -------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
> To unsubscribe, send a message to [log in to unmask] with following text in
> the BODY (NOT the subject field): SIGNOFF Leadfree
> To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
> Search previous postings at: http://listserv.ipc.org/archives
> Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
> -------------------------------------------------------------------------------
>
-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------
|
