My thanks to Joe Smetana for bringing to my attention a recent essay
defending RoHS written by Ray Franklin of ROHSwell.com. This essay is
available at  http://www.rohswell.com/News/Genl020.php. Since I don't
know how long Franklin's essay will remain at that link, I have included
it at the bottom of this posting so as to make it a permanent part of
the Leadfree archives. It has been quite some time since anyone has
presented an argument in favor of RoHS in this forum, so this might make
interesting reading for subscribers. I do offer some comments of my own.

Franklin calls RoHS "the first of many small steps along a path." This
single statement raises a number of questions:

*    Who established the path? As has been the case with this issue from
the beginning, the proponents have preferred anonymity, presumably so as
not to have to engage in the kind of debate that Franklin, in subsequent
comments, seems to favor.

*    What are the next "small steps"?

*    How many more such steps?

*    What is at the end of the path? One answer I have seen is "the
biosphere has been rid of hazardous materials." Apparently "no one is
being poisoned by use of the prohibited materials in electronic
products" is not a good enough answer for him.

*    Who gets to announce that the end has been reached and that there
are no steps of any size to be imposed on anyone?

Later he calls for rigorous scientific proof. As I have asked before,
who gets to decide whether evidence and arguments meet that test? We
have seen how no amount of evidence is enough to satisfy those who
"know" that deca-BDE is unsafe to use, but their own favored substances
are.

In interesting metaphors Franklin refers to those who favor progress on
this path as "cheerleaders" and those who do not approve of this path as
"nay-sayers urging the walkers to veer off onto a different path." He
seems to have confused cheerleaders and policemen.

Yet later in the same essay he asks "Are there good reasons to resist
the push to eliminate lead from solder? Possibly. Perhaps a thorough
analysis of the pros and cons will exonerate Sn-Pb solder for
electronics." This question also raises other questions:

*    Does he realize that by saying this he not only acknowledges that
whoever it was who laid out the path for us all to follow might have
made a mistake, but also that this person or coalition did so without
having done a thorough analysis?

*    Does he realize that the analysis has long since been done?

*    Has it occurred to him that technical merit of the other
prohibitions in RoHS might be just as lacking?

*    Does he realize that the prohibited brominated flame retardants are
not even commercially available?

Apparently it doesn't perturb him that the consequences of this failure
to think before acting has cost the world economy untold billions. His
justification: "When has any human effort ever been perfect the first
time?" Keep that excuse in mind, folks. It can cover a multitude of
sins.

Franklin calls for use of the "scientific method", which he implies that
he understands, then uses statements such as "I have a hard time
believing" and "I cannot support these protests because the tactics seem
to be mostly destructive rather than constructive." Perhaps he needs to
be reminded that the scientific method does not involve his ability to
believe or his assessment of tactics. One wonders whether he would
acknowledge as scientific anything that led to a conclusion he didn't
already favor. That couples with the attitude of environmental activists
that they know what is right for everyone, and anyone who opposes them
is obviously an obstructionist - and wrong. The everyday terms for these
attitudes are prejudice and self-righteousness.

The other statements Franklin makes in support of his beliefs I have
refuted in essays (with evidence and rigorous arguments) that I have
posted to this forum and to the Halogenfree forum, starting seven years
ago. But rather than repeating those refutations here, I thought that
other forum subscribers would like to have a chance to comment on his
claims, and also on any vested interest he might have in seeing RoHS
prevail. 

I am sending this posting to him. He would of course be welcome to post
his reply, or he can send it to me and I will post it for him.

Gordon Davy 

 

Calls to Throw Out RoHS Unnecessary

by Ray Franklin, RoHSwell.com, 5/13/2006 

The RoHS directive is the first of many small steps along a path. The
path

leads to a healthier world for all by eliminating environmental hazards.

Along one side of the path are cheerleaders urging the walkers forward.
On

the other side are nay-sayers urging the walkers to veer off onto a

different path. 

Fundamentally, the RoHS directive is based on toxicological evidence of
harm

caused by the six banned substances. The biological hazards of heavy
metals

are well documented, and the trend for the last 50 years has been the

elimination of these metals from a wide variety of applications. 

In the same vein, RoHS bans two particularly nasty brominated
hydrocarbons.

We have come to understand that many halogenated hydrocarbons are toxic
and

carcinogenic. Our application of this class of compounds has turned them

into persistent organic pollutants (POPs). We are slowly recognizing the

numerous biological impacts of POPs, which include sexual development

abnormalities, diabetes and obesity. 

Despite the large, and growing, body of evidence in support of the RoHS

substance bans, there have been numerous protests against the
legislation.

Two of those protests have recently captured attention: the RoHS
Pushback

Initiative and A Lead Free Essay by Gordon Davy. 

Having read through the blogs and comments on the Pushback Initiative
site,

I get the impression that the group wants to see the RoHS directive
repealed

entirely. I am not absolutely certain of this because the site does not

clearly state what actions supporters should take. However, it does
appear

to be a political effort to derail RoHS. The core complaint seems to be
with

the elimination of lead (Pb) in solder. 

In the same timeframe as the Pushback Initiative, a long article against

RoHS was published on the PCB007 site. The author claims definitive

scientific evidence of no harm from the burning of plastics and no
leaching

of lead from solder. This is completely contrary to my understanding. 

Burning chlorinated plastics (such as PVC and Teflon) produces dioxins
and

furans. Even well controlled incinerators release these chemicals. Both
are

known carcinogens and teratogens. Furthermore, recycling plastic makes
more

sense. There is also a process in production that can turn plastics into

oil, with no pollution. Burning is no longer a reasonable way to dispose
of

plastic. 

Davy claims that lead in solder will not leach into ground water from

landfills. Has basic chemistry suddenly changed? What of lead in
crystal?

Long ago it was proven to be a neurotoxin to those who store wine in
crystal

decanters. And what of lead gutters and roof flashing used so widely in

Europe? Lead in contact with water will leach into the water. If the
water

is acidified (rain, wine, citrus juice) the lead will leach faster. Rain

falling through pristine air reaches the ground as carbonic acid due to
the

CO2 in air. On much of the planet, acid rain (lower pH) falls from the
sky

due to nitrate and sulfate pollutants in the air. 

I have a hard time believing that rainfall through WEEE in a landfill

results in zero lead contamination. If there is scientific evidence to

support this assertion, it needs to be prominently displayed. Before
taking

action, the claims must be scientifically reproduced by multiple
research

teams. That is the scientific method. 

I cannot support these protests because the tactics seem to be mostly

destructive rather than constructive. It would be much more effective
and

helpful to alter the message slightly. Keep RoHS, and exempt Sn-Pb
solder in

electronics. Expand the scope to eliminate Pb in roofing materials,

glassware and plumbing fixtures. 

Are there good reasons to resist the push to eliminate lead from solder?

Possibly. Perhaps a thorough analysis of the pros and cons will
exonerate

Sn-Pb solder for electronics. Rigorous scientific proof of the benign
nature

of WEEE in landfills will be required. In such a case, the correct
action

would be to write the following exemption into the RoHS Annex: 

"Lead in solder used in any electrical or electronic device." 

No need to throw out the entire directive. Just use the built in tools
for

"adaptation to scientific and technical progress." 

The exemption and consultation processes are good ones. The RoHS
directive

is just one step in the right direction. Does it need improvements?

Undoubtedly. When has any human effort ever been perfect the first time?
I

say stay the course, use the processes, and make the RoHS directive into

better legislation, one step at a time. 

Additional Resources 

Irresistible Force Meets Immovable Object - A Lead Free Essay by Gordon

Davy. 

The RoHS Pushback Initiative 

Diabetes From Plastic Reported by Science News 21 January 2006:
Bisphenol-A

in polycarbonate is estrogenic when consumed. The compound has now been

shown to cause insulin resistance, a precursor to diabetes. The chemical
is

widely used in dental sealants, microwavable plastics and numerous other

products. The study was reported in the January Environmental Health

Perspectives. 

Obesity and Flame Retardants Reported by Science News 15 April 2006:

Brominated flame retardants are known to cause neurological and

developmental abnormalities. Now they have been shown to cause fat cell

changes that raise the risk of obesity and type 2 diabetes. PBDE, of a
mix

dominated by penta molecules, caused increased fat circulation in rats
after

four weeks. Increased fat circulation is strongly associated with
obesity. 

Thermal depolymerization Changing World Technologies is developing

production plants to convert any carbon-based waste into oil. The
conversion

process is 85% efficient, burning 15% of the product to run the process.

Feedstocks include agricultural and food processing waste, sewage
sludge,

tires and mixed plastics. The first plant is currently converting

turkey-processing waste into oil in Carthage, MO. This process is the

ultimate recycling tool. 


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