I haven't time for a detailed reply, but it's clear that Mr Franklin's
knowledge of toxicology, epidemiology, chemistry, earth sciences and
engineering are sadly lacking. All he has done is propagate errors of
others, usually out of context.

I don't know what his qualifications are but I did find this:
[quote starts]
About RoHSwell

The name came to me in 2004, a couple of months into a contract job with
a local electronics firm here in Fort Collins, Colorado. I was helping
to define and implement a RoHS compliance program. The requirements were
new to me and to all but a few of the employees at the company. I
quickly realized that information about RoHS and WEEE was hard to come
by. The whole program had an alien feel, and Roswell, New Mexico sprung
to mind. It was a short skip to RoHSwell.

My contract work ended with the cancellation of the compliance program.
However, my interest in RoHS and WEEE remained. I had learned a great
deal about the specifics of implementing a compliance program and
developed contacts within the industry. Information on the web was still
sparse and hard to locate. I resolved to eliminate that particular
barrier, and within a month I had launched RoHSwell.com.
[quote ends]

So here we have a guy who admits he knew nothing about the subject in
2004 and who was so competent that he states his client abandoned the
work he had done on it, causing the bug to bite him, probably with a
view to declaring himself an expert to obtain other contracts. IOW, he
had an apparent vested interest in studying the subject. It's called
jumping on the bandwagon.

Gordon, Harvey, Joe, Werner, John and many others (I'm too modest to
name them all :-) ) have been arguing the **scientific** wisdom of RoHS
from well before the time that the Directive split off from the proposed
WEEE one and, I believe, none of us have any vested interest other than
the well-being of our industry. I had published my feelings on the web
long before Mr Franklin had started his study. You can see what I wrote
at http://www.cypenv.org/worldenv/files/sustainability.htm#RoHS (this
was originally published on the now-defunct protonique.com site).

Brian

Davy, Gordon wrote:
> 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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