On Sat, 20 May 2006 10:17:06 +0300, Brian Ellis <[log in to unmask]> wrote:

>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.
>
[deletia]
>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).
>
What Brian, "Gordon, Harvey, Joe, Werner, John and many others" have been
arguing is against the impact of RoHS on lead in solders. You all have NOT
been arguing at all, as far as I can tell, about the REST of the directive.

There is no doubt that mercury, hex chrome, PBBs, PBDEs, and cadmium are
toxic and hazardous - some in use, some in manufacture, some in disposal. We
should elminiate them. Period. That's the vast majority of substances
restricted in RoHS - 5/6 to be precise ;o).

Lead is hazardous if ingested ... we at least know that. Don't sit there and
chew on that plastic coated wire (people do; they don't tend to chew on
PWAs...) or you could get lead poisoning...right? Is there a risk that it
can leach from landfills in to ground water where it presents a hazard? Is
it hazardous during use? Is it hazardous during manufacture? Is the mining
and refining process particularly hazardous? No the EU did not make clear
it's case for restricting any of these substances in products. The industry
should've done a better job arguing it 8-10 years ago. Now it's too
late...the law's in place. Get the scientific evidence together to detail
it's benign or controllable nature in each of these stages of its lifecycle
and then present it to the Commission.

But don't rail against RoHS; rail against the restriction of lead in solder.
Be clear; be precise.

Mike

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