On Fri, 19 May 2006 13:39:42 -0400, Davy, Gordon <[log in to unmask]> wrote:
[deletia]
>* 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.
>
This is all eminating and propogating from the EU.
>* What are the next "small steps"?
The EuP directive; the REACH regulation (that is NOT a small step; once
passed it could have enormous consequences that make RoHS pale by
comparison). The phthalates ban in toys in the EU. Similar legislation to
all of these in China, Korea, California, Maryland, and elsewhere.
Legislators pick up on these "solutions", often without applying their own
scientific rigor, and adopt them. Japan is so far different; they have not
adopted RoHS, but rather just a marking regimen for the 6 substances,
because of lack of scientific evidence (which I agree with in some cases -
like Pb in solder - but disagree with in many others - like the rest of the
RoHS substances).
>
>* How many more such steps?
How many more chemicals? How many more countries/states/cities/regions? Good
question. "Lots" is the answer. Maryland is trying to ban bisphenol-A and
phthalates in toys for children under 3. Bisphenol-A is used in lots of
plastics and epoxies (like IC mold compounds). A similar bill failed in
California last year...where a version of REACH is likely to emerge.
>
>* 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.
In general this movement goes beyond the narrow scope of electronic
products; it's just that they've now brought it around to focus on our
indistry. The end? Not in our lifetime.
>
>* Who gets to announce that the end has been reached and that there
>are no steps of any size to be imposed on anyone?
Envision a Star Trek-like utopia in the distant future...;o) Seriously, the
EU has an extraordinary lead in this area and is intent on spreading its
influence in environmental matters to developing (and developed) economies.
The US has had no say in the matter as a nation (feeble attempts have been
made like having Colin Powell tell the new EU member states that REACH is
not in their best interests); our federal government is completely unfocused
on this issue. So if there is an answer, today it looks like it's the DG
Environment in the EU and all their followers.
>
>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.
Answer: Government bureaucrats and legislators.
[deletia]
>
>* Has it occurred to him that technical merit of the other
>prohibitions in RoHS might be just as lacking?
>
Drink some mercury and call me in the morning ;o) Seriously, there are
studies showing that Americans have substantially more PBDEs in their
systems than most other countries...we are surrounded by plastics. PBDEs
(and PBBs) are known PBTs - persistent/bioaccumulative/toxic. Hex chrome is
dangerous if ingested...I have no idea how dangerous it is as used in
products but perhaps the issue there is in the handling and the
manufacturing and mfg waste processes...remember Erin Brockovich?
>* Does he realize that the prohibited brominated flame retardants are
>not even commercially available?
In the US. China still manufactures PBDEs and the US ceased manufacture only
2 years ago. Companies will move manufacturing of banned chemicals to
countries they are not banned it. BASF is moving it's phthalates
manufacturing to Tennessee from the EU because they're not banned for use in
the US but are in the EU.
I'm not necessarily interested in defending Ray here, but this forum and,
the United States in particular as a nation (I know many of you are not
based in the US), has to get a grip - we are not in control of this...that's
the point I've tried to make here. If we want to get in control we have to
do it at a much higher level and be much more involved in the legislative
processes around the world.
Industry has a story to tell; but the other stakeholders do too. We tried to
use flame retardants in plastics to lower the risk of fires...we picked
flame retardants that accomplished the task but failed to understand the
long term toxic and eco-toxic effects of them. Now they're banned and we
have to find other ones, which is a hardship to be sure. We as an industry
always try to do the right thing but we (like most industries) miss the
environmental aspect...government is coming back to us saying 'fine,
continue to make these great products but do a better job up front in
understanding the environmental characteristics of the substances being
used'. That's not unreasonable, is it? We're all human - I don't want these
damned substances floating around my system or my childrens'! Do you?
The fact is, we have an extraordinarily poor understanding of the toxic and
eco-toxic nature/effects of most of the chemicals in use around the world
today. This is what is raising alarm bells and driving this and the upcoming
chemical restrictions we'll be seeing.
Mike
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