Here it's not so bad because of the typhoon that passed through a few days
ago and the rain since. I was in Shanghai and Beijing before coming
here...smog and particulate matter (particularly in Beijing from sand/dust
storms)...ugh. But everyone is a-buzz about the 2008 Olympics - it's wild.
On Saturday we were walking up the Great Wall and the pollution was pretty
miserable....I was coughing for a few hours afterwards. I'll try and post a
photo later on today.
Mike
-----Original Message-----
From: John Burke [mailto:[log in to unmask]]
Sent: Monday, May 22, 2006 9:14 AM
To: 'Michael Kirschner'; '(Leadfree Electronics Assembly Forum)'
Subject: RE: [LF] Ray Franklin's defense of RoHS
Watch out for the air pollution............8-)
Its terrible in some places there - I speak from personal experience...
John
----------------------------------------------------------------------------
--
From: Michael Kirschner [mailto:[log in to unmask]]
Sent: Sunday, May 21, 2006 6:09 PM
To: John Burke; '(Leadfree Electronics Assembly Forum)'
Subject: RE: [LF] Ray Franklin's defense of RoHS
John,
I did put "run" in quotes ;o).
Oh I believe there is no cognitive dissonance regarding paragraphs 7 and
8. Lead's nasty stuff as a general rule. But is it in this particular
application? Perhaps not...so the precautionary principle allows a measure
to be temporary and "if necessary, adjusted to take account of available
technical and scientific information" as the last part of paragraph 8 says.
So this is perfectly consistent. You're just reading it from one direction
while they are writing it from the other. ;o)
Regarding the scientific research, they never said "they did it"; they
said "it's been done" but they never state by whom and at what level and
under what circumstances the research was done (perhaps by the Roman Empire
in the case of lead...). Since they are banning substances and exempting
specific uses, it would make sense to consider that the scientific research
they're resting the decision on is at the substance level, not the
application of the substance and in fact that is what it says: the
SUBSTANCES themselves ... are scientifically well-researched, not these
particular applications of the substances. So providing further scientific
evidence that shows there is no toxicity problem, or that environmentally it
is the lesser of two evils, in a particular application (i.e. lead in
solder) is presumably the right way to proceed, which you are doing.
Mike
I'm 15 hours ahead here, where it's a miserable rainy, warm, muggy Monday
morning...
-----Original Message-----
From: John Burke [mailto:[log in to unmask]]
Sent: Monday, May 22, 2006 7:21 AM
To: '(Leadfree Electronics Assembly Forum)'; 'Michael Kirschner'
Subject: RE: [LF] Ray Franklin's defense of RoHS
Mike,
Depends on your idea of "running".....8-)
They don't have countries to run - as such - they just have policy to
make - trust me I am a European - if they had a country to worry about we
might not see these kinds of issues since they would have one environmental
department involved instead as I suspect of a committee.
They have legislation to make based on "common policy" FOR other
countries as evidenced by the total confusion on WEEE and RoHS
implementation by those countries in the EU, If they were "running" them
this would not have been a factor. The governing body in Brussels called the
EU is what used to be called the "EEC" or European Economic Communit before
which it was simply called the "common market", whose member countries can I
believe opt into or opt out of; and basically is there to create common
policy for the member countries - although England ( yay - that's where I
was born - London) has chosen not to adopt the monetary policy.
As regards due diligence expectations I quote from the EU Directive
2002/95/EC:
(7) The substances covered by this Directive are scientifically well
researched and evaluated and have been subject to different measures both at
Community and at national level.
(8) The measures provided for in this Directive take into account
existing international guidelines and recommendations and are based on an
assessment of available scientific and technical information.
And of course it is dated 2003. So there we have it - they SAY they did
it but try asking for the report..........
So on the "due diligence" it is not my "expectation" it is their rule
book - they have to do it, they said they did it according to this, but
didn't as Brian pointed out - freaked out? You betcha..........and with good
reason.
John
PS how many hours ahead of Pacific are you?
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner
Sent: Sunday, May 21, 2006 3:19 PM
To: [log in to unmask]
Subject: Re: [LF] Ray Franklin's defense of RoHS
John, et. al.,
I was reading some of the posts on pcb007 and stumbled on a reply from
Ray
Franklin:
http://www.pcb007.com/anm/templates/article.aspx?articleid=7405&zoneid=1
27&v
=
I sent him the URL for this forum ;o)
Ray does make the point that this is the "precautionary principle" at
work...it is as he says the opposite of the prior governmental approach
to
chemicals promulgated by the US in 1976's Toxic Substance Control Act,
which
places responsibility for determining that a chemical is toxic and
should be
removed from the market on the EPA, then ties it's hands. REACH and the
precautionary principle would have industry understand fully the toxic
and
ecotoxic nature/risks/hazards of new (and old) chemicals and chemical
applications before putting them on the market, vs putting them on the
market and seeing what happens. Thus your expectation that "government"
does
the "due diligence"; they expect industry to do the "due diligence".
Suddenly our world is turned topsy-turvy and that's what has everyone
freaked out.
Members of the European Parliament are elected officials. I think they
have
many countries to "run", but in a seemingly very different way than most
other political monsters we have seen.
Mike
-----Original Message-----
From: John Burke [mailto:[log in to unmask]]
Sent: Monday, May 22, 2006 2:41 AM
To: '(Leadfree Electronics Assembly Forum)'; 'Michael Kirschner'
Subject: RE: [LF] Ray Franklin's defense of RoHS
Hey Mike, didn't realize you were traveling.
Interesting dialogue.
I believe one of the potential issues with the EU legislation is that
they
did not as Brian pointed out do the "due diligence".
Maybe part of the issue here is that they do not have a country to run?
And
so do not have the usual boring issues of standing for re-election in
the
country whose laws they changed without "due diligence".
To answer the question "why now?" - not entirely accurate, people have
been
applying for (and having turned down) applications for a lead in solders
exemption since '2004, I actually sent one case of this back to the EU
as a
part of my support for the 9 exemption requests on which RoHSUSA has
sent
support docs to the EU, and can be downloaded either there or from the
http://www.rohsusa.com site. The reason I sent that document back is to
show
them that since they didn't do due diligence there are now available
plenty
of materials where people did, including the EPA report which I have
sent in
support of those applications. WE also sent that same document among
others
as primary evidence for the blanket application which I filed with the
EU
Commission for a complete lead in solders exemption on environmental
grouds
and which arrived there yesterday - again details on the site.
Lets face it they (the EU)only cut this thing together officially in
2003
here is the document header:
=======================================================================
32002L0095
Directive 2002/95/EC of the European Parliament and of the Council of 27
January 2003 on the restriction of the use of certain hazardous
substances
in electrical and electronic equipment
Official Journal L 037 , 13/02/2003 P. 0019 - 0023
Directive 2002/95/EC of the European Parliament and of the Council
of 27 January 2003
=====================================================================
So I guess the difference is before release it was just an ugly rumour
as
far as the "main industry" was concerned. Of course trade associations
and
people "in committee" saw it coming a long time before, and in the case
of
the trade groups should in my opinion been pushing back on the
foundation of
the proposals which would have revealed the lack of due diligence.
It is late, but the environmental question mark still hangs over this
one.
The reviews for round 5 and 6 stakeholder consultations will be
interesting.
Travel safe.
John
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner
Sent: Sunday, May 21, 2006 6:08 AM
To: [log in to unmask]
Subject: Re: [LF] Ray Franklin's defense of RoHS
Brian,
This forum agreed a couple years ago to keep it called "lead-free"
despite
the fact that it was becoming more and more about RoHS. It is not simply
about "lead-free" and has not been for a long time. So [LF] does not
mean
that this forum is ONLY about solder. If it were it would be far less
interesting.
As I say every time I give the presentation about these laws being
adoped
around the world, we're not at the "United Federation of Planets" stage
yet
so stating that the only way this is acceptable is if the entire world
implements it is a red herring...things like this have to start
somewhere,
then they propogate for better or worse...then hopefully they change. So
if
there was no "risk assessment" why was the directive allowed to go all
the
way to law without legitimate and hard-fought protest? Why is protest
starting now, three and a half years after promulgation? Feh.
The EU is exercising it's new-found power. Go read my friend Mark
Shapiro's
article entitled "New Power for 'Old Europe'" at
http://www.thenation.com/doc/20041227/schapiro (it's dated at points but
explains the situation well). The world has to bend to the EU's whims
for
products that are built uniformly for the entire world...like
electronics
(and soon chemicals)...or skip the EU as a market; that is an option,
right?
(I guess it's an option like the Existentialists say there are options
besides suicide). That's what the EU diplomats say.
You think understanding toxicity of chemicals is folly? You want PBBs
and
PBDEs back in electronics? Really? There's this concept of the "line
item
veto" here that we need ... I disagree that all of RoHS is bad solely
because of the lead in solder issue...and as a counter to your "parson's
egg
rule" I would present the "Jackson Five rule": "one bad apple don't
spoil
the whole bunch" ;o)
By the way, the UN has a long-term chemical plan called SAICM - the
Strategic Approach to International Chemical Management that will be
rolled
out over the next 15 to 20 years. So there is international action on
this...just not nearly to the degree that REACH manages chemicals.
Mike (punchy in Shenzhen)
-----Original Message-----
From: Brian Ellis [mailto:[log in to unmask]]
Sent: Sunday, May 21, 2006 4:27 PM
To: (Leadfree Electronics Assembly Forum); Michael Kirschner
Subject: Re: [LF] Ray Franklin's defense of RoHS
I agree, but, if you look at the subject of these e-mails, they are
prefixed [LF], not [CdF], [HgF] or any of the others, even though there
has been the occasional thread about these from time-to-time.
However, if the parson's egg is all right in parts, it really means the
whole egg is rotten. Believe me, no environmental risk assessment has
been conducted on any of the other elements and substances, as used in
electronics, either. There is a requirement for such an assessment
before a Directive is proposed. This was ignored, "for lack of funding".
I therefore suggest that it could be argued that the whole of RoHS and
WEEE could be declared null and void on procedural grounds.
As for REACH, I would welcome something along those lines, on condition
that it were promulgated on a global basis, not just in Europe, perhaps
jointly by UNEP, WHO, WTO, ISO and BIT. It would then mean that everyone
would be subject to the same regulations and the stupendous cost of such
a folie de grandeur would be more evenly distributed, with no competing
norms.
Brian
Michael Kirschner wrote:
> 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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