For the attention of Anna Passera -
Good morning - and I would like to take this opportunity of thanking you and
your team on the excellent attention my various documents have received over
the last few weeks - Thank you so much it is appreciated.
Please confirm receipt of these documents, unless these new applications for
exemption are posted immediately and not just before stakeholder
consultations are announced. Also please let me know when to expect the
stakeholder round 6 public review period.
Thanks and Kind regards,
John Burke
Transcript of the attached application document.
TO:
European Commission
DG Environment, Unit G4 - Consultation Directive 2002/95/EC
B-1049, Brussels, Belgium.
Attention of Anna Passera
20 May 2006
From John Burke, CEO RoHSUSA Inc, Santa Clara California
Subject:-
Exemption application under ENV:Directive 2002/95 EC Article 5(1)(b) for
lead in solders
Dear Sirs,
Article 5(1)(b) of Directive 2002/95/EC provides that materials and
components can be exempted from the substance restrictions contained in
Article 4(1) if their elimination or substitution via design changes or
materials and components which do not require any of the materials or
substances referred to therein is technically or scientifically
impracticable, or where the negative environmental, health and/or consumer
safety impacts caused by substitution outweigh the environmental, health
and/or consumer safety benefits thereof.
The Directive states that:
(5) The available evidence indicates that measures on the collection,
treatment, recycling and disposal of waste electrical and electronic
equipment (WEEE) as set out in Directive 2002/96/EC of 27 January 2003 of
the European Parliament and of the Council on waste electrical and
electronic equipment (6) are necessary to reduce the waste management
problems linked to the heavy metals concerned and the flame retardants
concerned. In spite of those measures, however, significant parts of WEEE
will continue to be found in the current disposal routes. Even if WEEE were
collected separately and submitted to recycling processes, its content of
mercury, cadmium, lead, chromium VI, PBB and PBDE would be likely to pose
risks to health or the environment.
(6) Taking into account technical and economic feasibility, the most
effective way of ensuring the significant reduction of risks to health and
the environment relating to those substances which can achieve the chosen
level of protection in the Community is the substitution of those substances
in electrical and electronic equipment by safe or safer materials.
Restricting the use of these hazardous substances is likely to enhance the
possibilities and economic profitability of recycling of WEEE and decrease
the negative health impact on workers in recycling plants.
(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. The measures are
necessary to achieve the chosen level of protection of human and animal
health and the environment, having regard to the risks which the absence of
measures would be likely to create in the Community. The measures should be
kept under review and, if necessary, adjusted to take account of available
technical and scientific information.
I have highlighted a number of areas in the directive which recent
scientific evidence has revealed to significantly impact the direction of
this directive.
ITEM above (6) states the Community position on substitution of safer
materials. The evidence submitted with the check lists in this application
prove conclusively not only that such environmentally acceptable substitutes
are not available and that the ones currently offered are several times more
damaging to the environment.
ITEMS (7) and (8) above state that the substances covered by the Directive
are well researched, and take into account international guidelines and
recommendations. Unfortunately it is our belief that the environmental
impact of lead in solders must have been overlooked in this statement,
unless it was made as a part of a "recommendation" since we can find no
support for the statement as applied to this particular materials group.
The only conclusion we can come to is the conclusion that the material
concerned - lead (Pb) used in solder, has been assumed to have the same
environmental benefit by its removal as similar initiatives to remove lead
in paint and gasoline. This may have occurred as a part of the
"recommendation" process. The banning of lead in solders is clearly not only
not beneficial, but all replacements offered are significantly more damaging
environmentally as evidenced by modern scientific analysis of the situation,
by authorities from both Europe and the USA, which are submitted in support
of this statement.
The closing statement in paragraph (8) "The measures should be kept under
review and, if necessary, adjusted to take account of available technical
and scientific information." This is the reason for this exemption
application on lead in solders - to ask for adjustment through exemption,
and we trust that this application for exemption will be taken in the spirit
in which it is submitted - one of extreme concern that the environment is
going to suffer badly as a result of this lead in solder ban unless the
exemption is granted.
As an example of the environmental issues this will cause unless this
exemption is granted can be seen by a quick review at the "Solders in
Electronics: A Life-Cycle Assessment (472 pages)" document, which
illustrates that the replacements for "leaded" solder generally referred to
as "SAC alloy" have a much higher environmental impact than tin lead solder
in a number of areas such as:
Non-renewable resource use
Energy use
Global warming
Ozone depletion
Water Quality
Particularly tables ES-4 and ES-5 may specifically be found useful in
comparing environmental impact.
The reports findings in terms of Non Renewable Resources are that:
"The difference between SAC (the replacement solder) and SnPb (the leaded
solder) is 453 kg of NRR per 1,000 cc of solder applied. If this were all
automotive gasoline, this difference is equivalent to 162 gallons of
gasoline. "
So in closing, the replacement materials have a much higher impact on the
environment than the materials that they replace and it is our view that the
exemption for lead in solders for electronics use should be allowed.
Respectfully submitted to the European Commission
May 20th 2006
John Burke
CEO RoHSUSA Inc
[log in to unmask]
http:.//www.RoHSUSA.com
Enclosures:
Lead In solders exemption application.doc - Lead in solders exemption
application prepared and submitted by RoHSUSA Inc
Lead in solders exemption checklist.doc -containing TABLE I - CHECK LIST
PROPOSALS FOR FURTHER EXEMPTIONS FROM THE REQUIREMENTS OF ARTICLE 4(1)
OFDIRECTIVE 2002/95/EC FOR SPECIFIC APPLICATIONS OF LEAD, MERCURY, CADMIUM,
HEXAVALENT CHROMIUM.
Primary support documents:
lfs-lca-final.pdf -containing Environmental Protection Agency (EPA) report
Solders in Electronics: A Life-Cycle Assessment (472 pages) August 2005
submitted as evidence.
Stuttgart.pdf - The University of Stuttgart Department of Lifecycle
engineering paper on soldering with and without lead.
Secondary support documents:
JES00C337.pdf - "Effects of Lead on Tin Whisker Elimination Efforts toward
Lead-Free and Whisker-Free electrodeposition of Tin" by Wan Zhangz and Felix
Schwager
Expo99.pdf - Edwin B. Smith III and L. Kristine Swanger K*Tec Electronics
Sugar Land, TX presented at IPC Printed Circuits Expo 1999.
===========================================================================
===========
For those on the CC list you can get the documentation at
<http://www.rohsusa.com/> http://www.rohsusa.com after 5/21/06 and choose
the Exemptions Latest option
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