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May 2006

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Subject:
From:
"Dehoyos, Ramon" <[log in to unmask]>
Reply To:
TechNet E-Mail Forum <[log in to unmask]>, Dehoyos, Ramon
Date:
Mon, 1 May 2006 12:46:48 -0400
Content-Type:
text/plain
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text/plain (335 lines)
        The door is ajar, so there is an opportunity. Instead of trying
to convince the consumer who was misinformed and not taken into account
nor given all the information when the green guys made the wrong
decision and enacted ROHS, start with exemptions till all the product is
exempted. The greenies will save face and the world will be better off.

        Something to share:

: The opinion of the Commission is that excluded  *** Exemption***  from
the scope of the RoHS Directive is the equipment which is part of
another type of equipment that does not fall within the scope of this
Directive. Therefore, the equipment that is specifically designed to be
installed in airplanes, boats and other means of transport is considered
to fall outside the scope of the ROHS Directive. The effective date of
RoHS remains July 1, 2006. On exemptions, the European Commission will
likely vote in late May on several exemptions to EU Member State
governments. 
                        	
                                As of April 6, 2006
Source: US Mission to the EU, Dept of Commerce
The US Department of Commerce's Commercial Service in Brussels continues
to provide updates to AIA and others on current events in the EU
regarding various European chemical directives, including WEEE-ROHS and
REACH, which affect U.S. exports to Europe. The Commercial Service has
also developed and updated a comprehensive website aimed at helping U.S.
companies better understand the implications of the emerging European
legislations, www.buyusa.gov/europeanunion. The following is a brief
summary of the latest report from the U.S. Mission concerning the EU's
Restrictions on Hazardous Substance (RoHS) Directive. On April 24th,
Steve Andrews, a representative on the EU's Technical Adaptation
Committee (TAC) for the ROHS Directive, confirmed to AIA and the
Commerce Department that the language in the EU guidance document
released in May 2005, exempting military and aerospace operations,
remains unchanged, even though  there have been a number of exemptions
and exemption considerations since then that contain references to
"aerospace."  Andrews, from the UK Department of Trade and Industry,
stated that the exemption requests made and considered after May 2005
that mention aerospace and military were "not necessary but the
Commission made a policy decision to publish all exemption requests for
public consultation without prior vetting for need or validity." The
current exemption language in the May 2005 guidance follows: The opinion
of the Commission is that excluded from the scope of the RoHS Directive
is the equipment which is part of another type of equipment that does
not fall within the scope of this Directive. Therefore, the equipment
that is specifically designed to be installed in airplanes, boats and
other means of transport is considered to fall outside the scope of the
ROHS Directive. The effective date of RoHS remains July 1, 2006. On
exemptions, the European Commission will likely vote in late May on
several exemptions to EU Member State governments. Any adopted
exemptions will not be officially published for several weeks after
that, and it is possible that they will not be published in time for the
July 1st deadline. A letter was sent to the European Commission at the
end of March by Bosch, Electrolux, and FagorBrandt, in which the
companies strongly objected to the planned vote on the exemption for
hexavalent chromium passivation coatings. The companies argued that
adequate substitutes exist on a commercial scale. The Commission has
therefore removed the Cr (VI) exemption request from the list to be
voted on by Member States in May, and will review this issue further.
Companies with an interest in this exemption request are encouraged to
send comments to the Commission at [log in to unmask] More information on
the WEEE-ROHS Directives, including the full text of the U.S. Mission's
report, is available at www.aia-aerospace.org/newlogin/aialogin.cfm ,
under "Councils, Committees, and Steering Groups/Acquisition
Policy/Environment, Safety, and Health Committee/Issues and Interests/EU
WEEE-ROHS.
         










-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Dale Ritzen
Sent: Monday, May 01, 2006 12:03 PM
To: [log in to unmask]
Subject: Re: [TN] NTC Get the Lead Out

Ramon et al,
Please don't get me wrong... I am 100% totally behind the Push Back
effort and will do everything I can to help make it happen. I was simply
counseling against relying solely on U.S. produced documentation to back
up our arguments. I see that John has already had an input from the E.U.
on his website. That is an excellent start for getting a review of this
entire fiasco on both sides of the Atlantic (and hopefully ultimately
the Pacific as well). The more back up data that can be documented to
prove that this new process is an incredible waste of natural resources,
the better our argument.

There is one segment here that you had better appeal to, though... The
"green" folks. You can make every scholarly argument known to man to
convince politicians and scientists that this is the wrong direction to
go, but you need the groundswell of the common man behind you as well.
So far, they only know that drinking water from lead pipes (or with
leaded solders) is bad for you. Lead-based paint is also bad for you (if
you eat it). It's only a short leap of faith into the "lead in the
ground is bad for you, too"
argument, especially if it's backed up with junk science and used as a
political platform to divide people. Unless/until there is a turn in the
common thinking about this, it will remain a "sour grapes" issue for
those outside the industry. So how do we crack that nut? I am open for
any/all ideas in that arena... But, it does have to happen.

Dale Ritzen
Quality Manager
Austin Manufacturing Services

-----Original Message-----
From: TechNet [mailto:[log in to unmask]]On Behalf Of Dehoyos, Ramon
Sent: Monday, May 01, 2006 9:46 AM
To: [log in to unmask]
Subject: Re: [TN] NTC Get the Lead Out


        Hi Dale:
                  There is nothing to loose and a lot to gain by trying
what John proposes. Documentation to back the reason for an exemption
can be from America only or America and other countries as well. Can you
imagine the benefits from stopping this ROHS? I am in.
        Regards,
        Ramon




-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Dale Ritzen
Sent: Friday, April 28, 2006 4:22 PM
To: [log in to unmask]
Subject: Re: [TN] NTC Get the Lead Out

Unfortunately John,
Documentation from and by the U.S. Government is not given much weight
in European matters. I think it comes from too many years of living in
the shadow of the U.S. You would be better served if some governmental
agency in one of the E.U. member countries published something of this
nature that could be used to push this agenda. A university professor,
business or government publication originating in the E.U. would help.

How about it folks... Can some of our European cousins come up with
documented evidence of this kind that could lend some credibility in
European circles to the "push back" effort? If so, combine that with the
EPA document and you might gain some weight in your arguments to "the
Commission"...

Not trying to be a spoil sport, but using U.S. documentation in the
European arena is a losing battle... for many reasons.

Dale Ritzen
Quality Manager
Austin Manufacturing Services

-----Original Message-----
From: TechNet [mailto:[log in to unmask]]On Behalf Of John Burke
Sent: Friday, April 28, 2006 3:06 PM
To: [log in to unmask]
Subject: Re: [TN] NTC Get the Lead Out


Thanks Ahne.............Game ON.................

I for one would love to take a co-operative of industry through the
exemption application process using the EPA report as ammunition to
state that lead free solder has a negative environmental impact.

Anyone else up for the challenge?

If there is anyone on here from Microsoft, I would think they might
welcome the opportunity to "Pushback" on some European
matters..............8-)

Ping me through the site or on reply e-mail, anyone who is interested. I
will update the site pages to include this data this weekend.

http://www.rohsusa.com/


John Burke

-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Ahne Oosterhof
Sent: Friday, April 28, 2006 12:37 PM
To: [log in to unmask]
Subject: Re: [TN] NTC Get the Lead Out

>From the European Union website:
http://www.europarl.eu.int/registre/recherche/NoticeDetaillee.cfm?docid=
1608
39&doclang=EN

 E-3488/05EN
Answer given by Mr Dimas
on behalf of the Commission
(11.11.2005)

The objective of the measures identified in the Honourable Member's
question is to substitute harmful substances for humans and the
environment with suitable replacements where these exist.

The Commission is aware that the substitution of lead in electrical and
electronic equipment may have led companies to invest in new
technologies with greater energy use. However, if companies can prove
that the elimination or substitution of the banned substances via design
changes or the use of alternative materials and components causes
negative environmental, health and or consumer safety impacts, and that
these outweigh the environmental benefits of ceasing to use the banned
substances, an exemption can be granted. So far, only one company has
asked for an exemption on these grounds. All the other exemption
requests are based on either the lack of suitable substitutes or for
cost reasons, which cannot be considered under the RoHS Directive .
===========

This seems to say that if the alternative to lead is much more costly,
too bad.

BUT: if the alternative can be shown to be detrimental to the
environment and/or consumer safety, it is possible to get an exemption.
Looks like based on what I read one can prove both sets of problems. So
how come only one company has gone for that kind of exemption? How about
getting an exemption for the US electronic assembly industry?

(You have done a great job of getting a lot of information together in a
single place.)

Have fun,
Ahne.



-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: Friday, 28 April, 2006 11:10
To: [log in to unmask]
Subject: Re: [TN] NTC Get the Lead Out

Wow I guess I really did say that huh.......................

John

-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Stephen Pierce
Sent: Friday, April 28, 2006 10:46 AM
To: [log in to unmask]
Subject: [TN] NTC Get the Lead Out

http://www.worldmag.com/articles/11798

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