Hi John!
I noticed something in Mrs. Passera's email that is rather ironic. It's
this statement at the end of her email:
"Please consider the environment before deciding to print this e-mail."
Now if the same sort of thinking was done before adopting RoHS and
making it law, I'll bet that there wouldn't have been any of these
emails at all, would there?
-Steve Gregory-
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: Thursday, June 08, 2006 11:17 AM
To: [log in to unmask]
Subject: [TN] FW: NTC subject TAC committee for RoHS meeting minutes and
membership
Just an FYI,
Good to know that there is a system, I will update when I get further
data.
John
_____
From: [log in to unmask] [mailto:[log in to unmask]]
Sent: Thursday, June 08, 2006 8:52 AM
To: [log in to unmask]
Subject: RE: NTC subject TAC committee for RoHS meeting minutes and
membership
Dear Mr Burke,
Your request will be dealt according to Council Regulation 1049/2001/EC
regarding public access to the European Parliament, Council and
Commission documents. Pursuant to this regulation you will receive a
response to your request within 15 working days from registration.
Best regards,
Anna Passera.
NEW E-mail Address as from 9 May 2006:
[log in to unmask]
Web: http://europa.eu.int/comm/environment/
P Please consider the environment before deciding to print this e-mail.
*********************DISCLAIMER*****************************************
****
************************************
Disclaimer required under the terms and conditions of use of the
internet and electronic mail from Commission equipment:
"The views expressed are purely those of the writer and may not in any
circumstances be regarded as stating an official position of the
European Commission. A binding interpretation of Community law can only
be given by the European Court of Justice".
************************************************************************
****
******************************************
_____
From: John Burke [mailto:[log in to unmask]]
Sent: Friday, June 02, 2006 12:04 AM
To: PASSERA Anna (ENV)
Cc: 'TechNet E-Mail Forum'; 'Leadfree'; [log in to unmask]
Subject: NTC subject TAC committee for RoHS meeting minutes and
membership
Dear Mrs. Passera,
I am writing in regard to the communication chain below with Mr. Paul
Goodman of ERA who states that:
"In fact the TAC does have published minutes but these are not available
until after they have been agreed at the following meeting. Then they
are not "published" but can be obtained on request from the European
Commission, DG Environment, Sustainable Production and Consumption
Group."
So if I could ask for a copy of the TAC committee meeting minutes
generated to date, either sent by email or published on the EU web site
please that would be fantastic.
I would also ask for a list of the committee members at this time should
they not be indicated on the minutes as a "members present" item.
I acknowledge that this e-mail will probably not be answered until you
return to the office next week. If you are not the right person to ask I
would appreciate being sent the name of the contact person and their
e-mail details.
Kind regards,
John Burke
RoHSUSA
<http://www.rohsusa.com/> http://www.rohsusa.com
To subscribe to pushback mailing list send a blank email to :
[log in to unmask]
_____
From: [log in to unmask]
[mailto:[log in to unmask]] On Behalf Of John Burke
Sent: Thursday, June 01, 2006 10:29 AM
To: 'Paul Goodman'
Cc: [log in to unmask]; 'TechNet'; 'Leadfree';
[log in to unmask]
Subject: [RoHSUSAPushback] RE: TAC committee for RoHS
Thank you so much Paul,
Your reply is much appreciated, I have copied it to the original
circulation list to get closure as far as this enquiry is concerned, and
will take the matter up directly with the EU.
I trust that you will technically steer the TAC through the latest round
of exemptions applications which we have supported on environmental
grounds; which quite honestly is our only cause for concern. I think
perhaps though that they may need environmental consultants on that
committee when "major"
issues crop up.
The reason for enquiring about the TAC is that the TAC had exemption
application requests on environmental grounds lodged with the EU back in
2004 from RM Sommer Consulting Ltd of New Zealand whose verbatim
checklist application submitted to the EU and a matter of public record
reads as
follows:
""RM Sommer Consulting Ltd believes that the industry standard eutectic
Sn63/Pb37 solder should be exempt from the substance restrictions of
article 4(1). The grounds of this submission for exemption lie in
article 5(1)(b).
It is the view of RM Sommer Consulting Ltd that the negative
environmental and/or health impact of the alternatives are likely to
outweigh the environmental and/or health benefits.""
When looking in the "unofficial" DTI minutes of the October 2004
meeting, there is no reference to this submission, BUT there is this
somewhat worrying disclosure:
""A number of other exemption requests had been received by the
commission since the ERA study had been launched. Those submitted in
advance of the 15 September were discussed at this TAC meeting.
The commission said that it would prioritise the requests that it had
received to date and remove any that were obviously not justified. The
UK commented that many of these late requests were similar to those that
had been discussed earlier in the day and that there was no need to take
further action on those. Some Member States thought that a couple of the
new requests could be ruled out with immediate effect.""
Which would indicate (at least from my reading of that document), that
in fact the Commission has been screening applications for the TAC. The
last sentences of that second paragraph are also somewhat concerning
from my own understanding of the term "due diligence"
So once again thank you for you reply, it is truly appreciated. I have
great respect for the work done by yourself and ERA on the technical
input to these legislative processes and in other areas and trust that
the EU will be using you on their EUP program.
We will take the matter of the TAC membership and the official minutes
up directly with the EU Commission.
With very best regards,
John Burke
_____
From: Paul Goodman [mailto:[log in to unmask]]
Sent: Thursday, June 01, 2006 3:00 AM
To: John Burke
Subject: RE: TAC committee for RoHS
Dear John,
ERA is an independent consultant and has no links to the TAC or European
Commission other than as a supplier of services. You are correct that UK
DTI publish unofficial minutes of TAC meetings. Manufacturers find these
very useful as they are available soon after TAC meetings. In fact the
TAC does have published minutes but these are not available until after
they have been agreed at the following meeting. Then they are not
"published" but can be obtained on request from the European Commission,
DG Environment, Sustainable Production and Consumption Group.
The TAC is a committe set up to assist the Commission with details of
RoHS and WEEE implementation. Each of the 25 EU Member States send one
representative for this committee. Despite its name, the TAC is not
"technical" and this is why they use consultants like ERA to provide
technical assistance.
I hope this is useful.
Best regards,
Paul Goodman
ERA Technology Ltd
+44 1372 367221
-----Original Message-----
From: John Burke [mailto:[log in to unmask]]
Sent: 31 May 2006 05:58
To: Paul Goodman
Cc: [log in to unmask]; '(Leadfree Electronics Assembly Forum)';
'TechNet'; [log in to unmask]
Subject: TAC committee for RoHS
Importance: High
Dr Paul Goodman
ERA Technology Ltd. Contact person: Dr Paul Goodman, E-mail:
<mailto:[log in to unmask]> [log in to unmask]
CC Stavros Dimas Environmental Commissioner EU
CC IPC Technet and lead free lists servers
CC [log in to unmask]
Subject RoHS EU TAC membership.
Good morning Dr Goodman,
I have enquired of some trade association memberships both in Europe and
the USA regarding the members of the EU TAC advisory committee on RoHS.
My reasoning in asking the question is as follows:
1 There are no official minutes of meetings that I or
others have been made aware of.
2 There is no formally published list of the
committee
members, their company affiliations or their background and training for
the task at hand; although we are lead to believe that they are not
actually employed full time by the EU.
Unfortunately, there has been no response to date from these enquiries
of the industry generally, and so I would normally draw the conclusion
that in fact the meetings do not have official minutes and that the
committee membership is not published.
Knowing that this is almost certainly not the case, and perhaps there
are in fact such data available, since there are indeed unaccredited
"unofficial minutes" with no committee data, I thought I would ask you,
since being the EU contracted consultant for these matters you must in
fact interface with the EU TAC for RoHS on a regular basis.
The industry should be aware of this data, in the public view, since
everything else about this initiative is indeed posted on a web site
apart from this critical piece of information.
The reasoning being that the industry that has paid out an estimated 80
to 100 billion US dollars on lead removal from solders alone, based on
the recommendations of this committee, and the resulting (or not)
legislative amendments to the RoHS legislation.
At this level of authority, the industry deserves at the very least to
understand who is making the decisions, their qualifications to make
them, and their corporate affiliation.
This is not in the case with any of the committees supported by the
industry trying to deal with this legislation, IPC, iNEMI, and all other
groups involved in trying to make this legislation work have very
visible committee members, typically people at the top of their careers
in the electronics sector and expert in their respective fields.
If there is any reason why this should not be published, or if you are
not the correct contact in this instance, please would you let me know
by return to whom this enquiry should be addressed. If the list is
freely available I would appreciate a copy.
Kind regards,
John Burke
http://www.RoHSUSA.com <http://www.rohsusa.com/>
To subscribe to pushback mailing list send a blank email to :
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