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
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_____
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/>
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