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June 2006

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Subject:
From:
Mike Kirschner <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Fri, 2 Jun 2006 18:02:56 -0500
Content-Type:
text/plain
Parts/Attachments:
text/plain (364 lines)
John,

All you have to do is ask the right part of the government (DG Environment)
for a list of TAC members and you'll get it and you've done so (in a manner
of speaking). We did and we got it...a while ago. Not a big deal...you don't
have to wave sabres and fire (lead-free) bullets in to the air to do so.

Also, ERA Technology will only "technically steer the TAC through the latest
round of exemptions applications" if they are the selected EU-based
consultancy for this particular stakeholder consultation. Others have been
used in the past. I have not seen which company is doing the lastest batch -
perhaps I missed it.

Mike

On Thu, 1 Jun 2006 15:03:54 -0700, John Burke <[log in to unmask]> wrote:

>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 :
>
>[log in to unmask]
>
>
>
>
>
>
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John,

All you have to do is ask for a list of TAC members and you'll get it and
you've done so (in a manner of speaking). We did and we got it...a while
ago. Not a big deal...you don't have to wave sabres and fire (lead-free)
bullets in to the air to do so.

Mike

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