Mr. Dimas

You have suggested that removal of lead (mandated by RoHS) will make
recycling "safer".
With all due respect, the replacements for lead in solder offer hazards
that are in many respects, worse for the environment.  I refer to silver,
a biocide, and copper, also potentially toxic.  Probably more important,
lead in almost all forms is insoluble in water, compared to its very
soluble replacements.

I am sure you are aware lead acid bateries use up to 90% of all lead and
that lead is routinely and safely recycled.

In 1996, Dr. Braden Allenby,  Professor of Civil and Environmental
Engineering at Arizona State University, coauthored the first text on
"Industrial Ecology".   Coauthor was Dr. Thomas Graedel, Yale School of
Forestry & Environmental Studies.  They analyzed from a total system,
life-cycle point of view, all the environmental imacts of lead compared to
alternatives.  The conclusion--"contraintuitively", lead is safer.

I realize that you have inherited the suite of banned substances in RoHS.
I realize the political difficulty of dealing now with the oversighta and
lack of due diligence that resulted in the ban on lead in electronic
solder. But this is one mistake that should not be allowed to take a toll
on the environment

Harvey Miller

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