It's even more so when you read this letter from Airbus sent Jan 2004 to its supply base. While I think it's a bit unclear, I read it as Airbus' way of saying it intented to comply with RoHS. *----------------------------NAMEJean-Philippe BEDOSDirector Procurement Quality & Supply Chain Equipment Airbus FranceDATE09 january 2004PHONE05 61 93 81 37FAX05 61 93 50 [log in to unmask] REFERENCE714.143.04YOUR REFERENCE Subject: lead elimination in EEE equipment. Dear Sir, Context:On the 27th of January 2003, two European directives (2002/95/EC and 2002/96/EC), have been published at the Official Journal.These two documents have, in particular, the objectives to preserve, protect and improve the quality of environment, protect human health and utilise natural resources prudently and rationally.The objective of the directive 2002/95/EC (called also RoHS) is to facilitate the dismantling and recycling of waste electrical and electronic equipment (as identified in 2002/96/EC called also WEEE) by restricting the use of hazardous substances. The materials banned are lead, mercury, cadmium, hexavalent Chromium, PBBs (Polybrominated biphenyls) and PBDEs (polybrominated diphenyl ethers). The timing for the main requirements are as follow: - Directives to be transposed into national law : 13 August 2004,- Producer's financial obligations start from (WEEE directive) : 13 August 2005,- RoHS substances ban comes into effect: 1rst July 2006,- Re-examination of exemption at the latest: 1rst July 2008. AIRBUS dispositions:For AIRBUS, both directives and the associated planning's are applicable. As it is defined in the Equipment-Design-General Requirements for Suppliers ABD0100.1.6 PART 1- PRODUCT-CHAP 6 - MATERIALS paragraph 1.5, AIRBUS require "The supplier shall not use, in the equipment design and, shall not recommend for maintenance, materials forbidden by national and international regulations, or likely to be (**)." In this paragraph, the compliance to the AP 2091, "list of banned and Highly restricted substances" is required. This instruction will be updated, introducing the banned materials of the RoHS, during the first semester of 2004. For EEE (electronical, electromechanical, electrical) equipment the major concern is lead elimination. In order to evaluate the knowledge, the status and the level of advance of your company on this matter, AIRBUS decided to create a Questionnaire that intents to be fulfilled by the Supplier using alloy containing lead in its Products. Due to the short schedule and to anticipate the potential consequence of this major change, we are expecting to have the Questionnaire fulfilled in a month after receiving this letter. The Supplier response will be analysed by AIRBUS which will communicate the result of analysis. That will initiate an exchange and a follow up of your process and the possible corrective actions to mitigate the risks. Would you indicate the name of the AIRBUS interface on this subject. For AIRBUS, Joëlle Dussault (Tel. 33561189038) is the focal point on this subject. Yours faithfully, Jean-Philippe BEDOS Patrick FANGET Director Procurement Quality Vice President Equipment & Systems ProcurementAnd Supply Chain Equipment Airbus France Airbus France *--------------------------------------------
Mike Buetow
Editor in Chief
Circuits Assembly
30 Glenburnie Road
Boston, MA 02131 USA
W/mobile: 617-327-4702
Now on-demand! The UPMG PCB market update webinar
featuring Walt Custer, http://www.pcbshows.com/webinars/upcoming/custer/
>>> [log in to unmask] 11/17/2006 7:59 AM >>>
Yes, Chris, you are right. Aircraft were excluded from the scope of RoHS by
the Commission, but only after much debate and confusion. The point is that
the aircraft manufacturers, particularly Airbus, are pursuing compliance
ANYWAY. The further point was that all safety related applications of
electronic/electrical equipment ought to be exempt as well - at least until
some modicum of knowledge has been gained about replacement materials. No
big deal if your radio goes down in the middle of a Cher rendition of
Gypsies, Tramps and Thieves (perhaps that would be a good thing), but when
your house burns down because of a short or an A-380 Comet comes crashing
through your roof, that's what I call a big deal. Add to that the fact that
very little environmental protection or human health benefits will be
accomplished by RoHS, and it's a very big deal. I'm tired of it, too - but
it doesn't make it go away.
----- Original Message -----
From: "James, Chris" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Friday, November 17, 2006 3:13 AM
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
I'm getting tired with this thread...............
Planes like vehicles and boats are NOT within the scope of the directive
- the electronics built into them is considered part of the fabric of
the plane, vehicle, boat. This can also apply to some retro fitted
products which are only able to be used in the intended host.
Read the directives and let's leave Boeing alone as it is hardly
relevant to this forum anymore.............
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Brian Ellis
Sent: 16 November 2006 11:52
To: [log in to unmask]
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
If what this guy says is true, then Boeing cannot supply planes to the
EU unless they have lead-free electronics. As I see it, there are four
broad categories of electronics in aircraft: 1. navigational
instrumentation, 2. communications, 3. engine/fly-by-wire and 4.
accessory (e.g., cabin pressurisation, climate control, in-flight
entertainment, in-flight phone and fax etc.). With conventional
electronics, I believe that the first 3 are equipped with a 2x
redundancy, so that if one fails, the other (often of a different make
or batch) can take over. I understand the A380 has a 3x redundancy for
the most essential functions. Forward of the lower floor, there is an
air-conditioned space under the cockpit where they have most of the
electronics, housed in several 19" racks. I haven't seen this myself,
but I have seen the racks in an A320 (housed forwards of the baggage
compartment), while the plane was under construction, and even these are
impressive with bundles of cables as thick as your arm going off in all
directions.
Brian
Timothy McGrady wrote:
> John:
>
> Here's a link to a presentation given by Airbus on the electronics for
> the
> A380:
>
> http://www.arinc.com/amc/reports/2004/presentations/03_bernard_pelleri
> n_present.pdf
>
>
> ----- Original Message -----
> From: "John Burke" <[log in to unmask]>
> To: "'(Leadfree Electronics Assembly Forum)'" <[log in to unmask]>;
> "'Timothy McGrady'" <[log in to unmask]>
> Sent: Thursday, November 16, 2006 1:28 AM
> Subject: RE: [LF] EU Not Busting for RoHS Violations Yet
>
>
>> Could someone PLEASE enlighten me about why Airbus is even concerned
>> with this non issue?
>>
>> Aircraft are the epitomy of the need for safety requirements. Over
>> even a car and here is the reason why.
>>
>> Car carries few (but individually irreplaceable) people. Car
>> electronics stops, best case car rolls to a stop - passengers get
out.
>>
>> Airbus electronics fails on critical system, airbus stops, and falls
>> 32000 feet carrying hundreds of people.
>>
>> I believe the only possibility of an airbus turning up in the waste
>> stream is if it crashed into a recycling center.
>>
>> John
>>
>>
>>
>> -----Original Message-----
>> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Timothy McGrady
>> Sent: Wednesday, November 15, 2006 10:15 PM
>> To: [log in to unmask]
>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>
>> Here's a clip from an article in today's newspaper out of China:
>>
>> The first A380 will be delivered to Singapore Airlines in October
>> 2007, almost a year behind schedule. Sources said the airline would
>> first use the superjumbo to fly routes to Sydney and London.
>>
>> Airbus attributed the delivery delay to problems with installing
>> onboard wiring systems.
>>
>> _________________________________________
>>
>>
>>
>> Hmmm...
>>
>>
>>
>>
>> ----- Original Message -----
>> From: "Stadem, Richard D." <[log in to unmask]>
>> To: <[log in to unmask]>
>> Sent: Monday, November 06, 2006 8:45 AM
>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>
>>
>> Airbus planes are indeed quieter and more comfortable.
>> They never leave the ground, thanks to their ecological, lead-free
>> electronics that are much easier to recycle.
>> No engine noise, none of that infernal buffeting from the wind.......
>>
>> -----Original Message-----
>> From: Leadfree [mailto:[log in to unmask]] On Behalf Of David Suraski
>> Sent: Friday, November 03, 2006 8:38 AM
>> To: [log in to unmask]
>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>
>> Why should we presume that Airbus isn't making their suppliers prove
>> to them first that the new (lead-free) design meets all requirements?
>> Maybe the hoops they're making their suppliers of lead-free products
>> jump through are even more challenging than those Boeing would have
>> their suppliers jump through? Just because they have a hokey ad
>> campaign about lead-free electronics doesn't mean that they're not
>> doing their homework before implementation.
>>
>> I'm not an Airbus-backer or Boeing-detractor (though I do think that
>> Airbus' planes are quieter and more comfortable), nor do I have any
>> idea what these companies are REALLY doing about lead-free, but how
>> much can we really take from that article? Not too much, IMO. All we
>> can is hope that they're acting responsibly.
>>
>> Dave
>>
>> -----Original Message-----
>> From: Kane, Joseph E (US SSA) [mailto:[log in to unmask]]
>> Sent: Friday, November 03, 2006 9:16 AM
>> To: (Leadfree Electronics Assembly Forum); David Suraski
>> Subject: RE: [LF] EU Not Busting for RoHS Violations Yet
>>
>> We're a supplier to Boeing, and they've made it clear that they won't
>> accept lead-free solder unless we prove to them first that the new
>> design meets all requirements.
>>
>> As a high-technology company, they have to be interested in this
>> development, but they're not going to allow lead-free solder without
>> making the supplier jump through some hoops.
>>
>> And they have not made a splashy corporate announcement about making
>> a "lead-free airplane" for silly and unfathomable reasons. This will
>> be a comfort to me the next time I'm flying in an aluminum tube 7
>> miles up at Mach 0.8.
>>
>> -Joe
>>
>>
>> -----Original Message-----
>> From: Leadfree [mailto:[log in to unmask]] On Behalf Of David Suraski
>> Sent: Friday, November 03, 2006 9:04 AM
>> To: [log in to unmask]
>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>
>>
>> Tim,
>>
>> How do we know that Boeing will not use RoHS-compliant electronic? I
>> have heard information to the contrary, not to mention the quote from
>> the article you cite that states (capitalization mine): "Industrial
>> Advisory Board (IAB) members, BOEING, Rockwell Collins, ITT,
>> Raytheon, and Lockheed Martin, have individually and collectively
>> performed research and development tasks on Lead Free solders.
>> Together, it is proposed that a new Lead Free Program be initiated."
>>
>>
>>
>> Best regards,
>> David
>>
>>
>> -----Original Message-----
>> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Timothy McGrady
>> Sent: Friday, November 03, 2006 8:50 AM
>> To: [log in to unmask]
>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>
>> Brian:
>>
>> Go back and read the link provided. It states that the A-380 will
>> have RoHS-compliant electronics. Boeing will not do that, nor will
>> anyone else making aircraft except Airbus (and now, it seems, NATO
>> and a few others).
>> The unknown reliability of RoHS-compliant products causes me to not
>> want to stake my life on an Airbus A-380 or any other plane that
>> accepts equipment with unknown longterm reliability. No Airbus A-380
for me.
>> Period.
>>
>> Tim
>> ----- Original Message -----
>> From: "Brian Ellis" <[log in to unmask]>
>> To: "(Leadfree Electronics Assembly Forum)" <[log in to unmask]>;
>> "Timothy McGrady" <[log in to unmask]>
>> Sent: Friday, November 03, 2006 7:49 AM
>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>
>>
>>> What's so different between an A380 and any other plane? Boeing and
>>> Airbus have a common programme for all flight electronics techniques
>>> and lead-free.
>>>
>>> Brian
>>>
>>> Timothy McGrady wrote:
>>>
>>>> And they fire lead-free bullets as well. That's right - they used
>>>> depleted uranium! Much better for the environment and human
health.
>>
>>
>>>> No chance of getting lead poisoning if one of those bullets lodges
>>>> in
>>
>>
>>>> your brain.
>>>>
>>>> I will not fly on an A-380. Period.
>>>>
>>>> ----- Original Message -----
>>>> From: "John Burke" <[log in to unmask]>
>>>> To: <[log in to unmask]>
>>>> Sent: Thursday, November 02, 2006 1:54 PM
>>>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>>>
>>>>
>>>>> So we should be through this by about 2010.......8-)
>>>>>
>>>>> What really worries me is this item:
>>>>>
>>>>> http://www.empf.org/programs/leadfree.htm
>>>>>
>>>>> My personal opinion is that if you take a military weapons system
>>>>> (fighter aircraft etc) and make it lead free the safest place to
>>>>> be in order of preference would be:
>>>>>
>>>>> 1 A long way away from it
>>>>>
>>>>> 2 Above it
>>>>>
>>>>> 3 Behind it
>>>>>
>>>>> John
>>>>>
>>>>> John
>>>>>
>>>>> -----Original Message-----
>>>>> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael
>>>>> Kirschner
>>>>> Sent: Thursday, November 02, 2006 10:37 AM
>>>>> To: [log in to unmask]
>>>>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>>>>
>>>>> And the written-off parts get sold to brokers, and they sell them
>>>>> to
>>
>>
>>>>> other brokers, and so on, and eventually somebody remarks them and
>>>>> counterfeits the packaging to identify them as compliant so they
>>>>> can
>>
>>
>>>>> sell them so some poor soul desperate for allocated compliant
>>>>> parts...
>>>>>
>>>>> Mike
>>>>>
>>>>>
>>>>>
>>>>> -----Original Message-----
>>>>> From: Timothy McGrady [mailto:[log in to unmask]]
>>>>> Sent: Thursday, November 02, 2006 10:24 AM
>>>>> To: [log in to unmask]; (Leadfree Electronics Assembly
>>>>> Forum)
>>>>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>>>>
>>>>>
>>>>> Mike:
>>>>>
>>>>> Yes, I agree, the mixing of parts has been a big problem. Some
>>>>> companies have written off entire inventories of non-compliant
>>>>> parts
>>
>>
>>>>> for just that reason.
>>>>>
>>>>> Tim
>>>>> ----- Original Message -----
>>>>> From: "Michael Kirschner" <[log in to unmask]>
>>>>> To: "Timothy McGrady" <[log in to unmask]>; "(Leadfree
>>>>> Electronics Assembly Forum)" <[log in to unmask]>
>>>>> Sent: Thursday, November 02, 2006 12:56 PM
>>>>> Subject: RE: [LF] EU Not Busting for RoHS Violations Yet
>>>>>
>>>>>
>>>>>> Tim,
>>>>>>
>>>>>> Excellent point regarding standards. Unfortunately we are
>>>>>> generally
>>
>>
>>>>>> seeing just the opposite occur around the world: regulations
>>>>>> beget standards rather than the other way around. Having the
>>>>>> standard in place first ensures that industry understands how to
>>>>>> actually accomplish something and can actually do it.
>>>>>>
>>>>>> In my humble opinion the primary risk for one of the big
>>>>>> companies likely to be a target is the production problem of
>>>>>> mixed parts, rather than improper or inadequate testing (I
>>>>>> absolutely agree there are labs that are not using the right
>>>>>> tests out there; but I think that's a second order issue).
>>>>>> There
>>>>>> have been, and continue to be, many reports of not-compliant
>>>>>> parts shipping as, being stocked as, or being used as compliant
parts.
>>>>>>
>>>>>> Mike
>>>>>>
>>>>>> -----Original Message-----
>>>>>> From: Timothy McGrady [mailto:[log in to unmask]]
>>>>>> Sent: Thursday, November 02, 2006 9:16 AM
>>>>>> To: (Leadfree Electronics Assembly Forum); Mike Kirschner
>>>>>> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
>>>>>>
>>>>>>
>>>>>> Thanks for that link, Mike.
>>>>>>
>>>>>> When an enforcement authority finally does make the decision to
>>>>>> go ahead with a prosecution, they better make sure they've done
>>>>>> their homework.
>>>>>> There are very few standard methods for analysis of RoHS
>>>>>> substances
>>
>>
>>>>>> and there are few reference materials with which to validate
>>>>>> those
>>
>> methods.
>>
>>>>>> That is not to say they cannot come up with a solid case - I'm
>>>>>> saying that they should chose that case wisely and make sure they
>>>>>> can support their findings with solid, validated methodology. It
>>>>>> will have to be a "no brainer" - an obvious violation. But of
>>>>>> course, the EU would prefer to catch a high-profile company in
>>>>>> non-compliance. And it is likely they want to catch a company
>>>>>> originating in a developed nation such as Japan or the US -
>>>>>> picking
>>
>>
>>>>>> on a developing nation might not sit right with public opinion.
>>>>>> That might not be so easy, given the amount of attention paid to
>>>>>> RoHS by the big boys. None of them wants to be the next Sony,
>>>>>> and they certainly do not want their company name or product name
>>>>>> in the media.
>>>>>>
>>>>>> That being said, there has been a lot of testing done using
>>>>>> methods
>>
>>
>>>>>> that are inappropriate and can result in false negatives. So
>>>>>> there's a chance that a relatively big company placed faith in a
>>>>>> lab or used inappropriate methods themselves to overcheck results
>>>>>> from independent labs. Even so, there's also a good chance that
>>>>>> EU
>>
>>
>>>>>> enforcement authorities will also use inappropriate methods to
>>>>>> determine non-compliance (or conversely, compliance). The lack
>>>>>> of properly developed standards hurts all
>>>>>> involved:
>>>>>> enforcement authorities and producers alike. That is why
>>>>>> standards
>>
>>
>>>>>> must be in place before technical legislation such as RoHS go
>>>>>> into effect.
>>>>>>
>>>>>> The example I use to illustrate this problem concerns a
>>>>>> government developing a regulation stating that all children age
>>>>>> 14 and under must wear a helmet while riding a bicycle. Let's
>>>>>> say that no standards for helmets were developed prior to the
>>>>>> regulation going into force. A kid is observed riding a bicycle
>>>>>> wearing a baseball cap. Is that kid in violation of the law?
>>>>>> Not without a standard defining a helmet and laying out the
>>>>>> technical requirements necessary to protect the head in case of
>>>>>> an accident. Now let's say the givernment developed extensive
>>>>>> requirements for the helmet and a standards development body
>>>>>> developed a standard for such helmets.
>>>>>> The
>>>>>> resulting helmet would protect the head in every case, but it
>>>>>> would
>>
>>
>>>>>> cost $2000. Would it be fair to expect a poor child riding a
>>>>>> cheap
>>
>>
>>>>>> bike to wear a $2000 helmet? Again, the answer is no. But if
>>>>>> the law went into effect, there would likely be plenty of
>>>>>> violations to
>>
>>
>>>>>> go around. Fakes of standard helmets would quickly become
>>>>>> available. In that case, the government should have taken their
>>>>>> requirements to the standard developers and experts and get their
>>>>>> feedback before putting the law on the books. If the law was too
>>>>>> costly to implement, the regulation would have to be altered. In
>>>>>> either case, it is necessary to have standards developed prior to
>>>>>> the regulation going into force.
>>>>>>
>>>>>> That is why the World Trade Organization Technical Barriers to
>>>>>> Trade Agreement (TBT) is so important. Here is a quote from the
>>
>> TBT:
>>
>>>>>>
>>>>>> "
>>>>>> With respect to their central government bodies:
>>>>>>
>>>>>> 2.1 Members shall ensure that in respect of technical
>>>>>> regulations, products imported from the territory of any Member
>>>>>> shall be accorded treatment no less favourable than that accorded
>>>>>> to like products of national origin and to like products
>>>>>> originating in any
>>
>>
>>>>>> other country.
>>>>>>
>>>>>> 2.2 Members shall ensure that technical regulations are not
>>>>>> prepared, adopted or applied with a view to or with the effect of
>>>>>> creating unnecessary obstacles to international trade. For this
>>>>>> purpose, technical regulations shall not be more
>>>>>> trade-restrictive than necessary to fulfil a legitimate
>>>>>> objective, taking account of the risks non-fulfilment would
create.
>>>>>> Such
>>>>>> legitimate objectives are, inter alia: national security
>>>>>> requirements; the prevention of deceptive practices; protection
>>>>>> of human health or safety, animal or plant life or health, or the
>>>>>> environment. In assessing such risks, relevant elements of
>>>>>> consideration are, inter alia: available scientific and technical
>>>>>> information, related processing technology or intended end-uses
>>>>>> of products.
>>>>>>
>>>>>> 2.3 Technical regulations shall not be maintained if the
>>>>>> circumstances or objectives giving rise to their adoption no
>>>>>> longer
>>
>>
>>>>>> exist or if the changed circumstances or objectives can be
>>>>>> addressed in a less trade-restrictive manner.
>>>>>>
>>>>>> 2.4 Where technical regulations are required and relevant
>>>>>> international standards exist or their completion is imminent,
>>>>>> Members shall use them, or the relevant parts of them, as a basis
>>>>>> for their technical regulations except when such international
>>>>>> standards or relevant parts would be an ineffective or
>>>>>> inappropriate means for the fulfilment of the legitimate
>>>>>> objectives
>>
>>
>>>>>> pursued, for instance because of fundamental climatic or
>>>>>> geographical factors or fundamental technological problems.
>>>>>>
>>>>>> 2.5 A Member preparing, adopting or applying a technical
>>>>>> regulation
>>
>>
>>>>>> which may have a significant effect on trade of other Members
>>>>>> shall, upon the request of another Member, explain the
>>>>>> justification for that technical regulation in terms of the
>>>>>> provisions of paragraphs 2 to 4. Whenever a technical regulation
>>>>>> is
>>
>>
>>>>>> prepared, adopted or applied for one of the legitimate objectives
>>>>>> explicitly mentioned in paragraph 2, and is in accordance with
>>>>>> relevant international standards, it shall be rebuttably presumed
>>>>>> not to create an unnecessary obstacle to international trade.
>>>>>>
>>>>>> 2.6 With a view to harmonizing technical regulations on as wide a
>>>>>> basis as possible, Members shall play a full part, within the
>>>>>> limits of their resources, in the preparation by appropriate
>>>>>> international standardizing bodies of international standards for
>>>>>> products for which they either have adopted, or expect to adopt,
>>>>>> technical regulations.
>>>>>>
>>>>>> 2.7 Members shall give positive consideration to accepting as
>>>>>> equivalent technical regulations of other Members, even if these
>>>>>> regulations differ from their own, provided they are satisfied
>>>>>> that
>>
>>
>>>>>> these regulations adequately fulfil the objectives of their own
>>>>>> regulations.
>>>>>>
>>>>>> 2.8 Wherever appropriate, Members shall specify technical
>>>>>> regulations based on product requirements in terms of performance
>>>>>> rather than design or descriptive characteristics.
>>>>>>
>>>>>> 2.9 Whenever a relevant international standard does not exist or
>>>>>> the technical content of a proposed technical regulation is not
>>>>>> in accordance with the technical content of relevant
>>>>>> international standards, and if the technical regulation may have
>>>>>> a significant effect on trade of other Members, Members shall:
>>>>>>
>>>>>> 2.9.1 publish a notice in a publication at an early appropriate
>>>>>> stage, in such a manner as to enable interested parties in other
>>>>>> Members to become acquainted with it, that they propose to
>>>>>> introduce a particular technical regulation;
>>>>>>
>>>>>> 2.9.2 notify other Members through the Secretariat of the
>>>>>> products
>>
>>
>>>>>> to be covered by the proposed technical regulation, together with
>>>>>> a
>>
>>
>>>>>> brief indication of its objective and rationale. Such
>>>>>> notifications
>>
>>
>>>>>> shall take place at an early appropriate stage, when amendments
>>>>>> can
>>
>>
>>>>>> still be introduced and comments taken into account;
>>>>>>
>>>>>> 2.9.3 upon request, provide to other Members particulars or
>>>>>> copies
>>
>>
>>>>>> of the proposed technical regulation and, whenever possible,
>>>>>> identify the parts which in substance deviate from relevant
>>>>>> international standards;
>>>>>>
>>>>>> 2.9.4 without discrimination, allow reasonable time for other
>>>>>> Members to make comments in writing, discuss these comments upon
>>>>>> request, and take these written comments and the results of these
>>>>>> discussions into account.
>>>>>>
>>>>>> 2.10 Subject to the provisions in the lead-in to paragraph 9,
>>>>>> where
>>
>>
>>>>>> urgent problems of safety, health, environmental protection or
>>>>>> national security arise or threaten to arise for a Member, that
>>>>>> Member may omit such of the steps enumerated in paragraph 9 as it
>>>>>> finds necessary, provided that the Member, upon adoption of a
>>>>>> technical regulation, shall:
>>>>>>
>>>>>> 2.10.1 notify immediately other Members through the Secretariat
>>>>>> of
>>
>>
>>>>>> the particular technical regulation and the products covered,
>>>>>> with a brief indication of the objective and the rationale of the
>>>>>> technical regulation, including the nature of the urgent
>>>>>> problems;
>>>>>>
>>>>>> 2.10.2 upon request, provide other Members with copies of the
>>>>>> technical regulation;
>>>>>>
>>>>>> 2.10.3 without discrimination, allow other Members to present
>>>>>> their comments in writing, discuss these comments upon request,
>>>>>> and
>>
>>
>>>>>> take these written comments and the results of these discussions
>>>>>> into account.
>>>>>>
>>>>>> 2.11 Members shall ensure that all technical regulations which
>>>>>> have
>>
>>
>>>>>> been adopted are published promptly or otherwise made available
>>>>>> in such a manner as to enable interested parties in other Members
>>>>>> to become acquainted with them.
>>>>>>
>>>>>> 2.12 Except in those urgent circumstances referred to in
>>>>>> paragraph 10, Members shall allow a reasonable interval between
>>>>>> the publication of technical regulations and their entry into
>>>>>> force in order to allow time for producers in exporting Members,
>>>>>> and particularly in developing country Members, to adapt their
>>>>>> products
>>
>>
>>>>>> or methods of production to the requirements of the importing
>>>>>> Member."
>>>>>>
>>>>>> The EU has always argued that because their regulations such as
>>>>>> RoHS are for protection of human health and the environment and
>>>>>> because they impact their companies in the same way as they
>>>>>> impact importing companies, there cannot be a trade barrier (see
>>>>>> paragraphs 2 and 5 above). But paragraph 2 can be argued in the
>>>>>> case of RoHS. I contend (as I think many of you do) that RoHS is
>>>>>> much more trade restrictive than necessary, taking into account
>>>>>> the
>>
>>
>>>>>> actual impact the directive will have on human health and the
>>>>>> environment.
>>>>>> Had the proper standards been in place, billions of dollars would
>>>>>> have been saved. If RoHS had not been implemented or had been
>>>>>> delayed, I doubt many lives would be negatively impacted, if any
>>>>>> at
>>
>>
>>>>>> all. In fact, the argument can be made that RoHS can negatively
>>>>>> impact human health, because there is high probability that a
>>>>>> safety related part or system will fail due to the wholesale
>>>>>> redesign of products and materials.
>>>>>>
>>>>>>
>>>>>>
>>>>>> Tim McGrady
>>>>>>
>>>>>>
>>>>>> ----- Original Message -----
>>>>>> From: "Mike Kirschner" <[log in to unmask]>
>>>>>> To: <[log in to unmask]>
>>>>>> Sent: Thursday, November 02, 2006 12:05 AM
>>>>>> Subject: [LF] EU Not Busting for RoHS Violations Yet
>>>>>>
>>>>>>
>>>>>>> Rob Spiegel spoke, at our behest, to Steve Andrews to get a
>>>>>>> clear response on why we haven't seen any visible cases of
>>>>>>> non-compliance in the EU yet.
>>>>>>> He
>>>>>>> has more credibility on this topic than just about anyone, even
>>>>>>> DCA
>>>>>>> ;o)
>>>>>>>
>>>>>>> You can read his story, entitled "EU Not Busting for RoHS
>>>>>>> Violations Yet", at
>>>>>>>
>>>>>>> http://www.designnews.com/article/CA6387098.html
>>>>>>>
>>>>>>> So the bottom line is that they're trying to find that first
>>>>>>> case to go public with.
>>>>>>>
>>>>>>> Mike Kirschner
>>>>>>> Design Chain Associates, LLC
>>>>>>>
>>>>>>> ----------------------------------------------------------------
>>>>>>> --
>>>>>>> -------
>>>>>>>
>>>>>
>>>>> -
>>>>>
>>>>>> -----Leadfee
>>>>>>
>>>>>>> Mail List provided as a service by IPC using LISTSERV 1.8d To
>>>>>>> unsubscribe, send a message to [log in to unmask] with following
>>>>>>> text in the BODY (NOT the subject field): SIGNOFF Leadfree To
>>>>>>> temporarily stop/(start) delivery of Leadree for vacation breaks
>>>>>>> send:
>>>>>>> SET Leadfree NOMAIL/(MAIL)
>>>>>>> Search previous postings at: http://listserv.ipc.org/archives
>>>>>>> Please visit IPC web site
>>>>>>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16
>>>>>>> for additional information, or contact Keach Sasamori at
>>>>>>> [log in to unmask] or 847-615-7100 ext.2815
>>>>>>> ----------------------------------------------------------------
>>>>>>> --
>>>>>>> -------
>>>>>>>
>>>>>
>>>>> -
>>>>>
>>>>>> -----
>>>>>>
>>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>
>>>>> ------------------------------------------------------------------
>>>>> --
>>>>> --------
>>>>>
>>>>> ---Leadfee Mail List provided as a service by IPC using LISTSERV
>>>>> 1.8d To unsubscribe, send a message to [log in to unmask] with
>>>>> following text in the BODY (NOT the subject field): SIGNOFF
>>>>> Leadfree
>>
>>
>>>>> To temporarily stop/(start) delivery of Leadree for vacation
>>>>> breaks
>>>>> send:
>>>>> SET Leadfree NOMAIL/(MAIL)
>>>>> Search previous postings at: http://listserv.ipc.org/archives
>>>>> Please
>>
>>
>>>>> visit IPC web site
>>>>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16
>>>>> for additional information, or contact Keach Sasamori at
>>>>> [log in to unmask] or 847-615-7100 ext.2815
>>>>> ------------------------------------------------------------------
>>>>> --
>>>>> --------
>>>>>
>>>>> ---
>>>>>
>>>>> ------------------------------------------------------------------
>>>>> -- -----------Leadfee Mail List provided as a service by IPC using
>>>>> LISTSERV 1.8d To unsubscribe, send a message to [log in to unmask]
>>>>> with following text in the BODY (NOT the subject field): SIGNOFF
>>>>> Leadfree To temporarily stop/(start) delivery of Leadree for
>>>>> vacation breaks
>>>>> send:
>>>>> SET Leadfree NOMAIL/(MAIL)
>>>>> Search previous postings at: http://listserv.ipc.org/archives
>>>>> Please
>>
>>
>>>>> visit IPC web site
>>>>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16
>>>>> for additional information, or contact Keach Sasamori at
>>>>> [log in to unmask] or 847-615-7100 ext.2815
>>>>> ------------------------------------------------------------------
>>>>> --
>>>>> -----------
>>>>>
>>>>>
>>>>
>>>> -------------------------------------------------------------------
>>>> -- ----------Leadfee Mail List provided as a service by IPC using
>>>> LISTSERV 1.8d To unsubscribe, send a message to [log in to unmask]
>>>> with
>>
>>
>>>> following text in the BODY (NOT the subject field): SIGNOFF
>>>> Leadfree To temporarily stop/(start) delivery of Leadree for
>>>> vacation breaks
>>
>> send:
>>
>>>> SET Leadfree NOMAIL/(MAIL)
>>>> Search previous postings at: http://listserv.ipc.org/archives
>>>> Please visit IPC web site
>>>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
>>>> information, or contact Keach Sasamori at [log in to unmask] or
>>>> 847-615-7100
>>>> ext.2815
>>>> -------------------------------------------------------------------
>>>> --
>>>> ----------
>>>>
>>>>
>>>
>>
>> ---------------------------------------------------------------------
>> --- -------Leadfee Mail List provided as a service by IPC using
>> LISTSERV 1.8d To unsubscribe, send a message to [log in to unmask] with
>> following text in the BODY (NOT the subject field): SIGNOFF Leadfree
>> To temporarily stop/(start) delivery of Leadree for vacation breaks
>> send:
>> SET Leadfree NOMAIL/(MAIL) Search previous postings at:
>> http://listserv.ipc.org/archives Please visit IPC web site
>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
>> information, or contact Keach Sasamori at [log in to unmask] or
>> 847-615-7100
>> ext.2815
>> ---------------------------------------------------------------------
>> ---
>> -------
>>
>> ---------------------------------------------------------------------
>> --- -------Leadfee Mail List provided as a service by IPC using
>> LISTSERV 1.8d To unsubscribe, send a message to [log in to unmask] with
>> following text in the BODY (NOT the subject field): SIGNOFF Leadfree
>> To temporarily stop/(start) delivery of Leadree for vacation breaks
>> send: SET Leadfree NOMAIL/(MAIL)
>> Search previous postings at: http://listserv.ipc.org/archives Please
>> visit IPC web site
>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
>> information, or contact Keach Sasamori at [log in to unmask] or
>> 847-615-7100
>> ext.2815
>> ---------------------------------------------------------------------
>> ---
>> -------
>>
>> ---------------------------------------------------------------------
>> --- -------Leadfee Mail List provided as a service by IPC using
>> LISTSERV 1.8d To unsubscribe, send a message to [log in to unmask] with
>> following text in the BODY (NOT the subject field): SIGNOFF Leadfree
>> To temporarily stop/(start) delivery of Leadree for vacation breaks
>> send:
>> SET Leadfree NOMAIL/(MAIL) Search previous postings at:
>> http://listserv.ipc.org/archives Please visit IPC web site
>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
>> information, or contact Keach Sasamori at [log in to unmask] or
>> 847-615-7100
>> ext.2815
>> ---------------------------------------------------------------------
>> ---
>> -------
>>
>> ---------------------------------------------------------------------
>> -------
>>
>> ---Leadfee
>> Mail List provided as a service by IPC using LISTSERV 1.8d To
>> unsubscribe, send a message to [log in to unmask] with following text
>> in the BODY (NOT the subject field): SIGNOFF Leadfree To temporarily
>> stop/(start) delivery of Leadree for vacation breaks send:
>> SET Leadfree NOMAIL/(MAIL)
>> Search previous postings at: http://listserv.ipc.org/archives Please
>> visit IPC web site
>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16
>> for additional information, or contact Keach Sasamori at
>> [log in to unmask] or 847-615-7100 ext.2815
>> ---------------------------------------------------------------------
>> -------
>>
>> ---
>>
>> ---------------------------------------------------------------------
>> -------
>>
>> ---Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
>> To unsubscribe, send a message to [log in to unmask] with following
>> text in the BODY (NOT the subject field): SIGNOFF Leadfree To
>> temporarily stop/(start) delivery of Leadree for vacation breaks
send:
>> SET Leadfree NOMAIL/(MAIL)
>> Search previous postings at: http://listserv.ipc.org/archives Please
>> visit IPC web site
>> http://www.ipc.org/contentpage.asp?Pageid=4.3.16
>> for additional information, or contact Keach Sasamori at
>> [log in to unmask] or 847-615-7100 ext.2815
>> ---------------------------------------------------------------------
>> -------
>>
>> ---
>>
>
> ----------------------------------------------------------------------
> ---------Leadfee Mail List provided as a service by IPC using LISTSERV
> 1.8d To unsubscribe, send a message to [log in to unmask] with following
> text in the BODY (NOT the subject field): SIGNOFF Leadfree To
> temporarily stop/(start) delivery of Leadree for vacation breaks
> send: SET Leadfree NOMAIL/(MAIL)
> Search previous postings at: http://listserv.ipc.org/archives Please
> visit IPC web site
> http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
> information, or contact Keach Sasamori at [log in to unmask] or
> 847-615-7100
> ext.2815
> ----------------------------------------------------------------------
> ---------
>
>
------------------------------------------------------------------------
-------Leadfee Mail List provided as a service by IPC using LISTSERV
1.8d To unsubscribe, send a message to [log in to unmask] with following
text in the BODY (NOT the subject field): SIGNOFF Leadfree To
temporarily stop/(start) delivery of Leadree for vacation breaks send:
SET Leadfree NOMAIL/(MAIL) Search previous postings at:
http://listserv.ipc.org/archives Please visit IPC web site
http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100
ext.2815
------------------------------------------------------------------------
-------
-----------------------------------------
This message (including any attachments) may contain confidential
information intended for a specific individual and purpose. If you
are not the intended recipient, delete this message. If you are
not the intended recipient, disclosing, copying, distributing, or
taking any action based on this message is strictly prohibited.
-------------------------------------------------------------------------------Leadfee
Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send:
SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16
for additional information, or contact Keach Sasamori at [log in to unmask] or
847-615-7100 ext.2815
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------
|
