It is widely known.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Davy, Gordon
Sent: Tuesday, November 28, 2006 3:26 PM
To: [log in to unmask]
Subject: Re: [LF] Policing RoHS
My thanks to John Sieber for posting the link to the Green Supply Line
article on monitoring RoHS compliance. I offer below an excerpt of the
article, and some comments.
... Asian manufacturers tend to view substance restrictions at the
component level, not the homogenous material level. "There we can have a
very big surprise" [said Denis Pohl, coordinator of Belgium's product
policy for the Ministry of the Environment].
Whistleblowing can be tricky. To assess the tips, NWML uses a scoring
system in the producer's risk profile. One complaint is noted, two
complaints may raise the risk profile. "We don't take any one complaint
on face value," ...said [Chris Smith, head of the NWML's RoHS team]. "We
don't want to get into the game of slinging mud."
Greenpeace... found Deca-BDE in HP laptops.... Greenpeace found that
when the restricted flame retardants are embedded in plastic, they are
virtually undetectable.... "What we learned from testing can be
summarized in a sentence: It is going to be extremely difficult to
monitor RoHS compliance," ... said [Zeina Al-Hajj, in charge of the
Toxics Campaign for Greenpeace International].
Belgium is different in that it does not accept the "due diligence"
defense. The producer has sole responsibility for compliance and also
bears full responsibility for the accuracy of supplier certificates that
claim compliance, Pohl said. Moreover, authorities do not accept 99.9%
compliant product. "Either it is compliant or is not," he said.
Comments: It has been slow in coming, but we are starting to see
evidence of the collision that several forum participants and I forecast
some months ago.
Given all of the Leadfree postings over the years about the meaning of
"homogeneous," we should hardly be surprised that not all manufacturers
have grasped the subtleties.
As an Article 95 directive, RoHS is supposed to be enforced equally in
every Member State. At the moment, that appears not to be happening,
since Great Britain has said that they intend to allow a "due diligence"
defense and Belgium has said that it will not. Who will call the Member
States to account for non-uniform enforcement?
So Greenpeace now acknowledges how difficult it is going to be to
enforce the directive they promoted. Too bad that didn't occur to them
sooner. They say that they have learned it after testing. Had they only
been interested in listening and not just agitating, they could have
heard that from plenty of people long before RoHS became law.
Also, it seems to escaped Greenpeace's notice that the very property
that makes it virtually impossible to find restricted flame retardants,
namely the fact that they are embedded in the plastic, also makes it
impossible for them to pollute the environment. If highly intelligent
scientists (even Greenpeace scientists!) can't get it out when they try,
what makes them think that when no one is trying it would leak out to
cause problems?
Also, why is Greenpeace making an issue out of the use of deca-BDE when
RoHS allows that brominated flame retardant? Do they regard their own
beliefs as more important than law? On what grounds? Do these people
ever have any doubts about the policies they promote? Have they ever
acknowledged that they have erred?
I have stated repeatedly that irresponsible environmental activists
really care most about maintaining a positive cash flow. That cash flow
would no doubt be endangered were they to acknowledge that they are
after all mere mortals and lack infallibility. One wonders how long it
will be before that embarrassing fact becomes widely known.
Gordon Davy
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