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
>>>
>>> -------------------------------------------------------------------------
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>>>
>>
>>
>>
>
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