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
-------------------------------------------------------------------------------
|
