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November 2006

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From:
"Stadem, Richard D." <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Mon, 6 Nov 2006 12:53:06 -0600
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Brian,
Let me clarify a few basic tenets of leaded soldering processes, as well
as lead-free materials, whether it is solder, the PWB itself, or the
components.

Kester, AlphaMetals, and Indium currently carry over 100 alloys for
specialty soldering applications (just check out their websites). So do
most of the other solder alloy companies. They will continue to do so
for many years, as there are very many applications (both within and
outside of the electronics industry) that use these alloys in far less
quantities than 63/37 will ever drop to as a result of this RoHS idiocy.
I questioned the people at Kester about the possiblity of phasing out of
63/37 solder, and they laughed. Their estimate of phasing out of 63/37
solder was when the market drops to less than .0001%, and they do not
see any changes like this for at least 10 years.

PWBs manufactured for higher temperatures in Pb-free processes are
totally compatible for use in lower-temperature leaded processes, and
are being used by many major companies in leaded processes as I write
this note. I do not know of any reason why they shouldn't be. Nor am I
aware of any exceptions to this rule.

Leaded solder will solder very nicely to any finish used on PWBs
intended for lead-free processes, even lead-free HASL, provided the
process is set up correctly. There are no surface finishes that were
originated just for lead-free solder except lead-free HASL. All of the
other finishes were in use with leaded solder long before some idiot(s)
dreamed up RoHS.

Typically, leaded solder can be used to solder components having
lead-free finishes without any significant process changes. This
scenario is happening with every single manufacturer who is using leaded
solder today. The only exception is BGAs, and even this can also be
accomplished with the proper process profile, as has been pointed out in
various documents. See papers by David Hillman and others. Proper
process parameters that provide complete homogenity of the lead in the
solder joint is the key. 

And BGAs and other lead-free-solder-bearing array packages are easily
converted to leaded at very reasonable cost. Just ask Russ Winslow at
www.winslowautomation.com.

I am an industry consultant outside of my "regular job" here at General
Dynamics. I have firsthand experience in all of the above scenarios. I
have yet to see any instances where lead-free finishes are not backwards
compatible with leaded solders, except as noted.

Let me be the first to dispel the myth that with the advent of lead-free
solder processes and lead-free finishes on components and pwbs comes the
demise of lead-bearing solder and its corresponding processes. Au
contraire, just the opposite. Improvements in the durability and
robustness of pwbs and components so as to withstand the rigors of
lead-free processing only make these components and pwbs much more
reliable when soldered with lead. However, the caveat is that some of
the toxic materials that made these parts reliable are no longer there.

May I ask why you support the introduction of lead-free materials and
components in industries that are exempt? They are exempted for good
reasons.

There is only one single compelling reason that I can think of for
anyone to support the introduction of lead-free materials and processes
into exempt industries and that is to make a buck, even if it may cost
someone their life. The conversion is not ecologically favorable, and
the reasoning that it facilitates recycling is a weak argument, at best.


The argument that the exempt industries will not be able to get
lead-bearing solder, or that pwbs and components will not be able to be
soldered with lead-bearing solder is the largest fallacy of all.



-----Original Message-----
From: Brian Ellis [mailto:[log in to unmask]] 
Sent: Monday, November 06, 2006 9:22 AM
To: (Leadfree Electronics Assembly Forum); Stadem, Richard D.
Subject: Re: [LF] EU Not Busting for RoHS Violations Yet

The problem is not that they are exempt, it is the fact that PCBs and
components, soldering technology and so on for lead-containing solder
will be unavailable within a couple of years or so. Imagine that I'm a
specialised contractor to Boeing or, more so, Airbus and I supply two
assemblies/plane to B or three to A (yes, they have triple reduncancy
against B's double). This is, at the most, 700 units/year. This can
represent perhaps 1% of my turnover. Do I have a special line for this
tiny part of my business? Will Alpha, Kester or Multicore provide me
with the two pots of the SnPb paste I need per year? Will I be able to
obtain components tinned with SnPb, some of them perhaps just a single
one per unit? Will my PCB supplier offer me a SnPb HASL finish? This is
not a question of exemptions, it is one of pragmatism.

Brian

Stadem, Richard D. wrote:
> All control electronics for trains, planes, ships, and automobile 
> traffic are exempt.
> 
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Nic Bowker
> Sent: Friday, November 03, 2006 10:17 AM
> To: [log in to unmask]
> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
> 
> Well this has certainly been an interesting discussion, but I can't 
> help but think:
> 
> Shouldn't we all be more concerned with the lead-free computers going 
> into the Air-Traffic control systems?
> 
> Or the solder joins on the leads to the headsets of the controllers?
> These clearly don't have the question mark of exemption over them.
> 
> Or do they? Oh I don't know anymore. It's Friday.
> 
> Nic Bowker
> Technical Resources Adviser
> PLASA Ltd.
> 38 St Leonards Road, Eastbourne, East Sussex, BN21 3UT, UK.
> Tel:  +44 (0)1323 410335 : Fax: +44 (0)1323 646905
> Email: [log in to unmask] : Website: www.plasa.org
> 
> Join one of the largest trade communities in the industry.
> www.plasa.org
> 
> 
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]]On Behalf Of David Suraski
> Sent: 03 November 2006 16:06
> To: [log in to unmask]
> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
> 
> 
> Tim-
> 
> I can't and won't disagree with anything you say (except "Do not use 
> snowblower on roof"- how else can I get the snow off of there?).
> 
> My only point, really, is that that article appears too superficial to

> praise Boeing or damn Airbus. Maybe I am too trusting. I hope we don't

> have to have any crashes to learn the limits of lead-free solders in 
> aircrafts.
>  
>  
> Best regards,
> David
> 
> 
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Timothy McGrady
> Sent: Friday, November 03, 2006 10:58 AM
> To: [log in to unmask]
> Subject: Re: [LF] EU Not Busting for RoHS Violations Yet
> 
> David:
> 
> I audit laboratories who are accredited to test aircraft parts and 
> materials.  I can assure you there are very few standards written 
> around "lead-free".  I have also done testing for 20 years.  I know 
> that test simulation of real world conditions only gets you so far - 
> there are always field failures, and from those, hopefully we learn 
> and do not repeat past mistakes.
> 
> Perhaps you've seen labels on products that strike you as odd or 
> silly, e.g., "Do not use snowblower on roof" or "do not use hairdryer 
> in shower" or "do not eat packaging materials".  The reason those 
> labels are there is that someone actually had to do that stupid thing.

> We learn through real world experience that unanticipated consequences

> are all too real.  A great example is metal fatigue - we had to learn 
> through experience of a few crashes what was going on.
> 
> Leaded solders, flame retardants and hexavalent chromium conversion 
> coatings have been in use for long periods of time.  We have real 
> world experience with those substances/materials and we have learned 
> many lessons from failures in the field.  My point is that if you go 
> into the replacement of such substances/materials without a concerted 
> plan to evaluate long-term reliability, you will have crashes and 
> deaths on your hands.  Meanwhile, the environment and human health may

> or may not see any real benefit.  There is need for real long range 
> thinking here - something we humans are not good at.
> ----- Original Message -----
> From: "David Suraski" <[log in to unmask]>
> To: <[log in to unmask]>
> Sent: Friday, November 03, 2006 9:38 AM
> 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
>>>>>
>>>>>
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>>>>>>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
> ----------------------------------------------------------------------
> ---------
> 

-------------------------------------------------------------------------------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
-------------------------------------------------------------------------------

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