John:

I wrote the following to a US official who wondered about your exemption
request:

The author of that request claims that the lead solder replacements are just
as bad for the environment as the lead solders.  In a sense, he is forcing
the EU to look at information from sources such as the US EPA that shows
that by replacing tin-lead solder with tin-silver-copper solder, all that
has been accomplished is a shifting of the environmental impact from the
end-of-life (lead solders) to the beginning of manufacturing (mining,
extraction of silver, etc for SAC alloys), with no real overall benefit.
This may be a worthwhile effort, but it is unlikely to result in a repeal of
the lead "ban".  More likely, the EU agencies will do their own studies and
either come to a different conclusion (impact is less with SAC alloys) or
they will consider "banning" the replacement solders.  If it is the former,
nothing will change.  If it's the latter, the EU will have gained some
evidence supporting their new REACH proposal, since REACH is supposed to
prevent the replacement of "bad" chemicals with other "bad" chemicals.  I
doubt this will happen, but it's possible that the EU will try to "ban" the
SAC alloys at some future date.

Take the brominated flame retardants as another example.  Some companies
have even gone away from allowed brominated compounds, suspecting that they
will also be restricted by the EU.  The replacement flame retardant systems
sometimes include antimony trioxide, which is a highly toxic substance and a
possible carcinogen (California lists it as a Proposition 65 substance).
But the EU has supported claims that suitable replacements for brominated
flame retardants exist in their own research, and they even point to
antimony trioxide as one of the replacement chemicals!  This is a direct
contradiction of their policy, but I know they haven't yet caught on.
Eventually, they will restrict the use of antimony trioxide.  This is what
many have referred to as the "moving target" of environmental and health
regulation.

In my opinion, the EU and its agencies, particularly the Oko Institute and
other subcontractors it uses for expert advice (including Green Peace), are
not equipped to make the kinds of decisions they are making.  Combine this
with the fact that the EU regulations are directly impacting global
regulations on environment, safety and health, and you have a recipe for
continued chaos in the manufacturing world.  With the onset of REACH, the EU
will have unprecedented control over which chemicals may or may not be used
WORLDWIDE.  I suspect our government has received just as bad advice on
REACH as it did on RoHS, so I'm guessing we will back off and let them have
REACH.  That will be a huge and costly mistake and will give the EU chemical
industry a huge advantage over everyone else.  But what do I know?  I'm not
a lobbyist for a multi-billion dollar multi-national corporation.  Of
course, they know better.  They pay better and take officials on nice
junkets, too.  All I can offer is a baloney sandwich.

----- Original Message -----
From: "John Burke" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Friday, December 08, 2006 4:32 PM
Subject: [LF] Official EU exemption request support for lead in solders -
your input is needed - really important please read


> As you may know my exemption request for the use of lead in solders in
> electronics has been accepted for public support / stakeholder discussion
> by
> the EU and can be found as item 15 on the EU public exemptions stakeholder
> discussion web site here:
>
> http://tinyurl.com/y3p2dc
>
> I have prepared a support letter for the lead in solders exemption request
> that RoHSUSA submitted to the EU on behalf of concerned environmentalists
> in
> the electronics industry.
>
> You can support the exemption request by clicking on this link and
> following
> the instructions on that web page:
>
> http://tinyurl.com/yya4ua
>
> I have studied the EU system and I can tell you that to support the
> request
> for lead in solders is going to take you precisely 2 minutes and will be
> officially accepted by the EU as a support document, just follow the
> instructions. And please cc me on the support so I can keep track.
>
> Note that this instruction set is also now linked directly from the banner
> on the home page of the RoHSUSA.com web site.
>
> My aim is to get 1000 letters of support into the EU by the January 10
> deadline.
>
> I have done my best to get this issue highlighted, I am now relying on
> you -
> if you want to be heard click the link above and follow the instructions.
>
> If you have colleagues that would be interested in supporting a lead in
> solders exemption request please pass a copy of this email to them.
>
> Have a great weekend wherever in the world you may be.
>
> Kind regards,
>
> John Burke
>
> Santa Clara - California - USA
>
> (408) 515 4992
>
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