I just added my support for exemption #18 on hexavalent chromium conversion
coatings. The Oko Institute will have to at least look at the fact that
both the IEC and their enforcement authorities have not been able to come up
with a measurement method for hexavalent chromium in conversion coatings in
units of weight percent. But as I understand it, the new Euronorm written
by DIN will outline a test for which results will be reported in mass per
area, not weight percent. Also, I challenged them to provide evidence that
replacement products work as well as or better than hexavalent chomium in
all applications, particularly where bare metal is exposed to the
environment (air, soil and water). The burden of proof for those claiming
that replacements work as well as hexavalent chromium must be high,
considering that the consequences of field failures on safety-related
equipment may result in loss of power, loss of control, shorts, electric
shock and damage to the environment, health and property. There is also the
potential for early failure of consumer goods, meaning that more products
will enter the wastestream earlier than they normally would.
----- Original Message -----
From: "John Burke" <[log in to unmask]>
To: "'Timothy McGrady'" <[log in to unmask]>; "'(Leadfree Electronics
Assembly Forum)'" <[log in to unmask]>
Sent: Sunday, December 10, 2006 4:53 PM
Subject: RE: [LF] Official EU exemption request support for lead in
solders - your input is needed - really important please read
> Interesting,
>
> You might want to inform him that this exemption request has already set a
> record in terms of industry support......................8- )
>
> I also do not expect a reversal. The Oko institute has already stated
> publicly in their report on round 5 that they are not contracted to "go
> there" on the validity of the political decision based on lack of science
> to
> ban the material in this application in the first place. They stated
> publicly also that they were not in a position to even review my support
> of
> the round 5 exemptions on the same basis (see Oko report round 5 final
> report)
>
> There is hope - the commission since May have continuously stated that
> they
> would not accept my exemption request, and yet there it is as item 15.
>
> The commission in communications to RoHSUSA on this issue repeatedly state
> that the lead in solder has been removed to "make recycling easier" under
> the WEEE laws and avoid the environmental issue completely.
>
> It is obvious to me that they will indeed look very closely at this
> decision
> and will do so on their published time frame of 2008.
>
> My prediction is at that time they will make lead in solders exempted at
> the
> option of the manufacturer NOT reverse the legislation which would be
> politically damaging.
>
> One thing is for certain, the more companies that support it instead of
> complaining about lead free, the less wiggle room the EU will have at the
> end of the day, since all support correspondence HAS to be published on
> their web site under their own rule set.
>
> John
>
>
>
> John Burke
>
> (408) 515 4992
> -----Original Message-----
> From: Timothy McGrady [mailto:[log in to unmask]]
> Sent: Sunday, December 10, 2006 8:02 AM
> To: (Leadfree Electronics Assembly Forum); John Burke
> Subject: Re: [LF] Official EU exemption request support for lead in
> solders
> - your input is needed - really important please read
>
> 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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>
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>
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>>
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