Gordon,

Nobody is going to add copper or silver to RoHS. RoHS is now a dead-end.
They have now adopted a comprehensive chemical policy in Europe. It just
passed on Wednesday.

You are going to just LOVE REACH..."Registration, Evaluation, and
Authorisation of Chemicals".

REACH can potentially restrict thousands of substances unless the
manufacturers and users can prove they can be handled and used safely. So
can lead in solder be handled and used safely throughout its lifecycle?
Seems that there is plenty of evidence that it can with proper procedures.
So under REACH it would seem to be at least feasible for the electronics
industry to provide evidence that this particular application of lead should
be authorized...

So while far more complex (the June version of the law was 673 pages long
vs. RoHS's 5) it's a bit more rational that RoHS, which just restricted
it...seemingly without scientific evidence supporting many of the substance
bans.

I have suggested to one of the authors of REACH that it would perhaps make
sense to repeal RoHS and simply apply REACH in its place. Were that to
happen I believe the ultimate restrictions would be far less onerous. That
seems unlikely in the current environment but I think its something that the
electronics industry should consider lobbying for as REACH comes in to
effect over the course of the next several years.

Note, though, that this is a different approach from your statement "Even
though we can't prove that harm is occurring", where "we" is the
government... with REACH it is not up to the EU government to prove that
harm is occurring; it is up to industry to prove that harm will NOT occur.
That is why industry is having such a conniption about REACH. TSCA and
nearly every subsequent chemical policy around the world required government
to prove harm in order to ban substances...REACH turns this on its
head...and if it's like RoHS will be adopted (in mutating forms) in other
locales around the world.

RoHS may have been political in nature; despite lobbying by our fine
industry associations (which have agendas that often seem to conflict with
what is in industry's best interests - I just don't get that) I think
industry (not just electronics) needs to develop a better mechanism to
inject science and technological sense in to government deliberations around
the world. The RoHS horse has left the barn; we're seeing it adopted and
mutating around the world. To try and stuff it back in the bag seems to, at
this stage, be a futile waste of energy; what are you going to do after
Europe? Go harass China? California? Taiwan? Australia? Japan? New Jersey?
Maine? What other governments will adopt this type of law in the meantime?
You're going to be spending your time chasing one issue...a tree in the forest.

Instead I would rather see our industry develop a far more proactive, sane,
and consistent approach to taking the hint from governments and NGOs and
working more proactively with them to improving environmental performance of
products while avoiding unnecessary regulation. Work with them to help them
understand what is possible, how business actually works (GM is selecting
substances now that go in to products in 2010; they can't deal with
regulation that has less than a 4 year time horizon! I am sure there are
plenty of other examples), and what can in fact be done to address their
concerns, then doing it. There's much we can do to improve the environmental
attributes of products and either government will require it or we will just
do it. Government's already on the path to requiring it (look at EuP, if you
haven't already) and most of industry is just standing by being reactive and
complaining. That's just shortsighted and foolish.

Mike

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