Thanks Gordon,
I read that paragraph, but could not find any wordage that identified
the restriction as 1% of non-reacted TBBPA.
"<<It is proposed a prohibition on consumer products with more than 1
percent TBBPA by weight in the product's homogeneous component parts.>>"
Perhaps this is just semantics, but to regulatory offices and courts,
semantics can be everything.
Will the final regulation actually specify "non-reacted" TBBPA as the
restriction? Or will regulatory offices and courts be "understanding"
of the "intent"?
Thanks,
Ryan
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Davy, Gordon
Sent: Thursday, June 28, 2007 8:42 AM
To: [log in to unmask]
Subject: Re: [LF] Norwegian legislation
My thanks to Chris James for posting the Appendix to the Norway
document. I've been studying it this morning, and in answer to Ryan
Grant's question about the limits to the use of TBBPA, the following two
paragraphs are a relevant excerpt.
It is proposed a prohibition on consumer products with more than 1
percent TBBPA by weight in the product's homogeneous component parts.
Examples of known application areas for TBBPA that will be prohibited
are EE products and different plastic products...
The primary purpose of the regulation is to regulate its use as an
additive. With an extensive prohibition it is expected that the greatest
expenses will be associated with a prohibition on use in circuit boards
and means of transport, however by proposing a limiting value for TBBPA
in products of 1% the intent is not to cover reactive use in circuit
boards. In practice the portion of TBBPA in the circuit boards will be
under 1%.
The reason for the differentiation between additive and reactive is
discussed above this in the Appendix. They say that when TBBPA is not
chemically reacted with the polymer it is in, it can leak out, and that
it has been found in water leaking from landfills. (No statement of
concentration.) They say "There are reasons to presume that TBBPA used
as an additive exists in many imported products such as inexpensive
consumer electronics and electrical toys produced in Asia, however it is
difficult to survey the extent."
The takeaway is that conventional laminates such as FR4, in which the
TBBPA has been reacted with the epoxy polymer, is OK because the amount
of free TBBPA is well below one percent.
Gordon Davy
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