Brian Ellis is on line. He doesn't have any knowledge of the Deubzer thesis.
I haven't had either time or patience to wade through the whole doc. I
was hoping for an ExecSum but had to satisfy myself by skimming through
the start and the conclusions. It appears to be an interesting study but
my skim reveals a few initial potential problems (some of which may be
handled in the unread text):
1. If CR(VI) is of so little importance, why was it included in the
first place?
2. I'm astonished at the figures for Cd: I believe that this may be
ascribed largely to the use in Cd-Ni batteries which had already been
largely phased out and replaced by NiMH ones long before RoHS was
implemented. Is it correct to use legacy figures to promote
self-congratulation?
3. I'm astonished at the selection of just a few countries for the
study, missing out such important producers of EEE as F and I and
including relatively minor ones, such as B and LT. This is all the more
surprising in view that it is admitted that the economic differences
regarding EEE are so different between these countries, as are the
attitudes towards purchasing (e.g., the French would be much more likely
to consume products with a "Fabriqué en France" label than a Brit would
choose a "Made in the UK" one) and the sectors are different (S and SF
are strong on telecoms, while I is strong on white goods). Other than
that, there is a wide difference in the way WEEE has been implemented
across the Union. GR, for example, is very weak, as I suspect are most
of EU27 minus EU15. I know, for a fact, that CY has done almost nothing
towards the practical implementation of WEEE, other than stir a few
words. There is a company at Strovolos, near Nicosia, that purports to
collect WEEE but I see very little sector activity there; the public
have not been advised and most domestic WEEE, other than large white
goods, is still landfilled. I think about half the bulky items like
large TVs and white goods are taken back by retailers when replaced, but
I doubt whether they are disposed of correctly by the retailers, judging
by what I see (only the other day, I saw a pickup truck loaded with
half-a-dozen old washing machines drive off a main road to a major
landfill. Of course, I have no idea whether the electrics had been
stripped out or not).
4. Small countries and particularly the island states of CY and MT are
at an economic disadvantage when it comes to recycling. It implies
exporting all WEEE, which can be very costly. If they contain HazMat,
then the Basel Convention applies.
5. The economic and environmental studies appear not to have taken into
account all the holistic implications of the resources.
6. Can the 36 companies that returned questionnaires be considered
representative? I have no idea how many EEE manufacturers/importers
there are in the EU. OK, CH is not in the EU, but it is estimated that
about 3000 companies have some practical activity in electronics alone.
Many of them are one- or two-man affairs, such as repair shops,
consultants etc.; many are small departments of companies in other
sectors; many are SMEs in the electrical/electronic sectors; some are
massive stakeholders in the industry, such as ABB, Ascom, Siemens-Albis
etc. But if 3000 for a population of 8M were extrapolated to the 500M of
the EU, it would seem probable that the number of companies in the
sector would at least approach 100k. 36 companies represent considerably
less than 0.1% of the total. I suggest that it is nonsense to formulate
anything based on such statistically invalid data.
7. You may consider this trivial, but if a major report is published
with atrocious use of language, then it loses some credibility.
Just some thoughts... I await being shot down in flames.
Brian
John Burke wrote:
> I was hoping someone on the link could throw some light on the answer to
> that (is Brian Ellis on line?)
>
> John
>
>
>
> John Burke
>
> (408) 515 4992
> -----Original Message-----
> From: TechNet [mailto:[log in to unmask]] On Behalf Of Dennis Fritz
> Sent: Saturday, January 19, 2008 2:39 PM
> To: [log in to unmask]
> Subject: Re: [TN] EU "simplification"
>
>
> Interesting in how they cite data. The US EPA study is in part "credible"?
>
> What is this 2007 study by Deubzer?
>
> Denny Fritz
> MacDermid, Inc
>
> In a message dated 1/18/2008 1:56:40 P.M. Eastern Standard Time,
> [log in to unmask] writes:
>
> I received this email from one of my contacts. I strongly suggest a look
> at
> the environmental impact "DATA" contained in section 3 here is the link:
>
>
>
>
> http://ec.europa.eu/enterprise/environment/reports_studies/studies/draft_rep
> _study_rohs_directive_dec07.pdf
>
>
>
>
>
>
> **************Start the year off right. Easy ways to stay in shape.
> http://body.aol.com/fitness/winter-exercise?NCID=aolcmp00300000002489
>
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