I started to speed this, but began to lose the will to live at page 100 or
so and had to blow all tanks back to reality. So my reading is probably not
as complete as Brian's.
We have to assume they have reported honestly what they found, trouble is
they didn't look very hard or in many useful places or very critically, some
of the stuff is of "Heh?" relevance, but presumably was handy and adds bulk
to report. Worse they have then rather naively extrapolated from this
partial data to the whole of Europe and drawn conclusions which are then
stated as if facts.
The Cadmium usage highlighted by Brian is a good example. There must have
been an awful lot of cadmium plated parts or yellow colouring in electronics
before RoHS, because it wasn't in the solder. The major use of cadmium as an
alloying ingredient is in NON electronic electrical low melting alloys
(safety valves things like that)- by a huge amount compared to EEE. Perhaps
they mixed the total usages up, and then extrapolated a ROHS difference from
the whole WEEE and non WEEE usage. Who knows?
Wouldn't be surprised because, looking at the tables for amount of materials
saved pr unit and then putting those into the tonnages removed from
environment produces anomalous results on quantities of products made, which
you think they would have at least verified independently. I am not even
sure they agree with their numbers earlier but as I say I speeded though
this till my brain gave up and didn't try to check, could be my math as well
I suppose.
And I surely must have misunderstood the bit which I think said lead free is
major negative impact on landfill usage due to the increased volume of lead
free compared to tin /lead....
Regards
Mike
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Brian Ellis
Sent: Sunday, January 20, 2008 9:04 AM
To: [log in to unmask]
Subject: Re: [TN] EU "simplification"
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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