Chris,
 
TSCA (US toxic substances control ) is up for renewal this year.  http://www.epa.gov/lawsregs/laws/tsca.html

The Toxic Substances Control Act of 1976 provides EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures.  Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics and pesticides. 

I am watching TSCA very closely.  I am a member of PERM participating in the Communications, Advocacy and Supplier task teams).  While officially I can't speak for the membership, I know many members are very concerned that any new US legislation does not echo the flaws in RoHS. Certainly not until we have a certified equal or better replacement for lead and brominated flame retardant chemicals that needed in pcb mfg for high rel/mil/aerospace applications.

Bob Landman
H&L Instruments,LLC


On Jan 26, 2010, at 9:27 AM, "James, Chris" <[log in to unmask]> wrote:

> Yes reversing US legislation might be the only way left to leverage a 
> stand against RoHS, so go Yankees show us how we should have made a 
> stand and save old Europe once more :)
>
> .......... otherwise having a leadfree airliner full of "EU lefties"
> crash on Brussels might work also........ not that I advocate the loss 
> of life.
>
> I don't think the majority of us in the mfr sector in the EU have or 
> had our heads in the sand, or even try to sugar coat the situation, 
> these disparaging remarks just go to detract from the reality of the 
> situation.
>
> Plenty of people lobbied against it albeit too late, but for many 
> visibility of the issue was too late also (it was originally slated 
> for
> 2004 but was delayed because of the total lack of awareness). Others 
> had ignored it thinking it would go away, the US possibly thought it 
> would not affect them, even our own US staff thought that. If anyone 
> did have their heads in the sand it was those outside the EU and who 
> could have possibly waded into the political arena......... and then 
> there were probably those with other motives not wanting to rock the 
> boat.
>
> Certainly for us as an SME it was like pushing water uphill with a 
> rake in 2003 and 2004 and at some stage you just have to accept and 
> get ready for the inevitable if you want to stay in the world's 
> biggest market place.
>
> So go on, get your own legislation reversed, lobby for economic 
> sanctions against the EU on this unfair legislation, because that 
> would be the only possible chance now of making the lefties sit up and 
> think.
>
> C
>
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Gambie
> Sent: 26 January 2010 14:00
> To: [log in to unmask]
> Subject: Re: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
> So you are saying that for all the articles and white papers that have 
> been presented we appear to be stuck with the legislation? Further 
> that you are unable to do anything about the American legislation 
> either?
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Stadem, Richard 
> D.
> Sent: 26 January 2010 13:25
> To: [log in to unmask]
> Subject: Re: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
> Well, think about that for a moment. When forced to build electronic 
> devices with inferior reliability, where do you think they go?
> Recycling can be enforced without reducing the lead in solder.  
> Reduction
> of lead and other chemicals that enhance reliability is what keeps 
> those products away from either the recycling bin or the landfill. It 
> doesn't take too much of a light bulb to figure that one out.
>
> The terms "RoHS" and "reduction of waste" are incongruous.
>
> As far as staying quiet, do we need to shoot the EU lefties before 
> they hear us? There have been reams and reams of papers printed and 
> presented detailing why RoHS is the biggest boo-boo of the century. 
> This email string contains but a fraction of the thousands of articles 
> and white papers that have been presented, to no avail.
> Bob just provided you and impressive list. Don't you think that at 
> least a little bit of that is/was known to the EU loonies before or 
> during the legislation of RoHS?
>
> Pull your head out of the sand. They made a grave mistake; face it for 
> what it is and quit trying to sugarcoat it.
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
> Sent: Tuesday, January 26, 2010 3:13 AM
> To: [log in to unmask]
> Subject: Re: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
> Bob - an impressive list, so why aren't world manufacturing leaders 
> and organisations pressuring politicians to act on it........ why are 
> other national enterprises staying quiet..........
>
> On one point you are wrong - the EU won't be filling their landfill 
> with waste electronics because that was the point of the WEEE 
> directive, to enforce recycling. RohS and WEEE started life as a 
> single piece of legislation, the Restriction element not so much being 
> to keep substances out of landfill but to keep them out of the 
> recycling process.
>
>
>
> -----Original Message-----
> From: Bob Landman [mailto:[log in to unmask]]
> Sent: 25 January 2010 18:09
> To: '(Leadfree Electronics Assembly Forum)'; James, Chris
> Cc: tin whiskers forum
> Subject: RE: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
>
> Here's a partial list of problems ignored by the EU and major 
> manufacturers as they have switched to lead-free manufacturing to 
> comply with the EU lead ban.
>
> PREFACE:
>
> The waivers for defense and high rel products are essentially useless 
> (unless one sends parts to a replater to dip them in molten lead) as 
> the major component vendors have rushed to embrace lead-free 
> manufacturing.
> They have, in many cases, mixed their lead and lead-free parts by 
> using the same part numbers for both.  They have refused to make 
> available to RoHS exempt industries lead bearing platings on 
> components.
>
> 1)  Microsoft's XBOX as has been widely discussed on this and other 
> forums
>
> 2)  increased number of failures in recently purchased PC products
>
> 3)  subject matter experts of published environmental tests show 
> increased amounts of failures in lead-free manufacturing (mechanical 
> connection failures) including parts popping off boards, voids in BGA 
> balls, etc... Manufacturers continue to state lead-free manufacturing 
> is "ok", "no problems found"
>
> 4)  Conformal coatings mitigate the growth of tin whiskers (and not 
> using lead in solder guarantees that whiskers will grow) yet 
> commercial product manufacturers (including a major telecom product 
> provider who shall remain nameless) told me and several others on a 
> teleconference that I attended on behalf of the Dept of Homeland 
> Security, that "the selling price of the products cannot bear the cost 
> adder of conformal coating".
>
> 5)  Swatch watch company gets a waiver to use lead as millions of 
> their watches fail due to tin whisker shorts on crystal oscillator
>
> 6)  FDA forced Medtronic to recall their implanted cardiac 
> defibrilators (from patients bodies) when whiskers shorted the 
> devices.
>    http://www.fda.gov/ora/inspect_ref/itg/itg42.html
>
> 7)  a major Ethernet switch maker has senior field service personnel 
> who have not been told of the potential for tin whisker growth so when 
> failures happen, boards are simply replaced.  Reason given is that 
> "customers pay for service contracts so who cares what the reason is 
> that they fail so long as we repair them quickly".
>
> 8)  a major contract assembler states at a recent IEEE Reliability 
> Society meeting that they see no problems with lead-free manufacturing 
> yet an aside from one of their customers was said to me that "of 
> course they don't see the problems, we see them AFTER we ship the 
> product."
>
> 9)  all the whisker failures reported here 
> http://nepp.nasa.gov/WHISKER/failures/index.htm plus I am advised by 
> NASA that they have confidentiality agreements with many others who 
> call in to report problems which prevents them from listing the 
> failures
>
> 10) I was recently at a national meeting on lead-free manufacturing 
> where it was admitted that on many warplane systems there are lead- 
> free manufacturing problems but the manufacturers refuse to go public 
> with the information.
>
> 11) Anonymous (Terrestrial Application) - Field Failures First 
> Observed Circa 2003
>   http://nepp.nasa.gov/WHISKER/anecdote/2003ckt_breaker/index.html
>
> 12)  over 15,000 papers have been published on the subject of tin 
> whiskers http://www.dbicorporation.com/rohsbib.htm yet to this day, 
> no-one can state why they grow or how without lead to stop them, how 
> quickly they grow, how long they will grow.
>
> 13) white paper by the AIA outlining the problems 
> http://www.aia-aerospace.org/assets/wp_leadfree_0208.pdf
>
> 14)  As was recently posted here by Denny Fritz:
>
> A large amount of information has been accumulated in the 
> Aerospace/Defense community about lead based versus lead-free 
> solders/solder joints.  A good place to start to tap this knowledge 
> has recently been gathered at the Defense Acquisition University web 
> site:
>
> https://acc.dau.mil/leadfree
>
> I will point out the second item on the list - the Lead-free 
> Electronics "Manhattan Project" to compile the "best practices" for 
> use of lead based or lead-free solder in harsh environements.  15 
> leading metallurgical scientists in the US met for two weeks to 
> compile this 350
> page baseline.   Since then, the same 15 met again in August to  
> outline
> the required research to close the knowledge gaps between leaded and 
> lead-free solder, particularly in harsh environments.
>
> 15) The AIA and others are proposing to the US Dept of Defense a $95M 
> project which will take three years and which will hopefully come up 
> with solutions to the present problems with lead-free manufacturing.
>
> The bottom line is, that util the problems outlined above are solved, 
> if the EU does not want people to die from an increased amount of 
> failures in transportation, electric power, medical devices, not to 
> mention the waste and expense of filling landfills to overflowing with 
> an increasing number of failed electronic products, the EU should 
> immediately retract the RoHS ban on lead in manufacturing electronic 
> assemblies and components and instead specify that at least 5% lead 
> should be in all tin coatings and solders.
>
> Bob Landman
> H&L Instruments, LLC
>
>
>
>
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
> Sent: Monday, January 25, 2010 11:19 AM
> To: [log in to unmask]
> Subject: Re: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
> What evidence do you have to be able to assert this defamatory
> statement:
>
> "Knowing the EU and how the major manufacturers suck up as they do not 
> seem to be concerned about products surviving past their warranty 
> period, I highly doubt this report is factual."
>
>
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Whittaker, Dewey
> (EHCOE)
> Sent: 25 January 2010 16:10
> To: [log in to unmask]
> Subject: Re: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
> I am not aware that any of the so-called halogen-free laminate 
> materials will meet the Class 3 or 3/A requirements of IPC-6012 when 
> pre-conditioned per IPC-TM-650, Method 2.6.7 (Thermal Stress Testing 
> per
> 3.6.1.3 of the Rev C going to ballot), let alone some of the other 
> idiosyncrasies that are currently being addressed.
> Dewey
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bob Landman
> Sent: Sunday, January 24, 2010 3:55 PM
> To: [log in to unmask]
> Subject: Re: [LF] [tinwhiskers] FW: [SMART] Very useful RoHS review 
> conference report
>
> According to this EU article, manufacturers have successfully 
> transitioned from halogenated and pthalate containing pc boards 
> without any difficulty.
>
> Is this true?
>
> Are the new boards flame retardant?
>
> Do they survive multiple passes at lead-free soldering temperatures?
>
> What about delamination?
>
> What about pad cratering?
>
> Other issues?
>
> Knowing the EU and how the major manufacturers suck up as they do not 
> seem to be concerned about products surviving past their warranty 
> period, I highly doubt this report is factual.
>
> I would appreciate comments from those who have more than one year of 
> experience with these new board materials.
>
> Do they pass the UL flame and smoke tests?
>
> What other tests are they certified to pass?
>
> Have the tests been altered so these new board materials can pass?
>
> What are the life cycle testing -55C to +125C - results?
>
> -40C to +85C life cycle testing results?
>
> Shock?
>
> Vibration?
>
> How many layers?  (at least 24?)
>
> Will the Airbus avionics be using these new board materials and if so 
> when?
>
> Bob Landman
> H&L Instruments, LLC
>
> Sent from my iPhone
>
> On Jan 22, 2010, at 12:28 PM, "John Burke" <[log in to unmask]> wrote:
>
>>
>> FYI see link for report in email below
>>
>> John Burke
>> (408) 515 4992
>>
>>
>> -----Original Message-----
>> From: SMART Group smart-e-link [mailto:SMART-E- 
>> [log in to unmask]] On Behalf Of Nigel Burtt
>> Sent: Friday, January 22, 2010 1:43 AM
>> To: [log in to unmask]
>> Subject: [SMART] Very useful RoHS review conference report
>>
>> "Greening Consumer Electronics - from Hazardous Material to 
>> Sustainable Solutions Conference" in the European Parliament held on
>> 18 November
>> 2009
>>
>> Leading companies within the electronics sector sent strong message 
>> to
>
>> EU regulators at ChemSec Conference: Moving away from Brominated 
>> Flame
>
>> Retardants and PVC is possible, feasible and is already happening!  
>> The
>
>> question is not whether electrical and electronic equipment industry 
>> can phase out these chemicals, but when, says Jill Evans, Member of 
>> the European Parliament. (Rapporteur leading the drafting of recast 
>> amendments to
>> RoHS)
>>
>>
>> Full report including presentations and video
>>
>> http://www.chemsec.org/rohs/conference
>>
>>
>>
>>
>> Regards
>>
>> Nigel
>>
>

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