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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