Unfortunately sensationalism trumps science far too often in the world of
legislation. Couple that with the fact that fear and greed can be amazingly
powerful allies when they conspire to effect change and suddenly you find
yourself in wonderland where logic and reason evaporate into the ether.
In a message dated 3/12/2010 8:02:02 A.M. Pacific Standard Time,
[log in to unmask] writes:
Chris:
I actively engaged EU personnel during and after RoHS development. As a
testing and standards development professional, I was very concerned at the
lack of appropriate test methodology and also warned about the potential
cost to industry as a whole and disproportionate impact on small companies.
But much of what I presented went unheeded, including factual information
concerning the appropriate manner of testing RoHS substances in materials
(as opposed to applying inappropriate EPA tests developed for testing air,
soil and water).
When confronting one EU "expert" at an NIST conference on RoHS, I explained
that the standard units used in determination of hexavalent chromium
concentration in conversion coatings are mass per unit area - and the
appropriate international standard for testing was ISO 3613. I also
explained that because those coatings are typically less than 500
nanometers
in thickness, determination of hexavalent coating in mass/mass units is not
feasible since physical separation of the coating from the substrate is not
feasible and also because the old standard "weigh-strip-weigh" method would
be so wildly inaccurate that it is impractical at best (the coatings are so
minute that measuring such small mass coatings in relation to typically
much
more massive substrates is not at all accurate).
I presented strong technical and experience-based arguments for measuring
hexavalent chromium in conversion coatings in units of mass per unit area;
I
referenced an already existing international standard for measuring in
units
of mass per unit area; and I presented arguments as to why it is
inappropriate to measure hexavalent chromium in conversion coatings in
units
of mass/mass. The response from the EU "expert" was "We didn't know". I
presented the same information to Dr. Goodman and other members of the TAC,
to no avail. I wrote to EU government members; again, to no avail. The
fact
is that I am correct and the EU incorrectly set a limit for hexavalent
chromium at 0.1% by weight while dismissing all that was brought to bear on
the subject of conversion coatings. The only honest answer I ever received
as to why the EU refused to correct such an obvious error was that it would
be too difficult to amend the RoHS Directive.
My experience is that while the EU may pay lip service to ideas of
consensus, international standardization, they pretend to care about the
costs of their legislative agendas and impact on small business. Technical
experts are met with dismissive attitudes if their sound technical
information does not jive with what has already been laid down in
legislation. I'm not saying that it's any better in the U.S., because it
isn't - but the EU is just as guilty of ignoring sound science as the U.S.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Chris Robertson
Sent: Friday, March 12, 2010 2:33 AM
To: [log in to unmask]
Subject: Re: [LF] More importantly.... 8 new substances proposed for REACH
control
Dear Bob
Leaving aside all other matters and to put the record straight from my
experience.
- ERA carried out the RoHS category 8/9 study for the European
Commission in 2006 (see
http://ec.europa.eu/environment/waste/pdf/era_study_final_report.pdf).
Annex 1 lists the contributors to the review - organisations we spoke
to. Many are outside the EU or multinationals, particularly from the
US.
- We are currently involved in 3 ecodesign preparatory studies (see
www.eco-furnace.org and www.ecocooking.org). We have been instructed
(not just encouraged) by the Commission to consult as widely as possible
worldwide. Reference to previous studies and ensuing regulation shows
that much of this is built on non EU best practice - standards, Energy
Star etc. Much of this comes from the US.
I'm not suggesting there are not problems (I would sympathise with many
of your points) but just for this issue my own experience is that
nowadays substantive evidence presented in a timely fashion (e.g.
through stakeholder consultations) can shape policy. So it is important
to engage. Trade associations have a key role here.
I hope this is of some encouragement.
Best regards
Chris
Tel: +44 (0)1372 36 7204
<><
www.era.co.uk/rfa
Environmental product compliance conference 17/18 Nov >>
www.era.co.uk/conference2010/.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bob Landman
Sent: 11 March 2010 17:53
To: [log in to unmask]
Subject: Re: [LF] More importantly.... 8 new substances proposed for
REACH control
Chris,
Thanks for the note. Alas, it doesn't seem that they do consult outside
the EU. I could find nothing that indicates they seek input from the
USA or that when they do solicit comments, they pay any attention to
them if they are not from EU member states.
It also seems that the EU regs are focussed on high volume commercial
products without the slightest bit of concern for what they are doing to
aerospace, military, industrial, medical, broadcasting, etc... Where is
the concern for high rel desired long lifetime products that need to be
constructed with chemicals and elements (e.g. lead) ?
Worse, they don't seem to at all understand what they are doing to small
businesses. I recall that once upon a time Dolby was one of those small
businesses. Would there be a Dolby today, were it to be started in 2010?
I doubt it. The EU seems to churn out regulation assuming we are all
like Siemens and thus can bear the burden of all the bloody paperwork.
That's utter nonsense.
It is a fact that small businesses (most are in the USA as that is where
entrepreneurship is king) are where new products come from.
Not all small businesses are started by venture capital (those that are
are commercially oriented and can afford the paperwork employees).
Hence, innovation that our 21st century needs is being stifled by the
increased amount of draconian labor intensive mind boggling regulations
heaped upon us by the legions of EU bureaucrats. What's worse, they are
then emulated by countries like China who use it as a trade barrier!
Bob Landman
H&L Instruments, LLC
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: Thursday, March 11, 2010 10:52 AM
To: [log in to unmask]
Subject: Re: [LF] More importantly.... 8 new substances proposed for
REACH control
One for you here Bob............... :)
http://www.wired-gov.net/wg/wg-wlabel-dti.nsf/wfArticle?ReadForm&unid=E2
41B7919C8E0D29802576E30051AED2
whether they consult outside the EU is another matter...........
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