Letters: Leave the Lead In, part 1
Apparently my previous essay, "Calls to Throw Out RoHS Unnecessary," has touched a nerve with those who are fighting RoHS and related regulations. Ordinarily I would just ignore the kinds of responses I have received. But I do enjoy a bit of sparring when the opponents are making such obvious errors. Here's one letter, from D.F. (name withheld), followed by my rebuttal of each point. Original text from the leter is in a larger font. Also note that some of my comments, particularly those at the end, apply to all those who wrote to say how wrong I am. D.F. is not being singled out.
The original title of this article was in error. According to Mr. Burke, publisher, the correspondents I mention here have no connection with Pushback at RoHSUSA.com.
Ray,
I strongly suspect that you are making a good living consulting to the scared companies now rushing to RoHS compliance. Is your defense of RoHS self motivated by economics?
First of all I am not consulting. My site is very much a part-time business, less than quarter-time actually. It is funded by Google ads and by sales of my book, which helps engineers and others with the mechanics of the compliance process. I manage to cover my expenses and earn a little for my time. My book customers seem to feel that I am delivering a reasonable value for the price.
I happen to think that any environmental legislation is generally a good thing. The specifics and fitness of each law must be determined over time. Some get repealed and the good ones live on. Until the environmental movement emerged, too many business owners were free to pollute at will. While that situation has improved, it is far from perfect. RoHS is one more attempt to protect the common environment from those who accept little or no responsibility for the consequences of their pollution.
I think there is a tremendous weight of science now showing that the elimination of lead, particularly in electronics is misguided legislation. The US EPA has not moved on the issue, and the commercial electronics production arena is left to deal with this issue against the EU. I sense that even Japan has backed off. That view will be more clear to me after next week, when the JISSO International Council meets in Berlin.
As I stated in my essay, it would be fine with me if Sn-Pb solder was exonerated and shown to be non-polluting. The EPA LCA document does not do that. Even if Pb were exempted, the hazards of the other banned substances would remain just as real. The whole point is that the RoHS directive is a reasonable law. The EC has already demonstrated a willingness to adapt it by adding exemptions. If Sn-Pb solder is exempted, it remains a good law. The final decision on this issue rests with the EC.
Probably not all RoHS is bad - I suspect that the cadmium and chrome restrictions may in fact be fine. There probably should be other materials instead of lead in RoHS, but we are left fighting with the regulations which no one expects to be repealed.
Thank you for your support on this point. The law has room to improve, and mechanisms in place to do so.
Incidentally, you probably ought to change your logo from a green leaf to a blue leaf. When green is printed, the most common pigment for green is pretty close to those brominated compounds you brag about - just chlorinated, not brominated. I would bet that burning your printed green leaf gives off detectable dioxins, too
D. F. (name withheld)
I wasn't bragging about brominated hydrocarbons. I was castigating them. Halogenated organic chemicals were mostly released into the world with inadequate testing for toxicity and long-term biological effects. All of us are now paying the price for that short-sighted strategy. Every year a few more species are found with reproductive abnormalities caused by estrogenic pollutants in the air and water. Over and over again I read about yet another organic chemical that has been found to be estrogenic. Anyone who says these chemicals are doing no harm is not paying attention. The science is voluminous and sound.
The RoHSwell green leaf logo is not printed on any business materials - it is used solely on the web. Most printers use process colors of cyan, magenta and yellow, so the green ink problem wouldn't exist anyway. And if it were printed with soy-based inks, free of toxins, even better.
I feel no need to argue the specifics of which scientific study is better than the other. That has already been done very thoroughly by others. I have read much about the consequences of pollution from the RoHS six. The environmental effects of these substances have been studied for decades. I think the evidence of harm is overwhelming. The easiest way to see what I have seen in this regard is to look at back issues of Science News for the past twenty years. You can browse and search the archives online.
My purpose in publishing the RoHSwell site remains unchanged. I just want to help with what I know to be a daunting and difficult task: achieving compliance. I gather information, sift it through my experience, and present what I consider to be the most useful. I will keep doing exactly that.
Read the next response, and my comments, in Letters: Leave the Lead In, part 2.
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