Letters: Leave the Lead In, part 2
Here is a second response to my essay, "Calls to Throw Out RoHS Unnecessary." This one is from Gordon Davy who penned the opus "Irresistible Force Meets Immovable Object - A Lead Free Essay." Original text from the letter is in a larger font.
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.
My thanks to Joe Smetana for bringing to my attention a recent essay defending RoHS written by Ray Franklin of ROHSwell.com. This essay is available at http://www.rohswell.com/News/Genl020.php. Since I don’t know how long Franklin's essay will remain at that link, I have included it at the bottom of this posting so as to make it a permanent part of the Leadfree archives. It has been quite some time since anyone has presented an argument in favor of RoHS in this forum, so this might make interesting reading for subscribers. I do offer some comments of my own.
All RoHSwell pages are permanent.
Franklin calls RoHS "the first of many small steps along a path." This single statement raises a number of questions:
Definition of terms. The environmental movement is a process, sometimes referred to as a path. It is also called a megatrend. Other examples of megatrends are the industrial revolution, the development of the automobile, telecommunications and biotechnology.
· Who established the path? As has been the case with this issue from the beginning, the proponents have preferred anonymity, presumably so as not to have to engage in the kind of debate that Franklin, in subsequent comments, seems to favor.
Initially the path was established by NASA astronauts when they first saw the Earth from vantage points between Earth and Moon. The images spawned the environmental movement, which now includes a very large fraction of the people on the planet.
· What are the next "small steps"?
· How many more such steps?
The next steps? How many? I'm not a prophet, just an engineer and publisher. The natural progression of respect for the environment has been from emotional activism in the 60s and 70s to pragmatic action in the 80s and beyond. The latest is the emergence of the precautionary principle. This principle states that "actions should be taken to avoid serious or irreversible environmental harm, even if the available scientific evidence cannot provide evidence of such harm." This principle was consciously applied in the formulation of the RoHS directive. Other nations appear to have embraced the precautionary principle as well, Japan being one of the most notable. (See Resources 1 and 2).
· What is at the end of the path? One answer I have seen is "the biosphere has been rid of hazardous materials." Apparently “no one is being poisoned by use of the prohibited materials in electronic products" is not a good enough answer for him.
I clearly stated the destination in the second sentence of my essay. "The path leads to a healthier world for all by eliminating environmental hazards." As for the quoted poisoning statement not being a good enough answer for me, that is correct. The statement is unrelated to the question and unsubstantiated. The true issue is with the low-level toxicity of Pb in our environment, not the acute toxicity of electronics to humans. However, I do suspect that ingestion of a cell phone would indeed be acutely toxic.
· Who gets to announce that the end has been reached and that there are no steps of any size to be imposed on anyone?
Processes that underlie megatrends do not have fixed, pre-established end points. One of the other forces behind RoHS is global politics. Where is the end in a political process? Mr. Davy's question has no answer. For that reason it is meaningless.
Later he calls for rigorous scientific proof. As I have asked before, who gets to decide whether evidence and arguments meet that test? We have seen how no amount of evidence is enough to satisfy those who "know" that deca-BDE is unsafe to use, but their own favored substances are.
I asked for proof that Sn-Pb solder is environmentally benign. Since we are talking about RoHS, the deciders are the European Commission. If Mr. Davy has not seen any evidence of the toxicity of PBDE, I can only conclude that he has not been looking for it. The same can be said for all six of the RoHS substances. (See Resources 3 and 4).
In interesting metaphors Franklin refers to those who favor progress on this path as "cheerleaders" and those who do not approve of this path as "nay-sayers urging the walkers to veer off onto a different path." He seems to have confused cheerleaders and policemen.
I chose my words carefully. Cheerleaders are those who support the precautionary principle, the environmental movement and the political processes that generate regulatory law. The nay-sayers are those who oppose the same. Read Mr. Davy's article and decide for yourself if the tone is positive (cheerleader) or negative (nay-sayer).
Yet later in the same essay he asks "Are there good reasons to resist the push to eliminate lead from solder? Possibly. Perhaps a thorough analysis of the pros and cons will exonerate Sn-Pb solder for electronics." This question also raises other questions:
· Does he realize that by saying this he not only acknowledges that whoever it was who laid out the path for us all to follow might have made a mistake, but also that this person or coalition did so without having done a thorough analysis?
· Does he realize that the analysis has long since been done?
· Has it occurred to him that technical merit of the other prohibitions in RoHS might be just as lacking?
· Does he realize that the prohibited brominated flame retardants are not even commercially available?
So many assumptions. No wonder Mr. Davy's writings are so long. He has to deal with each assumption he makes. The path is not fixed, not like a human-built road. It is a metaphor for a process of change. If the future were totally known, the journey would not be necessary. Could there be a mistake in RoHS, particularly in the ban on Pb in solder? As I said before, perhaps.
I think the questions, with all their assumptions, make it clear that Mr. Davy is unaware of or does not support the precautionary principle. The RoHSUSA.com site holds up the EPA Life Cycle assessment document as the ultimate proof that Sn-Pb solder is environmentally benign. Even if one were to read the entire 472 pages, I doubt most reasonable people would reach that conclusion. The more manageable executive summary (47 pages) shows that SAC has a somewhat higher impact score than Sn-Pb solder in selected categories. In toxicity and health related categories, Sn-Pb solder has impact ratings from 8 to 68 times higher than SAC (table ES-4). It also states in the final summary, that the "SnPb alloy would still have the higher potential impacts for both public non-cancer and aquatic ecotoxicity than the other solder alloys, based primarily on its relative toxicity." RoHS is founded on the precautionary principle. The EPA report strongly supports the RoHS ban on lead. (See Resource 5).
Apparently it doesn't perturb him that the consequences of this failure to think before acting has cost the world economy untold billions. His justification: "When has any human effort ever been perfect the first time?" Keep that excuse in mind, folks. It can cover a multitude of sins.
Costing "untold billions." Let's assume this nebulous, undocumented price tag is true. Everyone chooses how to spend their money. Governments tell businesses how to spend some of their money through regulation. That is a basic principle of practical democracy. The Europeans, Japanese, Chinese and Koreans have all chosen to spend money on environmental regulation. The choice was conscious.
As for the so-called excuse, how I could be justifying his "failure to think" assumption before Mr. Davy had put it into words? I guess he expects precognition and all decisions to be absolutely correct for all time. I have never known even engineering decisions to achieve that level of perfection. The RoHS bans were not made in a scientific vacuum, as Mr. Davy suggests. While I cannot point to specific studies used by the EC, I am aware of the scientific, environmental and political trends that gave birth to RoHS. It seems obvious to me that much of the world is equally aware of these trends. Hence the raft of protective legislation from around the world.
Franklin calls for use of the "scientific method", which he implies that he understands, then uses statements such as "I have a hard time believing" and "I cannot support these protests because the tactics seem to be mostly destructive rather than constructive." Perhaps he needs to be reminded that the scientific method does not involve his ability to believe or his assessment of tactics. One wonders whether he would acknowledge as scientific anything that led to a conclusion he didn't already favor. That couples with the attitude of environmental activists that they know what is right for everyone, and anyone who opposes them is obviously an obstructionist – and wrong. The everyday terms for these attitudes are prejudice and self-righteousness.
Read my words in context and you will see how Mr. Davy has twisted them. My original paragraph was actually offering a little friendly advice on a more effective communication strategy. I guess it fell on deaf ears.
The scientific method requires independent reproduction of results. I asked for supporting studies of the environmental superiority of Sn-Pb solder. None have been offered. Mr. Davy accuses me of being unwilling to acknowledge scientific proof that opposes one of my opinions. I have the same complaint of him. This paragraph is also a great example of name calling, a tactic Mr. Davy favors. It happens to be a logical fallacy, argumentum ad hominem.
The other statements Franklin makes in support of his beliefs I have refuted in essays (with evidence and rigorous arguments) that I have posted to this forum and to the Halogenfree forum, starting seven years ago. But rather than repeating those refutations here, I thought that other forum subscribers would like to have a chance to comment on his claims, and also on any vested interest he might have in seeing RoHS prevail.
I am sending this posting to him. He would of course be welcome to post his reply, or he can send it to me and I will post it for him.
Gordon Davy
In summary, most of the complaints against my views are based on false assumptions (argumentum ad ignorantiam). The arguments against the RoHS lead ban tend to be made in ignorance of the precautionary principle.
Mostly what I find annoying about the disapproving responses I have received are the sweeping assumptions. I would be happy to discuss these topics in a reasoned, respectful manner. There are more effective ways to uncover my motivations than to make assumptions and veiled accusations. Direct questions work quite well.
I hope my views are clear. For everyone who is reading between the lines, here is a highly inaccurate profile in sound bytes. I am pro-technology and pro-environment. I am pro-life and pro-choice. If you see any contradictions in this profile, you have probably made some unwarranted assumptions. Move beyond polar opposites and ride the continuum.
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