Letter to EU TAC regarding tin/lead solder exemption

TAC = Technical Adaption Committee set up by the European Commission to help implement RoHS and pass on exemption applications

John Burke is doing a magnificent job and everyone should know about it. This letter to the TAC hasn't been posted yet on . Pass it on. Reprint it. I believe that John Burke's letter will have an impact, come July 1, 2006. It will go down as another demonstration of how individuals who care can influence the course of events.

--- John Burke wrote:

> From: "John Burke" >> To: "Harvey Miller" , >> "Joe Fjelstad" >> Subject: FW: Letter to EU TAC committee >> Date: Tue, 20 Jun 2006 22:43:08 -0700 >> >> Guys this went out individually addressed to each member of the TAC this >> evening. >> >> >> >> John >> >> >> >> >> >> Dear EU TAC member, >> >> >> >> I am writing to you for a number of reasons - all of which concern the >> environment. >> >> >> >> Firstly I would like to congratulate you on the results achieved in >> tackling >> the job of Technical Adaptation Committee - to have discussed so many >> times >> the very substance of the RoHS legislation and worked through with the >> technical consultants the reality of implementing this kind of >> environmental >> legislation is outstanding. >> >> >> >> You have made incredible headway given the budgetary constraints and the >> lack of original research funding for the task. >> >> >> >> And it is on this last point that I am mainly concerned in writing to >> you. >> In October 2004 an application was submitted presented to the TAC by RM >> Sommer Consulting Ltd who stated that: >> >> >>

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> =========== >> RM Sommer Consulting Ltd believes that the industry standard eutectic >> Sn63/Pb37 solder should be exempt from the substance restrictions of >> article >> 4(1). The grounds of this submission for exemption lie in article >> 5(1)(b). >> It is the view of RM Sommer Consulting Ltd that the negative >> environmental >> and/or health impact of the alternatives are likely to outweigh the >> environmental and/or health benefits. The supporting evidence for this >> is as >> follows: >> . The environmental impact study by Ed Smith and Kristine Swanger of >> K*Tec >> Electronics concluded "The data from these experiments shows that lead >> free >> solders leach at levels that would cause them to be classified as a >> hazardous waste". >> . The paper "Is this Ban Really Necessary? A Critical Investigation of >> the >> CRT Ban: by Clark Akatiff details an investigation of the Palo Alto >> landfill >> that has existed since the 1930s. It has an estimated 20,000 -100,000 >> CRTs >> disposed there from 1982 to 2002. These CRTs are part of televisions and >> computer monitors, both of which have a high level of associated >> electronics >> using eutectic Sn63Pb37 solder. Additionally, given the age and type of >> equipment the electronics would be predominantly through-hole technology >> which uses x10+ more solder per joint than modern Surface Mount >> Technology. >> This makes this study representative of worst case for EEE waste. The >> lead >> content of the leachate pumped out contained, at worst case 1 part per >> 100 >> Million - 500 times lower than the EPA actionable level. The lead levels >> from the 10 monitoring wells ranged from undetectable to 1.3 parts per >> 100 >> Million - 1/400th of the EPA actionable level worst case. >> . Dr Laura Turbini, from the Centre for Microelectronic Assembly and >> Packaging provides a well rounded argument supported by a plethora of >> data >> and like minded research in her presentation "The Real Environmental >> Cost of >> Lead Free Soldering" >> >> This was not discussed at the October 2004 TAC meeting, but was taken >> off >> line and referred again in the December TAC meeting of 10th December >> 2004 >> Item 5 on the agenda was 5. DIRECTIVE 2002/95/EC - ARTICLE 5(1) (B) >> which >> dealt with new exemption requests. >> >> >> >> On this there is an item 19 which is the RM Sommer submission which has >> the >> minuted annotation "- entry 19: as this is normal solder, it should not >> be >> studied;" >> >> >> >> This brings me to the point about the lack of funding or up front >> research >> on this project. The dismissal of this exemption request in this manner >> can >> only lead me to the conclusion that the TAC had been assured that there >> was >> a sound scientific reasoning for a lead in solders ban, otherwise an >> even >> superficial study of the data available at that time would have revealed >> the >> Stuttgart study and a wealth of other data supporting the application in >> addition to the sources cited. >> >> >> >> So as I believe that the TAC is composed of fair minded environmentally >> concerned people, I would suggest that you have a chance to make >> history. >> >> >> >> The data for making a lead in solders exemption under article 5(1)(B) >> is >> simply overwhelming, much of the data is posted in support of exemption >> requests under round 5 stakeholder commentary and support, much of it >> can be >> linked to here:
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>> >> >> >> I would ask you all individually to think long and hard about the >> contents >> of the Stuttgart and EPA lifecycle studies which show that the >> environmental >> impact of removing lead in solders is 5 to 6 times higher than simply >> leaving the situation as it is. >> >> >> >> You have the power to give exemptions. You understand the reasoning >> behind >> DIRECTIVE 2002/95/EC - ARTICLE 5(1) (B) and you are fully aware of the >> meaning of the term "precautionary principal" which it is my belief >> applies >> in this case. Please consider granting a blanket exemption to lead in >> solders; which given the overwhelming evidence would have been granted >> had >> the matter been studied in 2004. >> >> >> >> I thank you for the great work that you are doing, I just wish that the >> whole matter of the lead in solders ban had been far more thoroughly >> looked >> into by the EU before you were asked to step up to the TAC position. You >> are >> meeting as a group next week; don't miss the opportunity to improve the >> environment. >> >> >> >> Kind regards, >> >> >> >> John Burke >> >> >> >> RoHSUSA >> >> >> >>
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