From: Harvey Miller To: R Rasmussen , Bob Baer Subject: Fwd: Gordon Davy's response --- to-' Your Opportunity to be Heard' -- on RoHS Date: Apr 30, 2007 7:29 PM
Introduction >
> The European Commission in charge of compliance with the lead-free ban > is > now re-examining the RoHS directive that invoked it. >
> An enormous penalty has been exacted on electronics equipment > reliability > and on the environment. Tin mining has grown by at least 40% with more > impending, to replace lead. From an article in the Resource Investor, > April 17, 2007, "Silver sales were 13.5 million ounces last year, up > from > 9.7 million ounces in 2005, while the average realized price increased > to > $11.72 an ounce, up from $7.31." In a tight market like tin, that can > only mean more mining. >
> Finally, a real cost-benefit analysis may be in the works. Gordon has > performed a great service, as usual, in detailing some of the reasons it > is needed. >
> Everyone who pretends to be an environmentalist should become aware that > unintended consequences lurk behind many seemingly environmentally- > friendly measures. Substance bans are a childish, simplistic reaction > that often defeat their purpose. Exceptions to this principle should be > weighed carefully. There is an intelligent alternative---OSHA- enforced > global recycling! >
> Harvey Miller >
> --- "Davy, Gordon" wrote: >
> > Date: Mon, 30 Apr 2007 18:52:47 -0400 > > From: "Davy, Gordon" > > Subject: Re: [LF] [CN] RoHS/WEEE Directives - Your Opportunity to be > > Heard > > To: snipped-for-privacy@IPC.ORG > >
> > Sahar Osman-Sypher has posted to Compliance Net, but not the Leadfree > > forum, a notice of an official request for input regarding the impact > of > > RoHS/WEEE Directives on the electronics industry. That posting can be > > seen in the CN archives. The questionnaires and more information can > be > > found at
formatting link
Deadline for > > completion is May 25. I post below my response to the person > identified > > on the cover of the questionnaire as the contact. > >
> >
> >
> > Gordon Davy > >
> > Email to contact for RoHS questionnaire > >
> > Ms. Bogaert: > >
> > I have just received from the IPC, an industry association, a link to > > the ECOLAS Ltd. questionnaire which lists you as the contact. I > started > > to examine it but found that it appears to be aimed at companies that > > are required to comply with the RoHS directive. I wonder if you have > > considered preparing tailored questionnaires for companies > manufacturing > > EEE that is regarded as exempt, such as military and aerospace > > electronics, and for companies that supply the manufacturers of > > non-exempt EEE. If your questionnaire does not get completed by these > > segments of the industry, you will fail to capture the associated > costs, > > and will significantly underestimate the impact of RoHS. > >
> > In passing, the completed questionnaires that you receive from the > > non-exempt manufacturers will surely show the greatest cost to comply > > with RoHS is compliance verification - and attorneys. Many unanswered > > questions remain on how to conduct accurate verification testing - > there > > are no industry standard test methods. (That fact could have been > > established rather easily before RoHS was enacted, but was not. Even > > Greenpeace knows it now.) Consequently, compliance is really a matter > of > > risk management. > >
> > I trust that it has not escaped your notice that RoHS has had a > profound > > effect on the exempt industries as well as non-exempt industries. As > > just one example, I along with several dozen others representing > several > > dozen manufacturers of exempt (high reliability) equipment and their > > customers (e.g., military services, NASA) have long been involved in a > > telephone conference (it started five years ago) that lasts from one > to > > two hours every week. This conference focuses on just one (presumably > > unforeseen by those who enacted the directive) consequence of the > > directive. > >
> > That consequence is the growth of tin whiskers on the electrical > > terminations of electronic components that we buy. Most of those > > components are of course the same components bought by manufacturers > of > > non-exempt equipment. While the directive does not mandate that tin > > without lead be used as the termination finish, that has proved to be > > the preponderant choice by the component manufacturers. Our industry's > > market share is far too small to influence those decisions. The result > > of using tin without lead (instead of the previous tin with lead) as a > > termination finish is a significant risk of the growth of tin > whiskers. > >
> > Without getting too technical, tin whiskers pose the possibility of > > equipment failure due to short circuits. Those short circuits can > cause > > failures of any equipment - exempt and non-exempt. Ironically, the > > result of each failure is typically increased WEEE. So an unintended > > consequence of RoHS is more WEEE. > >
> > While it is difficult to prove that any given failure is actually due > to > > a tin whisker (they are very difficult to see), tin whiskers are > > believed to have caused many equipment failures, including the failure > > of several communications satellites, with losses of those alone > running > > into the billions of euros. Of course, those failures did not result > in > > WEEE going into landfills, but did result in the expenditure of > > resources (including mining and energy use) to replace the failed > > equipment, to say nothing of the loss of opportunity to use those > > resources for other social benefit. Those who are concerned about > > sustainability should recognize the problem. > >
> > Some of those failures were due to errors by designers or the factory. > > However, with increasing numbers of components becoming available with > > no other finish, it is not hard to predict an increase in the number > of > > whisker-caused failures of both non-exempt and exempt EEE. Think of > the > > consequences for automobile computers alone - including yours. > >
> > Those component manufacturers that have decided to adopt lead-free tin > > as the termination finish have had attendant expenses. They have had > to > > conduct expensive research (non-recurring) to find ways to minimize > the > > whisker risk, and they are now required to engage in time-consuming > and > > expensive (recurring) process monitoring. > >
> > Just last week I attended a two-day international symposium on the > > subject of tin whiskers. Attendance was capped at 150 attendees. The > > first day was devoted to discussing research aimed at understanding > tin > > whiskers; the second on research on how to protect equipment from > > whisker-caused failures and to how recover (remediate) when whiskers > are > > found. Had the RoHS directive not prohibited the use of lead in > > electronics this entire area of research would not have been > necessary. > >
> > Not long ago, the EU TAC issued an exemption allowing the use of lead > in > > the finish of components that had a very small distance between > > terminations. Lamentably, this was a case of too little, too late. Tin > > whiskers can get very long. While not common, cases have been found > with > > a length approaching two centimeters. I published a paper five years > ago > > on a spectacular failure of an electronic component used in a military > > system. It failed after over a decade in the field due to whiskers > that > > grew inside. A similar unfailed component when opened had hundreds of > > whiskers longer than one centimeter. > >
> > Besides, by the time that the permission to use lead was issued, > > component manufacturers had already switched to lead-free tin. It > isn't > > practical for them to apply tin to some component terminations and > > tin-lead to others. > >
> > The result is that many of the components we buy will be available > with > > only lead-free tin as a finish. My company pays component engineers to > > review each such case to assess the risk to our hardware, which I > remind > > you, is used for military purposes and is expected to operate for > > decades without failure. Each such review is expensive. For equipment > > destined to operate in space, the use of tin without lead is strictly > > prohibited. > >
> > In each case where the determination is that we cannot take the risk, > we > > are faced with the prospect of redesigning the equipment to get by > > without it (often not possible without serious performance > consequences) > > or getting the terminations dipped in ordinary tin-lead solder (all > the > > way to the body, with attendant risk of damage due to asymmetric > > heating). The US Navy recently spent a million dollars on a project to > > assess the risk of heat damage to tin-plated components that had to be > > solder dipped to render them usable by some of its programs. One > company > > has developed a business of replacing the lead-free tin plating on a > > certain type of component with tin-lead plating by a proprietary > > process. It should be obvious that had it not been for RoHS, these > > activities would be unneeded. The costs and risks of handling delicate > > components alone are significant, but for those applications where the > > components are needed to achieve performance requirements, there is no > > alternative. > >
> > Our risk of field failures due to the RoHS directive is greater than > > what I have discussed so far. In addition to building EEE we buy many > > electronic subassemblies. Where those subassemblies are commercial > > off-the-shelf, we have no control over what components get used or how > > rigorous a risk analysis has been conducted before a component is > > selected. The manufacturer can change the components used at any time > > without even notifying us. > >
> > In conclusion, I understand that your questionnaires are intended to > be > > used to supply data for a cost-benefit analysis. Regrettably, the > > benefit part of that analysis was not done before the RoHS directive > was > > enacted. I have read the preamble carefully, and while I see vague > > allusions to benefits, I can find no claim that can be verified with > > publicly available data. Instead of documenting actual cases of > > poisoning by lead (and the other prohibited substances) that have > > occurred due to use in electronics, the directive's authors seem > simply > > to have assumed that their use poses risks to public health. The > > precautionary principle puts the burden of proof on those who seek a > > change from prevailing practices. In this case, burden falls on the > > people who have asserted that substances must be prohibited. They have > > failed to provide even rudimentary proof. Of course, if the proof > > doesn't exist because the assertions are false, that is > understandable. > >
> > For what it is worth, my training is in chemistry, and starting in > 1999 > > I have conducted extensive investigations into whether the risk is > real > > or imagined. There's no question in my mind that it's the latter. In > > fact, you will have a hard time finding any scientist or engineer who > > has been involved in helping the industry adapt to the directive who > > believes that the risk is real. They do what they are told to do > because > > their employers are told what they have to do, but their heart is not > in > > it. That aspect may not emerge from your questionnaire explicitly, but > > if you look for it in the responses, you may detect expressions of an > > underlying hostility toward those responsible for enacting RoHS. Those > > scientists and engineers have job security, to be sure, but most would > > have preferred to be engaged in an activity with some redeeming social > > value. > >
> > Despite a rigorous search I have been able to find not a single case > of > > poisoning attributed to use of any of the prohibited substances in > > electronics. Did you know that blood lead levels have been dropping > for > > decades since lead was removed from gasoline and paint? Did you know > > that the major sources of cadmium in people are food and cigarettes? > Or > > that the major source of mercury in people is the burning of coal for > > power? So if you find that the costs are real and the risks are not, > the > > analysis you publish should make it clear (if your client will allow > you > > to tell the truth) that RoHS has been not a boon to society but a > > burden. > >
> > Before I would be willing to recommend the use a sharp pencil to > > document the cost impact of the RoHS directive on our company in > > completing your questionnaire, I would want some assurance that > someone > > was conducting a parallel and sincere effort to, for the first time, > > document the actual environmental and health consequences of the use > of > > the prohibited substances in electronic equipment. Actually, if that > > effort were made, and the results showed that there is no credible > harm > > from the use of the prohibited substances in EEE, there would be > little > > need for people to spend time completing your questionnaire to > document > > the costs. Without effort those costs can be seen to run into the > > billions. > >
> > I'm sorry to be so pessimistic, but the European Commission up till > now > > has been hostile to any consideration of cost, presumably because it > has > > taken it as an article of faith that the risks are so great as to > render > > such considerations irrelevant. Now at long last it appears that some > > VIP has had a change of heart and that cost is a permissible topic of > > discussion. But given the past attitudes and behavior, I respectfully > > request that you, or your client, provide our industry some sort of > > good-faith evidence that the time and effort spent in completing your > > rather extensive questionnaire will have a reasonable prospect of a > > payoff - that is, of meaningful relief. Since the biggest cost of RoHS > > compliance is compliance verification, any proposed relief that does > not > > address this burden will be regarded as of secondary benefit to the > > industry. > >
> > Sincerely, > >
> > Gordon Davy, Ph.D. > >
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