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Calls to Throw Out RoHS Unnecessary
May 15, 2006 |Estimated reading time: 4 minutes
by Ray Franklinwww.RoHSwell.com
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The RoHS directive is the first of many small steps along a path. The path leads to a healthier world for all by eliminating environmental hazards. Along one side of the path are cheerleaders urging the walkers forward. On the other side are nay-sayers urging the walkers to veer off onto a different path.
Fundamentally, the RoHS directive is based on toxicological evidence of harm caused by the six banned substances. The biological hazards of heavy metals are well documented, and the trend for the last 50 years has been the elimination of these metals from a wide variety of applications.
In the same vein, RoHS bans two particularly nasty brominated hydrocarbons. We have come to understand that many halogenated hydrocarbons are toxic and carcinogenic. Our application of this class of compounds has turned them into persistent organic pollutants (POPs). We are slowly recognizing the numerous biological impacts of POPs, which include sexual development abnormalities, diabetes and obesity.
Despite the large, and growing, body of evidence in support of the RoHS substance bans, there have been numerous protests against the legislation. Two of those protests have recently captured attention: the RoHS Pushback Initiative and A Lead Free Essay by Gordon Davy.
Having read through the blogs and comments on the Pushback Initiative site, I get the impression that the group wants to see the RoHS directive repealed entirely. I am not absolutely certain of this because the site does not clearly state what actions supporters should take. However, it does appear to be a political effort to derail RoHS. The core complaint seems to be with the elimination of lead (Pb) in solder.
In the same timeframe as the Pushback Initiative, a long article against RoHS was published on the PCB007 site. The author claims definitive scientific evidence of no harm from the burning of plastics and no leaching of lead from solder. This is completely contrary to my understanding.
Burning chlorinated plastics (such as PVC and Teflon) produces dioxins and furans. Even well controlled incinerators release these chemicals. Both are known carcinogens and teratogens. Furthermore, recycling plastic makes more sense. There is also a process in production that can turn plastics into oil, with no pollution. Burning is no longer a reasonable way to dispose of plastic.
Davy claims that lead in solder will not leach into ground water from landfills. Has basic chemistry suddenly changed? What of lead in crystal? Long ago it was proven to be a neurotoxin to those who store wine in crystal decanters. And what of lead gutters and roof flashing used so widely in <?xml:namespace prefix = st1 ns = "urn:schemas-microsoft-com:office:smarttags" />Europe? Lead in contact with water will leach into the water. If the water is acidified (rain, wine, citrus juice) the lead will leach faster. Rain falling through pristine air reaches the ground as carbonic acid due to the CO2 in air. On much of the planet, acid rain (lower pH) falls from the sky due to nitrate and sulfate pollutants in the air.
I have a hard time believing that rainfall through WEEE in a landfill results in zero lead contamination. If there is scientific evidence to support this assertion, it needs to be prominently displayed. Before taking action, the claims must be scientifically reproduced by multiple research teams. That is the scientific method.
I cannot support these protests because the tactics seem to be mostly destructive rather than constructive. It would be much more effective and helpful to alter the message slightly. Keep RoHS, and exempt Sn-Pb solder in electronics. Expand the scope to eliminate Pb in roofing materials, glassware and plumbing fixtures.
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. Rigorous scientific proof of the benign nature of WEEE in landfills will be required. In such a case, the correct action would be to write the following exemption into the RoHS Annex: "Lead in solder used in any electrical or electronic device."
No need to throw out the entire directive. Just use the built in tools for "adaptation to scientific and technical progress."
The exemption and consultation processes are good ones. The RoHS directive is just one step in the right direction. Does it need improvements? Undoubtedly. When has any human effort ever been perfect the first time? I say stay the course, use the processes, and make the RoHS directive into better legislation, one step at a time.
Additional Resources
Irresistible Force Meets Immovable Object - A Lead Free Essay by Gordon Davy.
Diabetes From Plastic Reported by Science News 21 January 2006: Bisphenol-A in polycarbonate is estrogenic when consumed. The compound has now been shown to cause insulin resistance, a precursor to diabetes. The chemical is widely used in dental sealants, microwavable plastics and numerous other products. The study was reported in the January Environmental Health Perspectives.
Obesity and Flame Retardants Reported by Science News 15 April 2006: Brominated flame retardants are known to cause neurological and developmental abnormalities. Now they have been shown to cause fat cell changes that raise the risk of obesity and type 2 diabetes. PBDE, of a mix dominated by penta molecules, caused increased fat circulation in rats after four weeks. Increased fat circulation is strongly associated with obesity.
Thermal depolymerization Changing World Technologies is developing production plants to convert any carbon-based waste into oil. The conversion process is 85% efficient, burning 15% of the product to run the process. Feedstocks include agricultural and food processing waste, sewage sludge, tires and mixed plastics. The first plant is currently converting turkey-processing waste into oil in Carthage, MO. This process is the ultimate recycling tool.