[tinwhiskers] Re: Revisiting the Toxic Substances Control Act of 1976: H.R. 2420

  • From: "Gordon Davy" <gordondavy@xxxxxxxxxxx>
  • To: <tinwhiskers@xxxxxxxxxxxxx>
  • Date: Mon, 8 Jun 2009 12:00:15 -0700

Bob White states "the Pb free issue is not so much one of the environmental 
effect directly, so much as it is to be able to safely recycle products." It's 
understandable that he would say that, because that's what the preamble to the 
RoHS directive says. But the claim, though plausible, doesn't hold up to 
scrutiny. The waste electrical and electronic equipment going to recyclers 
today (and for the foreseeable future) contains Pb, and to some extent the 
other prohibited metals, so it is only prudent for recyclers to assume they are 
present. (The prohibited brominated flame retardants probably are not present 
because they were long ago taken off the market.)

But so what? No one has ever shown that the safety precautions used by workers 
at recycling facilities are burdensome or that they would be any less so if 
those substances weren't present. In fact, studies conducted by environmental 
activist organizations of unregulated recycling in third-world countries found 
people making a royal mess of their immediate environment from their unwise 
practices, but remarkably didn't find people getting sick or dying as a result.

Incidentally, the real (original) reason for the prohibitions, though 
plausible, also doesn't stand up to scrutiny - a belief that the prohibited 
substances would get into the public water supply by being leached from waste 
in landfills, or would go up the smokestack of incinerators. The prohibited 
metals don't leach in landfills, and while it is true that an improperly 
operated incinerator can spew forth noxious substances, that is so whether or 
not it contains electrical and electronic waste. 

Sad to say, the electronics industry has had to spend tens of billions of 
dollars, euros, etc. to substitute practices to solve what is claimed - but has 
never been shown - to be a problem. There are no cases of poisoning 
attributable to lack of the RoHS directive. The problems - including the tin 
whiskers that prompted the creation of this forum - have come from the 
substitute practices.

Greenpeace, the environmental activist organization responsible for RoHS, and 
hence for causing the wasted money and the problems, is not strong on 
conducting environmental impact analyses - only on making their adversaries 
conduct them. For Greenpeace, doctrine preempts science. Generating plausible 
(as opposed to factual) new claims is important to environmental activist 
organizations. Claims are what they use to frighten donors into keeping the 
cash flowing in. By posing as diligent representatives of the best interests of 
the public, these organizations manage to get away with making all kinds of 
unsubstantiated claims because no one challenges them.

The press gives environmental activists a free ride, and legislators don't want 
to look "un-green" so they go along. "Greedy industrialists" don't oppose them, 
wary of having their counter-claims dismissed as self-serving, and worse, 
fearful of being labeled "anti-environment" and having demonstrations outside 
the corporate offices or in front of the CEO's house. The result is legislation 
drafted from greed (the activists' not the industrialists') and enacted by 
superstition and intimidation.

Gordon Davy

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