Exemption request 15 under stakeholder consultation round 6 has been running for 1 month and 12 days and I just had an interesting though which is:
On my original support for stakeholder consultations under round 5, the consultants dismissed the evidence supplied in support of using lead in solders since, as they said in their report:
“review of basic assumptions behind the ban of lead in the RoHS Directive would be an evaluation of the RoHS Directive and the political decision behind it, which is beyond the consultant’s tasks and possibilities within this consultation process. The consultants therefore refrain from commenting these studies and findings and did not take into account this stakeholder document during the evaluation of the respective exemption requests.”
So since we are now in round 6 application 15 with a full on exemption request for a lead in solders exemption for electronics use, one wonders whether the consultants frame of reference has been changed to consider environmental impacts as well as technical ones – or whether in fact we may end up with a copy paste of this section which would be very sad:
This is the text out of the 29 July ’06 OKO Institute round 5 exemption request final report:
5.2.2 John Burke Stakeholder Document
The same applies to the other document, which the stakeholder had submitted (EC_check_list.pdf) citing several studies and arguments as evidence that lead in electronics in general or from electronics solders in particular on landfills do not cause groundwater pollution or any other adverse environmental or health effects. He cites several studies and findings, which should prove that there is no toxic risk from lead on landfill sites. The stakeholder therefore demands that the use of lead in solders should be generally exempted from the ban of lead in the RoHS Directive.
Again, the review of basic assumptions behind the ban of lead in the RoHS Directive would be an evaluation of the RoHS Directive and the political decision behind it, which is beyond the consultant’s tasks and possibilities within this consultation process. The consultants therefore refrain from commenting these studies and findings and did not take into account this stakeholder document during the evaluation of the respective exemption requests.
I guess we shall see, check back often.
John
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