Lead Free Environmental Counter Argument

Whilst RoHS has been controversial, RoHS-International supports the intent of RoHS and the ban of the 6 substances and elements. However, since 2004 we have been campaigning, through the correct and official channels, for an exemption for lead in solder. Under our previous name of RM Sommer Consulting Ltd we made the first submission for exemption for eutectic tin/lead solder in the second round of exemptions. This was overturned by the TAC and never made it to public consultation. We continue to make submissions on this issue.

Early in my investigations into RoHS I came upon the environmental counter argument to lead free solder. The argument is two fold. Firstly the argument that lead is, in most applications a benign substance, and secondly that the inclusion of silver as well as the higher levels of tin in the lead free alternatives made lead free less environmentally friendly than eutectic Sn63Pb37 solder when assessed with a full life cycle analysis.

This argument was the subject of the 472 page report (3.53 MB) from the American Environmental Protection Agency (EPA) released in 2005. The report is very wordy and technical but the layman's summary lays in the footnote on page 131 "The difference between SAC and SnPb is 453 kg of NRR per 1,000 cc of solder applied. If this were all automotive gasoline, this difference is equivalent to 162 gallons of gasoline. Assuming a driver consumes 20gallons per week, this is also equivalent to approximately 8 weeks of driving."
Note NRR is Non Renewable Resource usage.

There is no denying that lead is toxic, however for it to be dangerous it needs to get into the body. The availability of any substance to get into the body is called its "bio-availability" and this changes with different forms and uses of the substances. Taking lead based paint as an example, when it is on the wall and touched with fingers - if it is in good condition then none will come off. However if you take a piece of sandpaper and sand the paint and then either breath the dust in or touch the dust and then lick your fingers, the lead will get into your body. Bio-availability is an easy concept but fundamental to understanding the truth about lead and lead poisoning.

There are three well documented applications of lead where poisoning or elevated levels of lead in bloodstreams has regularly occurred due to non occupational exposure (ie the people effected were not working with lead as an occupation). These are:

Lead in water pipes was highlighted as an issue in the 1960s and many houses were converted to alternative pipework in Europe. However the pipes in the ground were still lead in many cases as much documentation was lost in the second world war and the routes that the pipes followed were largely unknown. However much effort was put into studing the ability of lead to leach into water - known as plumbosolvency. The result was neutral ph or alkaline water did not leach at all and acidic water leached only slightly. Lime was added to water where it was known that lead pipes were in use to reduce the ph of the water. There were a number of studies done in Edinburgh on this.

Surely these two applications alone would pose far more of an issue than the amount of lead in solder joints - which if disposed of in a landfill is contained. It is noted that lead balancing weights are now banned in the EU under the ELV Directive.

Leading on from this is the Palo Alto study where a landfill leachate was analysed for lead. The landfill had its' fair share of electronics and even though the article concentrates on CRTs (Cathode Ray Tubes) television sets have the full range of electronics so this study is representative.Is this Ban Really Necessary?

Another telling study is with the Smuggler Superfund site in Aspen Colorado. Condominiums were built on an old tailings site from the Smuggler lead mine. The Environmental Protection Agency wanted to perform a major retrospective clean up which was oposed by the residents as they felt that there was not a real problem. The upshot was that external consultants were called in to perform a study including monitoring the blood lead levels of the children in the area. The results showed that the children did not have elevated blood lead levels. This link will take you to an overview from one of the consultants The Smuggle Mountain Techical Advisory Committee and this link will take you to the 5 year review report. Five year Review Report Page 6 paragraph 3 gives the main summary.

Rather than regurgitate a lot of other peoples work - now that I have said my piece I will present the rest of the argument by grouping and overviewing the articles that I have come across on my research so far.

Niels Warburgs presentation on the LCA on lead and lead free solder from the University of Stuttgart. Note that Niels explicitely states that he has not included the disposal part of the Life Cycle Analysis and this may have an overall bearing on the results.

Environmental impacts and toxicity of lead-free Solders by Edwin B Smith. I have been unable to contact Edwin B Smith as it would have been interesting to see what the comparitive results would have been for standard eutectic tin/lead solder.

Use of Lead in Electronics - from the IPC website - Author unknown. General article detailing the amount of use of lead in electronics. http://leadfree.ipc.org/files/LF_3-1.pdf

The University of California has published several well researched articles on lead-free. The focus is mainly on highlighting and managing the uncertainty inherrent in the precautionary principle. Their call (very sensible) is to perform studies such a a full lifecycle assessement on the substance in question as well as all the alternatives before a decision is made.

IPC lead free website - excellent resources and the only other website that I know that has any material on the environmental issues with Lead-Free solder
http://leadfree.ipc.org/

I found out in September 2004 that despite all the concern, no one had made a formal submission to the EU for an exemption for eutectic Sn63/Pb37 solder under Article 5(1)(b). As a result RM Sommer Consulting Ltd (previous company name for RoHS-International Ltd ) filed for an exemption under environmental grounds in October 04. Follow this link for a copy. The submission was unminuted in the unofficial TAC minutes but was minuted in the official minutes of the meeting 10 December 2004. The TAC overturned it with the comment "entry 19: as this is normal solder it should not be studied:" This is the only official record of the submission ever being made. I decided not to pursue further action as being a small company we needed to concentrate on creating revenue rather than altruistic endeavours.

In more recent times the challenge has been taken up by Mr John Burke who created a website called Pushback USA dedicated to overturning the ban on lead in solders. This websire can be found at www.rohsusa.com. John has been very active in petitioning the TAC and the EC andf has suceeded in getting his submission against the ban on lead in solders through to the stage of public consultation. There has been great support for this. As of 20 December 2006 there are 187 support submissions to the EU for John, including one from RoHS-International.

We continue to support the lobbying of the EU against the ban of lead in solders but as a professional company remain focused on the needs of our clients to meet the law.

After now working in RoHS and WEEE for over 2 years I am aware of the power of public opinion and public perception. I can see how difficult it would be to have any credibility to a RoHS legislation without the inclusion of the ban on lead (Pb). If lead (Pb) was excluded every well meaning "Green" group would be lobbying for it's inclusion and we would have the same situation in reverse. Also the electronics industry did have a number of years to provide input into this legislation but due to the general short term focus (inherrent in any commercial industry) RoHS was not on the radar screens of most companies 5 years ago when the main consultation was taking place. I would guess that most input was from the environmental quarter.

Regarding the TAC, the members that I have met are all very nice, very sincere people trying to do their best within the same constraints of time and money as most "normal" people. They are not technical or industry experts. Most appear to have full time jobs prior to being given responsibility on the TAC so they have to squeeze the work in around an already busy schedule. As you will see from the Photo Gallery page on this website, some of them are young, vibrant and dynamic.

Any issue we have is not with the TAC, RoHS was done and dusted before they became part of this, it is with the advisors that the EU had in the initial stages and with the Environmental Lobby Faction who need to become better informed, more moderate and take a more holistic view otherwise they are likely to cause more damage to this planet than they prevent.

My overriding concern with environmental policy such as RoHS which is based on the precautionary principle is that even though the intentions are generally good the science is lacking. This can result in huge sums of money being spent in areas that have very little true positive environmental impact and at worst a negative environmental impact - a classic "home goal". As an example, converting to lead-free is costing 2 Billion Pounds for the UK alone (http://www.dti.gov.uk/sustainability/weee/RoHSRIA_July_2004.pdf) page 13. The same document on page 3, section 12 (lead) admits that the benefits of banning lead may be "somewhat limited". What is the cost world wide and how does that compare with the environmental impact if the funds were used to subsidise wind power or other environmentally friendly renewable energy sources?