June 25, 2009

Environmental Design of Electrical Equipment Act and Mercury in Your Mouth

Although most of US electronic industry has converted to a ROHS-compliant manufacturing, up until now there was no a legal requirement in US to meet ROHS regulations except for the state of California. The electronic manufacturers switched to ROHS-compliant products primarily in order to sell them to Europe, Japan, and some other countries, and because many customers were requesting ROHS compliance. However, when a product is not shipped to the geographical areas where ROHS or similar regulations are enforced by a law, and the compliance is not requested by a customer, it is basically up to the manufacturer to choose the components and the soldering technology.

Now there is a possibility a ROHS compliance would soon become a federal law. A legislation have been recently introduced in the U.S. House of Representatives that imposes restrictions on the use of lead, mercury and other materials in many types of electrical products and equipment.
The proposed legislation, designated H.R. 2420 and referred to as Environmental Design of Electrical Equipment Act (EDEE), would amend the federal Toxic Substances Control Act (TSCA) to provide national regulatory standards for the use of some potentially hazardous substances. According to the bill, ‘electroindustry products’ manufactured after July 1, 2010 must not contain lead, mercury, hexavalent chromium, polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs) and cadmium in the concentration levels that are consistent with EU's RoHS Directive.

The bill particularly states: "It is the purpose of this Act to enhance the economic, environmental, and social well-being of the people of the United States in the global marketplace".

Well, I wonder how for example mandating a lead-free solder technology that is known to have potential long-term reliability issues, whose implementation requires extra spending, and which is not driven by free market forces, would enhance our economic well-being?

I also wonder, how come for example mercury is not OK in electronics, but OK in your mouth? It is interesting that currently in the US and in most European countries there is no restriction on the use of dental mercury amalgam fillings. So far only Sweden, Denmark and Norway ban mercury use in dental fillings, while all members of EU restrict its use in electronics devices. Of course, mercury, lead and other toxic substances in electronic devices present a health threat only if you have a habit of chewing printed circuit boards. Contrary to this, mercury in your mouth presents a much more probable health issue. According to some studies, amalgam fillings leach mercury into the mouth and mercury vapor can be inhaled during the fillings removal, although FDA disputes the effects of this exposure.

The state of California is a bit more consistent with the toxic substances issue. It at least mandates the following notice: "Notice to Patients, Proposition 65: Warning on dental amalgams, used in many dental fillings, causes exposure to mercury, a chemical known to the state of California to cause birth defects or other reproductive harm. Root canal treatments and restorations including fillings, crowns and bridges, use chemicals known to the state of California to cause cancer. The U.S. Food and Drug Administration has studied the situation and approved for use all dental restorative materials. Consult your dentist to determine which materials are appropriate for your treatment. "

However, currently neither CA, or federal laws restrict mercury use in dental fillings. Apparently, for our lawmakers mercury is hazardous only in landfills but not in your mouth.


Linda Brocato said...

I totally agree with you. What is mercury doing in our mouth since a cross and skull bones with the word poison is affixed to the amalgam label when it reaches the dentists office...and how many people read the MSDS (Materials Data Safety Sheet) Copyright 1997 DENTSPLY INTERNATIONAL (World’s largest amalgam manufacturer)Dispersalloy®
Food for thought!

Linda Brocato

danielaqwe said...

I am a EE as well as a craftsman.
I remove a 240pin chip from a PCB and put it back ten times in a row and you will not even notice that someone did solder on the board.
Unfortunately I have some problem with ROHS. The new solder alloy sucks. There is nothing better than 63Zn/37Pb eutectic solder for electronics. An I use RNA flux too, which must be removed. We do not need a new solder alloy (unless its better than the old one), we simply need a proper recycling infra-structure. Every outlet who sells "things" with lead solder should be forced by law to accect "things" containing lead-solder for recycling. What is difficult about it... nothing would end up on the landfill