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IPC position and lobbying efforts Due in large part to IPC and other industry stakeholders' lobbying efforts that focused on the need for science- based regulations, NGOs were unsuccessful in persuading the EU government to restrict additional substances under the RoHS Directive. IPC and itsmembers strongly believe
and the environment, all halogenated substances are potentially harmful and should be banned in order to prevent unanticipated consequences. This argument is not based on scientific evidence. The simple presence of halogens, a group of elements on the periodic table, hardly serves to indicate the likelihood of similar toxicity. Each substance is different and should be evaluated on an individual basis in order to ensure that safe, reliable substances are not restricted.
Another argument used by NGOs to
support the removal of halogenated materials from electronics is that dioxins and furans can be formed during low- temperature, uncontrolled incineration, which can occur in substandard recycling and open burning in developing countries.
Open burning is never good for the
environment. Open burning of electronics can result in incomplete combustion, which can lead to the formation of a number of hazardous compounds, including dioxins. The formation of dioxins during incomplete combustion has been tied to the presence of halogens in waste materials. While it would be far more efficient to ban open burning than to remove all halogens from electronic materials, the industry is being "encouraged" to address this problem by eliminating halogens from products.
that any lawor regulationmust be supported by sound science. Although specific halogenated flame retardants have been conclusively shown to be dangerous to the environment or human health, this does notmean that all halogenated flame retardants are bad for the environment or human health. In fact, an extensive and thorough risk assessment conducted by the European Commission Scientific Committee on Health and Environmental Risks (SCHER) found that the use of Tetrabromobisphenol A (TBBPA), the most common flame retardant in printed boards, does not pose a danger to human health or the environment.
IPC believes that revisions to
environmental regulations should follow a rigorous scientificmethodology to ensure that they result in genuine benefits to the environment and human health.
In an excerpt froman IPC white paper,
Recasting the RoHS Directive: An Opportunity to Solidify its Scientific Basis in Support of Comprehensive Environmental Regulation (
http://leadfree.ipc.org/files/Recasting- RoHS-Directive-wp.pdf), IPC explains, "Electronicsmanufacturers use specific materials because of their unique energy efficiency, safety or performance characteristics. The decision to prohibit a substance should not be undertaken lightly. Commitment of scarce societal resources should instead be guided by the best available science. … Before additional substance restrictions are included in the RoHS Directive, there should be clear and compelling scientific evidence that potential substitutes are better for the environment and human health."
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