I can't answer the question but I can offer the following insight which might be of some use.
I attended a meeting hosted by DEFRA, the UK government department charged with implementing WEEE, RoHS and the other environmental directives, in December last year. The purpose of the meeting was to present a report on progress with the development of new WEEE and RoHS Directives. By far the most useful speaker at the meeting was Steve Andrews (who does not actually work for DEFRA but works for BIS, which deals with the non-environmental harmonisation directives, but I digress). Among many other things which Steve mentioned was the subject of the agreed exceptions. As those who are familiar with the directive will be aware, exceptions to the ban on the use of the 6 substances listed in the Directive can be agreed by the Commission where a case is made by industry that there is no possible alternative. I believe there are now something like 40 of these exceptions. Steve said two interesting things - firstly that manufacturers should not take it for granted that the exceptions will be carried forward to the new Directive without being reviewed and that it may be necessary for industry to make the case that the exceptions continue to be required. The second point Steve made was that one of the proposals for the new Directive is to include an economic test as part of the criteria for deciding on whether an exception is to be permitted. The current RoHS Directive makes no such allowance - if there is an alternative to the use of one of the banned substances then an exception cannot be granted no matter what the economic effect of the ban is. The proposal is that the new Directive should include an economic test which permits an exclusion even if there is an alternative to the use of a banned substance where the alternative would be prohibitively expensive. The reason I bring this up in the context of this discussion is because the example which Steve used in his discussion was the use of lead in shielding against ionising radiation. There are alternative to the use of lead and so under the current Directive there can be no exception for this application, despite the fact that the alternatives are very much more expensive (ISTR that depleted uranium was one alternative mentioned). Under the new proposal, an exclusion would potentially be permitted because there is no economically viable alternative in this case. Some might call me cynical, but I suspect that the fact that a ban on the use of lead for X-ray shielding has a significant impact on the cost of certain machinery which in Europe is frequently funded from the public purse is not going to be lost on the legislators. I have a copy of the Powerpoint file from the meeting and would be happy to forward it to anyone who would care to contact me, although frankly it contains only a small percentage of the useful information - the stuff which was presented verbally and in response to questions >from the floor was much the more useful part. Nick. At 15:35 -0700 3/6/10, Pete Perkins wrote: >Speak, O Oracle, and enlighten us with your wisdom, > > Lead based shielding has normally used to contain x-radiation. > > Under RoHS is there an exemption for the use of lead based shielding >for industrial applications? If not, what substitutions are acceptable? > > Thanx in advance for your response. > >br, Pete - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
