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[GreenYes] Re: REACH in the EU passes!

Hi Eric,

Thanks for highlighting the REACH law in Europe for GreenYES.

I'd offer a note of caution. Applauding or denouncing products based
on the toxics they contain is a simple process with potentially
perverse outcomes, and environmentalists in this century need to look
at product lifecycles, not end-of-life contents. Most mercury in the
USA comes from gold, silver, and copper mining, not from the
smokestacks and recycling bins we are accustomed to regulating. None
of those is a toxic material, but gold and silver are primarily used
for vanity products (under 40% of those metals goes to engineering

REACH is not a bad thing, but it is derivative from "end of pipe"
regulation (even though it is being hailed as an alternative). It
begins with a toxic substance in a landfill or obsoletes bin, and
assumes that reducing that material will be better for the environment.
As I've said before, baby seal pelts are non-toxic, organic, and
reusable. Gold in a circuit board yields more mercury than the mercury
in a circuit board.

For 2007, I'd prefer a simple ban (Iike rhino horn, ivory, whale
hunting, and lead gasoline) to a new government agency which says gold
is good and lead is bad. Take a known product which is easily
replaced, immune to panic in a supply disruption, and which has an
effect we've studied from cradle to grave. Replacing all 18k gold with
14k gold (or better, 9k) would have a more profound effect on the
environment than ROHS (lead free solder) legislation.

Robin Ingenthron

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