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Threat From Eu Rohs Legislation


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I am quite prepared to do my bit, but first I want to know a lot more.

 

Let's start with the directives. What do they say?

 

WEEE Directive

Its purpose is the prevention of waste electrical and electronic equipment and the reuse/recycling/recovery of such wastes. It also seeks to improve the environmental performance of producers, distributors, consumers and operators involved in their treatment. [Article 1]

 

Electrical and electronic equipment means equipment which is dependent on electrical currents or electro-magnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields. [Article 3(a)] Musical instruments are listed under "consumer products" at Annex 1B.

 

Member States should encourage the design and production of electrical and electronic equipment in a way that facilitates the dismantling, recovery, reuse and recycling of WEEE, their components and materials. [Article 4]

 

RoHS Directive

This restricts the use of hazardous substances, including lead, in electrical and electronic equipment (which is defined as in the WEEE Directive),

 

From 1 July 2006 new electrical and electronic equipment must not contain lead (and some other things).

 

For the purpose of scientific research and technical progress there is provision to establish minimum concentrations of the hazardous substances, and exemptions for materials and components if their elimination or substitution is technically or scientifically impractical.

 

The Annex to the directive exempts several things from the restrictions, including lead in some solders (but I am not in any way a technical chap so have no idea how relevant this is)

 

I see nothing here that spells the death of organ pipes, or even necessarily the death of electic actions. So:

 

1) What did that email say and who originated it?

 

2) What have the DTI and EC said so far on the subject of pipe organs?

 

3) Who is behind http://www.pipes4organs.org/? It looks very snazzy, but why is it anonymous? If I'm being asked to sign a petition, I want to know who I am signing it for.

 

4) How do we know that the whole thing isn't a ruse to marshall the support of pipe organ enthusiasts in order to protect the European interests of electronic organ manufacturers. If that sounds far-fetched, read this letter on the EC's website.

 

I'm not saying my understanding is complete, or even necessarily accurate, but nor am I going to start running round like a headless chicken without some hard facts. So let's have some.

 

I would normally take exactly this line and give the proximity of April the 1st I would have assumed this was another "Italian Spaghetti Harvest" story. However the second post on this thread is from Mr Mander and Dr Wyld has also contributed. Of course, there could be an arrangement for a monumental practical joke BUT it does not seem very likely. The massive loss of good will that would ensue from making a number of people who were trying to help you look like a prat, and the virtually impossibility for the forseable future thereafter of ever mobilising support from these people again - once bitten twice shy - would surely lead intelligent people in the positions they occupy to realise that such a joke would be very likely to be be highly counter-productive, and possibly result in financial consequences reflected in their respective firms' accounts long after the laughter had faded away.

 

BAC

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Anyone could put an IBO link on their webpage, Pierre.

I believe the site has been created by Doug Levey, of the IBO, and that this is an IBO led initiative.

 

I notice that hand blown, entirely mechanical action organs are exempt. So perhaps we'll have to go to completely mechnical, hand-blown organs in the future.

 

Our organ is to be installed later this year - probably over 1st July. While it is mechanical key and stop action, the simple fact it has an electric blower means it will be illegal to install it. This has been a 4 year project for me, we've spent 2 years raising the £250,000 for it, it's involved massive commitment from the local community, all for this issue to appear 4 months before installation.

 

Had we known, I'd have asked for feeder bellows to be added to the double rise reservoir... it did come up in passing but we didn't consider it too seriously.

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Our organ is to be installed later this year - probably over 1st July. While it is mechanical key and stop action, the simple fact it has an electric blower means it will be illegal to install it.
It's not that bad. As Brian pointed out on the other thread, although the directives become effective on 1 July, they need legislation in the UK parliament before the provisions can become law here. I rather think that legislation may be some time coming; I am sure the government has more important things to worry about at the moment.
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It's not that bad. As Brian pointed out on the other thread, although the directives become effective on 1 July, they need legislation in the UK parliament before the provisions can become law here. I rather think that legislation may be some time coming; I am sure the government has more important things to worry about at the moment.

 

Doug Levey has stated that:

 

"in the UK the RoHS Directive was transposed into law

on the 7th October 2005"

 

David Wyld.

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Doug Levey has stated that:

 

"in the UK the RoHS Directive was transposed into law

on the 7th October 2005"

 

David Wyld.

 

Thank you for that date. That made it fairly painless to track down the Restriction of Hazardous substances Regulations. They can be read here

 

http://www.opsi.gov.uk/si/si2005/20052748.htmFortunately , to spare me from looking completely daft, I did mention in a previous post that there was an EU fast track: these came down it. They do come into effect on 1 July 2005.

 

It seems likely that the other regulations will arrive a little more slowly since they seem to be a delegated matter to be dealt with at the level of the Regional Assemblies for Scotland , Wales and Northern Ireland

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Thank you for that date. That made it fairly painless to track down the Restriction of Hazardous substances Regulations. They can be read here

 

http://www.opsi.gov.uk/si/si2005/20052748.htmFortunately , to spare me from looking completely daft, I did mention in a previous post that there was an EU fast track:  these came down it.

In that case, things are as bad as feared.
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Hi everybody,

 

I have now found the regulations which are causing the anxiety and read through them. I am now a good deal less concerned than I was before, although there would be no harm in getting specific clarification made in the legislation ; something that might be more easily done with these regulations because it is less hassle to alter delegated legislation than primary legislation since the former does not require parliamentary time (always in short supply) to alter it, whereas primary legislation does.

 

Anyway here is the the main provision

 

Electrical and electronic equipment to which these Regulations apply

3. These Regulations apply to electrical and electronic equipment that is within the categories set out in Schedule 1 and to electric light bulbs and to luminaires for use in households.

 

You will see that the regulations apply to the categories of equipment listed in Schedule 1. What does schedule 1 say ?

 

 

 

 

SCHEDULE 1

Regulation 3

 

 

 

Categories of electrical and electronic equipment

 

 

1. Large household appliances.

 

2. Small household appliances.

 

3. IT and telecommunication equipment.

 

4. Consumer equipment.

 

5. Lighting equipment.

 

6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools).

 

7. Toys, leisure and sports equipment.

 

8. Automatic dispensers.

 

 

There is a perfectly plausible (though not guaranteed to succeed )argument that a large pipe organ is not included on this list at all, since it does not fit into any of the categories. If that were to be accepted, the regulations do not apply at all and the problem has just gone away. Since I do not think anyone has ever suggested that it was intended to apply the regulations to the pipe organ such an iterpretation has the obvious attraction of making the problem go away with the least possible effort on the part of everybody. HOWEVER

 

It could be argued that organs were "leisure" equipment within category 7 or large household appliances within category 1. Neither conclusion seems to me particularly obvious, let alone so compelling that there is no escape from it. It is perfectly possible to scan down the list, and to see it as a list of common household electrical items, and to conclude that the only things which were intended to be included were common household electrical items, so pipe organs are off the hook.

 

To put the matter beyond doubt it would be possible to insert something into schedule 2 which lists the exceptions to the obligation to comply.

 

If all else fails the offence created is only punishable by a fine, so you could always go ahead and add the fine to the final account.

 

BAC

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IOur organ is to be installed later this year - probably over 1st July. While it is mechanical key and stop action, the simple fact it has an electric blower means it will be illegal to install it. This has been a 4 year project for me, we've spent 2 years raising the £250,000 for it, it's involved massive commitment from the local community, all for this issue to appear 4 months before installation.

 

 

Fortunately the regulations only impose obligations on the "producer" (= organ builder) so you would not be committing any offence. Also there does not seem to be any provision in the Regulations to require something that has been installed to be removed , so once you have got it in you can keep it. In any event, as I have indicated in another post , I think you can interpret the regulations as not applying to the pipe organ at all. In fact I would be prepared to argue that the better (but not alas the only possible) interpretation is that they do not apply to the pipe organ, so I would not lose too much sleep yet.

 

BAC

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IOur organ is to be installed later this year - probably over 1st July. While it is mechanical key and stop action, the simple fact it has an electric blower means it will be illegal to install it. This has been a 4 year project for me, we've spent 2 years raising the £250,000 for it, it's involved massive commitment from the local community, all for this issue to appear 4 months before installation.

Fortunately the regulations only impose obligations on the "producer" (= organ builder) so you would not be committing any offence. Also there does not seem to be any provision in the Regulations to require something that has been installed to be removed , so once you have got it in you can keep it. In any event, as I have indicated in another post , I think you can interpret the regulations as not applying to the pipe organ at all. In fact I would be prepared to argue that the better (but not alas the only possible) interpretation is that they do not apply to the pipe organ, so I would not lose too much sleep yet.

 

BAC

 

Hi

 

Lead free solder is already available for electronics use (I have a sample somewhere in the "workshop" - but as I understand it, existing equipment is exempt (and probably will be in the other legislation - there's still plenty of lead water pipe about - including the feed from the street into this building). The lead free solder, I understand, has a slightly higher melting point - which might have implications for use in pipe-making, but that's about all.

 

I've not seen anything other than on this site about a total ban on lead, so I can't comment further on that.

 

Every Blessing

 

Tony

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Guest Lee Blick

I wish this was one huge practical early April Fool joke. I really cant believe that this is happening. Does someone know how to stuff a large 32ft organ pipe with explosives and fire it in the direction of Brussels please. :o

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I wish this was one huge practical early April Fool joke.  I really cant believe that this is happening.  Does someone know how to stuff a large 32ft organ pipe with explosives and fire it in the direction of Brussels please.  :o

 

 

This might be useful:

http://hsgm.free.fr/recent/dca.jpg

Pierre

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It's definitely happening. See the article in today's Times which has quotes from the DTI confirming the situation. Surely, those in the 'business' have to combine and forcefully articulate the argument that pipe organs must be exempt from this legislation - there are powerful arguments why this should be so, but they need to be made. Unfortunately they may not be enough to make the little Hitlers in Europe see sense. I really think the world is going mad.

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There was a short piece in The Times Online about this today and also a brief mention on BBC Radio 4's Today programme this morning. You can hear the excerpt using the LISTEN AGAIN features at www.bbc.co.uk/radio4. You will need to Fast Forward through the 2hr programme until 1hr 44mins to hear it.

 

H

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For anyone who doesn't know what this is about, Click here for the article from "The Times" newspaper.

 

This is absolutely (...) pathetic IMO. These regulations threaten a craft that has been in Europe for more than 2000 years, and probably longer than that. There is no alternative to the alloy that is used for metal pipes (unless they are made from wood, but organs would be boring like that) so stuff the EU legiuslation. This puts the livelihood of more than 800 people here in the UK, plus more across Europe, North America and possibly other parts of the globe.

 

And actually, whilst I think of it, the lead measurements apply to electrical equipment! Does an organ pipe classify as electrical equipment? I think not, so couldn't someone could mount a challenge to this directive on those grounds?

 

STUFF THE E.U!

 

Dave

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With some friends we wrote to our representatives in Belgium (in short):

 

"If the EC acts as a threat to the people, don't be surprised to encounter some problems.

The french and the Dutch refused the european constitution, and you know if there

had been a referendum in Belgium too, the results would have been even worse

for Brussels as in these two countries.

The european idea must not consist in rules that fall from the sky upon our heads as

if they came from nowhere, intended at nothing save to destroy even more crafts,

arts and trades" (etc...)

 

I have had some reactions from french builders after having launched a thread

on the french forum. There is now a page on the Walcker Website too.

Pierre

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For anyone who doesn't know what this is about, Click here for the article from "The Times" newspaper.

 

I think the crux of the article is at the end:

 

"A spokeswoman for the DTI said that the directive did apply to organs and that Britain could not deviate from a “harmonised approach”. She said: “The DTI has been working with the pipe organ industry for some time on this and is fully aware of the issue.”

 

"She said that exemptions from directives could be granted by the EU."

 

So what, exactly, is the DTI doing to persuade the EU to grant organs an exemption? Are they doing anything, or just sitting back on their hunkers and quoting the rule book at everyone? The latter simply won't do. They should be pro-actively negotiating on organ builders' behalfs. I think we should be told.

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Come to think of it, it would be quicker to ask for the details under the Freedom of Information Act.

 

The "harmonised approach" argument really won't wash. I doubt anyone is looking for a "disharmonised approach". What's needed is a harmonised approach that exempts organs!

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I wish this was one huge practical early April Fool joke.  I really cant believe that this is happening.  Does someone know how to stuff a large 32ft organ pipe with explosives and fire it in the direction of Brussels please.  B)

 

 

As a matter of fact I do. You cannot live in Ulster for over 30 years without acquiring some familiarity with things that go bang. However, on this occasion I am not at all sure that all the ire being directed at Brussels is properly targeted, and while it may be true that the Directive applies to pipe organs it does not follow that the Regulations by which it has been implemented in the UK do. It is not unknown for countries to botch their attempts to implement EU Directives, leading in time to enforcement proceedings some years down the road. But consider the facts.

 

The RoHS and WEEE Directives are addressing a problem of waste disposal that hardly existed even 50 years ago but is growing at a fearsome rate. Most people are aware of the problems of the disposal of nuclear waste but there are numerous other nasties generated by our modern life styles, which we cannot solve by dumping ever increasing mountains of waste into holes in the ground. There has already been extensive litigation over who was to pay the costs of dealing with the effects of chemicals called PCBs which were spilt on a concrete tannery floor, seeped through it and down to the chalk aquifer below contaminating the water which it contained, a source from which the local water company extracted part of its supplies. (Cambridge Water v Eastern Counties Leather) Those who live in the South east or any other part of the country where subterranean water is extracted and used to supply households surely have an interest in seeing it is not contaminated.

 

Another [potential source of problems is the discarding of household appliances parts of which are made of, or contain, harmful substances. One can hardly disapprove, surely, of attempts to protect our children and grandchildren from a ticking toxic time bomb ? And given the understandable reluctance of individual governments to act by imposing restrictions on domestic manufacturers which did not apply to those elsewhere and thus placed local business at a competitive disadvantage a Europe wide solution offered the best hope of some action whilst maintaining a level playing field.

 

But how did the organ come to be caught up in all this? I think if you look at the IOB website it becomes farely obvious that the pipe organ has been the victim of guilt by association with what are frequently called on this Board "toasters" and which many here would dearly love to see consigned to a hole in the ground. A moment's reflection serves to show that the average "toaster/pipeless organ" contains a considerable number of the same sort of circuits to be found in PCs and Mobile Phones , which are clearly a concern of the Directive. If there is a desire to restrict computers and phones going to landfill in massive quantities the same argument applies to toasters. Indeed the Allen Company has been in discussion with the Commission about the implications for their products as the IOB site makes clear. So the pipe organ shares a name with the electronic organ and contain some electrical components and some harmful substances- it is not all that surprising that the the view taken was to include it, rather than exclude it.

 

But as we all know the situation with the pipe organ is different and can be shown to be so, unless someone discovers a massive landfill site somewhere full of decaying pipes from redundant organs. Dismissing that as a very unlikely scenario, it ought to be possible to get an exception made. This is after all a heritage issue not just for us but for almost every country in the EU. So I do not see the need to declare war just yet : I think one should give sweet reasonableness a try first.

 

Brian Childs

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I think one should give sweet reasonableness a try first.
Except that there's precious little time and you have to have regard for public sector inertia. The DTI have been aware of this for three years now; they could - and should - have been more imaginative and proactive.
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Except that there's precious little time and you have to have regard for public sector inertia. The DTI have been aware of this for three years now; they could - and should - have been more imaginative and proactive.

 

Probably longer than three years but my reading of the IOB site is that for most of this time they considered that the Directive applied only to the elecrical components and were planning on the basis of that. It seems that it was the application by Allen for clarification that set the cat amongst the pigeons. If the IOB were cruising along under a particular belief, it is hardly surprising that the DTI was.

 

However, the Lords Spiritual, are part of the upper House. Surely at least a couple of them can get a debate going. You get a better quality debate in the Lords because it contains people who have both expertise and long experience, and relatively few party hacks. David Wyld has already started the ball rolling but some additional support and lobbying of contacts would not go amiss. I have some contact with the Ulster peers and I will try to stir something up.

 

Brian

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