MEMORANDUM BY THE LEAD DEVELOPMENT ASSOCIATION
INTERNATIONAL (DSW 55)
1. INTRODUCTION
1.1 The Lead Development Association International
(LDAI) welcomes the opportunity to submit evidence to the Environment
Sub-committee's inquiry into Delivering Sustainable Waste Management.
1.2 The LDAI is a UK-based trade association
representing the lead producing and consuming industries. In common
with the rest of industry and commerce, our members are producers
of waste, and in some cases special or hazardous waste which must
be disposed of. The lead industry also uses considerable quantities
of secondary raw materials in its recycling plants which produce
new lead products that can be indistinguishable from those products
produced from lead ore.
1.3 The LDAI broadly welcomes the Government's
Waste Strategy and its vision for managing waste and resources
in aiming to deliver sustainable development. We welcome the target
of reducing the quantity of waste produced where possible and
recycling waste when this is not an option.
1.4 We believe the objectives of sustainable
development can be achieved with the careful management of hazardous
wastes. In fact, the lead industry has already taken significant
steps in this direction. Over half of all lead currently produced
in the world comes from scrap, and it is estimated that recycling
rates for key applications already exceed 90 per cent in the UK.
Furthermore, we believe that over 85 per cent of the lead consumed
today is in a form that can be recycled at the end of a product's
life. However, despite the already high levels of lead recycling
currently achieved, the industry remains concerned that waste
policies being developed at European Union level, which will be
implemented in the UK, are not consistent with the objectives
of sustainable development.
1.5 This memorandum is divided into four
sections:
(i) Background on EU Priority Waste Streams
(ii) The Risk Versus Hazard Argument
(iii) Other Environmental Factors
(iv) Summary and Conclusion
Although LDAI acknowledges that our memorandum
deals with a specific part of the Government's Waste Strategy,
we would be happy to provide oral evidence to the Sub-committee
on this issue.
2. BACKGROUND
ON EU PRIORITY
WASTE STREAMS
2.1 The European Commission has identified
a number of priority waste streams for action at EU level. The
development of policies and legislation on three of these waste
streams is at various stages in the EU process, but the UK Government
specifically refers to them in the section on Hazardous Waste
in its Waste Strategy. They are as follows:
(i) The final text of a directive on end-of-life
vehicles (ELV) was agreed recently and includes the phase out
of lead in new vehicles from 2003.
(ii) A draft directive on waste electrical
and electronic equipment (WEEE), which has now been separated
into two directives, the new one being restrictions on the use
of certain hazardous substances in electrical and electronic equipment
(ROS), is currently undergoing consultation with Member States.
The ROS directive proposes to eliminate lead from a wide range
of electrical and electronic equipment from 2008. Both the ROS
and ELV directives include a limited number of exemptions for
uses where no practical alternatives to lead currently exist.
(iii) A draft EC green paper on construction
and demolition waste was published earlier this year and includes
a recommendation that lead should no longer be used in new buildings.
2.2 LDAI welcomes these initiatives as mechanisms
for increasing the rate of collection and recycling and thereby
reducing the quantities of waste for ultimate disposal. The lead
industry plays an important part in recycling these products and
has been involved in discussions on all three waste streams as
lead is used for a range of applications in vehicles, electrical
and electronic equipment and the construction industry.
3. THE RISK
VERSUS HAZARD
ARGUMENT
3.1 LDAI is extremely concerned that all
three initiatives include the phasing out of lead, cadmium, mercury
and hexavalent chromium in new products on account of their hazardous
properties and without any scientific demonstration of risk. Hazard
is an intrinsic property of a substance and risk combines an assessment
of the hazardous properties of a substance with the degree to
which a target group is exposed to that hazard. Hence a substance
that is very hazardous but whose emissions are tightly controlled
is likely to pose a lower risk than a material which is less hazardous
but more widely dispersed into the environment.
3.2 It is therefore essential, and a fundamental
part of EU and UK legislation, that an assessment of the potential
environmental and health risks associated with a hazardous material
be carried out before any restrictive measures are considered.
In addition it is necessary to assess the risks posed by alternative
materials in order to ensure that there is an overall reduction
in the burden of risk. No such assessments have been performed
for any of the priority waste streams listed above.
3.3 This argument is backed up by the European
Commission's Scientific Committee on Toxicology. Ecotoxicology
and the Environment (CSTEE), following objections by EU Member
States to a proposed ban on lead in Denmark, which was largely
based on perceived concerns about waste. CSTEE concluded that
"the Danish authorities have not provided sufficient evidence
to demonstrate that the introduction of a general ban on the use
of lead products would result in a significant additional reduction
in the body burdens of lead in the general population." Instead
the CSTEE recommended that "it is more appropriate to tackle
areas where levels of lead exposure are significantly above average
by identifying the major sources of this exposure and taking appropriate
measures for their reduction."[251].
4. OTHER ENVIRONMENTAL
FACTORS
4.1 LDAI also believes that it is inappropriate
to restrict substances on the basis of waste considerations alone.
Instead, substances should be regulated under horizontal legislation,
for example the EC Directive on the Marketing and Use of Certain
Dangerous Substances. The impact of using a substance should be
assessed at all stages of a product's life cycle and in this way
all relevant factors can be taken into account. For example, in
the case of lead solders used in vehicles and electrical and electronic
equipment, substitution by alternative materials may have a negative
impact on the environment for the following reasons:
4.2 Recyclability
Lead is an inherently recyclable material and
unlike most non-metallic materials it can be recovered an infinite
number of times to produce a material that is indistinguishable
from the primary form. Recycling rates are already very high and
would increase further as a result of the ELV and WEEE directives.
Typical lead-tin solders can be used for virtually any electrical
or electronic application, thus limiting the number of substances
used in a product. No universal replacement exists for lead solders
and a wide range of substitute materials are required for specific
applications. The use of many different types of solder for different
applications could actually lower recycling rates as it would
be extremely difficult to separate all substances used in the
various replacement solders and recycle them separately. The use
of bismuth alone in replacement solders is a concern for at least
one major global electronic scrap recycling facility in Europe,
as the cost of removing the bismouth from other circuit-board
metals such as copper and precious metals may be prohibitive.
Furthermore the recycling capacity for many of these replacement
materials within Europe is very limited.
4.3 Resource Conservation
Proposed alternatives to lead-free solders generally
use materials with a much lower natural abundance than lead (lead
is one of the most abundant elements on earth). This fact was
highlighted by the National Center for Manufacturing Sciences
lead-free solder project that pointed out that "low melting
alloys usually contain high levels of bismuth and/or indium that
are expensive and have limited availability. The use of bismuth-
or indium-containing alloys raises serious questions concerning
the long term availability of these solders and the related ethical
implications of potentially exhausting the supply of an element"[252].
These arguments apply equally to other proposed alternative materials.
4.4 Risk Management
A wealth of information already exists on the
health and environmental effects of lead. Emissions of lead are
continuously monitored, as are levels in the environment. This
means that any risks associated with lead can be managed in a
highly effective manner in order to ensure that they remain below
accepted levels. However, many of the proposed substitute materials
have not been studied in detail and their impacts on human health
and the environment are not well known. This means that effective
risk management cannot be undertaken and this may ultimately result
in a greater risk to the environment in the future.
4.4 Energy Efficiency
Lead has one of the lowest melting points of
any common metal. As a result, the energy required to produce
lead, transform it into end use applications and then recycle
lead from waste products is considerably less than for many other
materials. However, many of the potential substitute materials
have much higher melting temperatures, resulting in increased
carbon dioxide emissions at various stages of the life cycle.
5. SUMMARY AND
CONCLUSION
5.1 LDAI welcomes the Government's Waste
Strategy and its vision for managing waste and resources in aiming
to deliver more sustainable development.
5.2 One of the key goals in the Government's
Waste Strategy is the minimisation of hazardous wastes. Although
we fully support the aim of reducing risks associated with wastes,
we believe that the phasing out of lead (as proposed in EU waste
legislation) will have a negligible and possibly even a negative
effect on human health and the environment whilst potentially
reducing the recyclability of products. Furthermore, there may
be negative implications for resource conservation and energy
efficiency.
5.3 We believe substances should be regulated
under appropriate EU legislation taking account of all impacts
on human health and the environment, rather than those solely
related to waste issues.
5.4 UK and EU waste policies should focus
on a reduction in the risks posed by hazardous wastes through
appropriate management, rather than simply minimising the use
of hazardous materials.
5.5 We therefore recommend the UK Government
reviews its negotiating stance with the European Union on the
proposed Directives concerned, taking into account that the elimination
of lead from priority waste streams may run counter to the aims
of a sustainable waste policy.
5.6 LDAI would be happy to assist the Sub-committee
with any further material it may require on this matter.
251 CSTEE Opinion on Lead-Danish Notification 98/595,
5 May 2000. Back
252
United States National Center for Manufacturing Sciences, Lead-free
solder project report No. 0401 RE96, 1997. Back
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