Threat to the pipe organ lifted in the UK and throughout the European Community
The threat against pipe organs has been lifted (but see below for the situation regarding electronic organs).
The European Commission has accepted the unanimous agreement of the EU Technical Adaptation Committee on 26 June that organ pipes are outside the scope of of the WEEE and RoHS directives due to come into effect on 1 July which restrict the use of hazardous substances, including lead, in machinery and appliances that are reliant on electricity for their primary function. The decision is understood to be largely on the basis that pipe organs do not fall within the definition of consumer equipment and electronic products to which the regulations apply.
More details from pipes4organs.org >
The decision has been endorsed by the Trade & Industry Minister, Malcolm Wicks. A copy of the DTI press release may be found here.
The decision is effective immediately and revised EU guidelines are expected to be published shortly. Changes to the Directives affecting the legal changes will take a further 18 months.
The RSCM – along with other musicians around the EC – welcomes this news.
It is important to note that although some EU statements refer to "church organs" being excluded, it is understood that electronic organs in churches will remain subject to the regulation.
The threat to the pipe organ is lifting in the UK (and throughout the European Community). Thanks to lobbying and media coverage, the Department of Trade and Industry has responded, albeit tardily, and it seems that the threat to pipe organs is receding. The Minister for Industry has announced in the UK Parliament that the pipes in pipe organs lie outside the bounds of the European directives regarding lead and other hazardous substances. This follows an earlier statement to the European Parliament by the Commissioner responsible for the legislation. The deadline of 1 July 2006 is, nevertheless, a tight one to meet.
Two European directives relating to the manufacture and disposal of electrical and electronic equipment, quite accidentally, created a threat to the building of new pipe organs. The directives relate to lead and five other hazardous substances used in electrical and electronic components and manufacture (e.g. solder): they are intended primarily for consumer goods (which include some electronic musical instruments). The definition of ‘electrical equipment’ appeared to include anything which will only operate when powered by electricity - including any pipe organ reliant on an electric blower, electrically assisted stop and piston action, and electrically controlled key action. An organ with mechanical action and blown by hand was never going to be affected. This was patently anomalous, since both a hand-blown and an electrically blown pipe organ contain a substantial quantity of lead alloy in the pipes. There has been real concern that this would bring an end to the building and import of new pipe organs in Europe. This would have immediately put paid to plans for the new organs at Worcester Cathedral, for instance. And it took a good deal of media coverage and political lobbying to persuade the Department of Trade and Industry to grasp the nature of the pipe organ and to reach a common-sense view.
The situation as expected
Organs will be affected in part by the legislation, which comes into effect on 1 July 2006. All electrical and electronic components of any new pipe organ will be subject to these directives, as will an entirely new blower or new action. Repairs and renewals of existing components are, however, exempted. New digital and electronic organs will also have to comply with the directives on the same terms. The same exemption will apply to repairs of existing instruments. Many manufacturers of electrical and electronic components have been preparing for this change for some years, so this should not affect any project that is about to begin.
The RSCM has been active in discussions with Members of Parliament, the Institute of British Organ Building, the officers of the Council for the Care of Churches and the Cathedrals Fabric Commission, the media, organists, and some of those in charge of organ projects – and is delighted to welcome a common-sense solution.
What you are advised to do
If you are planning an organ project that will begin after 1 July 2006, you will need to take note of the developments. Much detailed advice, updates, and a full account of the saga at the dedicated website www.pipes4organs.org
You may have heard of the current threat to pipe organs. We hope that we can provide you with some clear information and advice.
The problem of lead
Two European directives relating to the manufacture and disposal of electrical and electronic equipment have, quite accidentally, created a threat to the building of new pipe organs. The directives relate to lead and five other hazardous substances used in electrical and electronic components and manufacture (e.g. solder).
The directives are intended primarily for consumer goods (which include some electronic musical instruments). However, the current interpretation of the definition of 'electrical equipment' includes anything which will only operate when powered by electricity.
This definition therefore includes any organ reliant on an electric blower, electrically assisted stop and piston action, and electrically controlled key action. An organ with mechanical action and blown by hand is not affected. There is an anomaly here, since both a hand-blown and an electrically-blown pipe organ will contain a substantial quantity of lead in the pipes.
The Department of Trade and Industry is entering into a specialist field, and has apparently found it difficult to distinguish between digital/electronic organs and pipe organs.
So what does this mean?
As things stand, there is no difficulty in repairing an existing pipe organ using either compliant or non-compliant materials (i.e. with or without lead) both now and in the future.
From 1 July 2006, when the directives come into force, new pipe organs will be affected by the restriction on the use of lead. This causes a major problem.
The majority of organs requiring work are neither new nor being repaired: they are being rebuilt, often with new action or additions. This is an area where it is not at all clear, since there is no provision in the directives for this 'middle ground' between repair and new construction.
On the basis of the evidence and interpretations currently available:
- The new organs planned for Worcester Cathedral could not go ahead.
- It is not clear whether the new Nave organ planned for St Albans Abbey would be permitted – it is new, but part of an existing instrument.
- It seems likely (but not quite certain) that the current improvements to the console of the organ of Salisbury Cathedral would be permissible after 1 July (the work will in fact be completed earlier than that date).
This is a serious matter, and everyone is hopeful of a sensible outcome. A pipe organ may be assisted by electrical and electronic equipment, but of its nature it is not electrical or electronic – and it certainly does not fall into the category of '‘consumer goods' that rot in landfill and other rubbish tips, and to which these directives primarily relate.
What is happening, and what can you do?
The Royal School of Church Music has been active in discussions with Members of Parliament, the Institute of British Organ Building, the officers of the Council for the Care of Churches and the Cathedrals Fabric Commission, the media, organists, and some of those in charge of organ projects – and will continue to press for a common sense solution.
If you are planning an organ project that will begin after 1 July 2006, you will need to take note of the developments. It may be too soon to panic, but not too soon to protest!
For a detailed review of the matter, and an opportunity to sign a petition, go to www.pipes4organs.org