It could be a design issue too. Like are they accidentally over-voltaging the clock with a transient or some sort of power sequencing issue? Or does some component have tin somewhere? Really hard to say at this point.
The problem was ultimately found to be a combination of pedals being pressed by floor mats, pedals sticking on their own, and drivers pressing the wrong pedal.
That's not to say acquiring non-RoHS components isn't made more difficult by RoHS.
http://www.militaryaerospace.com/articles/print/volume-20/is...