[Stoves] Free webinar on automated wood stoves

[Crispin Pemberton-Pigott]

Dear Nikhil

>Did BNL do "cookstove testing"?

I have no idea. It is a space heating stove test facility. Last year they conducted a long and carefully design set of experiments to see how the CONDAR system compares with the EPA dilution tunnel. The CONDAR is far cheaper as a system. It was a set of tests to see how scattered the data were, done with a very reliably consistent pellet stove that emits very little PM.

The result was that the CONDAR has 1/5th of the CoV of the EPA dilution tunnel method. At low PM levels, it is a superior technology and happens to be a tiny fraction of the cost.

>You can do what you want in your private space but can't market your services or results without some legal or regulatory imprimatur if the results are to be used in the formulation of or compliance with some official standard?

Well, if one were to claim to be able to perform EPA tests you would have to prove it on demand.

>That imprimatur may be derived second- or third-hand, but the main question is one of jurisdiction.

I would say it is a question of capacity – using a method that has been approved using ISO 17025 if you were to claim that you could test to ISO requirements, voluntary or otherwise. To get 17025 certification, a lab needs to choose one of two paths: either they can test (something) in a consistent manner and get the same answer (self-referential replication). The alternative is to replicate what is done by another lab. Neither of them have to already have the 17025, they can do it to and for each other because they might be the only two in the world that can do that thing.

If you claim to be able to test to EPA xxx or ISO xxx you would have to show you were certified to do that, even if it is only your own protocols for something your lab does. ISO 17025 consists, like 9001, largely of documenting things. It is reviewed every three years, externally.

>Unlike some other countries, in US a government cannot just do anything it is not prohibited from doing under the law.Rather, it may only do what it is explicitly authorized to do.

OK.

>EPA and its contractors have a legal framework to abide by.
OK. There is a framework in there fore validating the ability of a lab to perform certain tests.
>It is silly to assume that after the WHO poppycock on SFU Guidelines -- which didn't need any legal basis, though its exact authorization from Margaret Chan should be explored -- the TC 285 directives can be automatically become effective under US law.
I don’t fully understand that sentence. However I can point out that TC 285 which is making ISO 19867 (and others) is producing a voluntary standard that is only applicable to “developing countries”. What the heck does that mean? Is China a developing country? The ISO has no power to make a standard into something required by a country. The country must do so, and usually that is only going to happen after reviewing it. Usually there are localisations needed unless it is highly technical like a communication standard etc.
When it comes to the USA, it was specifically stated clearly at the start of the process that the they would not be using the standard themselves. I don’t know why they took time to say that. Who would have been worried by them not saying so? Is it supposed to be for directing funding through organisations like the GACC and WB and USAID and Engineers Without Borders and Practical Action? If it is, then it should have been written by them.
As for the WHO method of ‘estimating exposure’ and calculating DALY’s from it, it doesn’t pass the smell test. Anyone looking into the matter quickly realises it is so unrealistic that the uncertainty of any claim will include zero. Specifically, claiming that a certain emission rate from a stove predicts health impact is unsupportable. As we showed this winter, demonstrating that exposure can be measured is trivial and accurate. Predicting it is hopeless.
>If EPA seeks to incorporate ISO cookstove standards under US law, with testing and certification methods recommended by TSO, there may be a cause for action under Federal law.

They have already handled that by declaring that it will not be used in the USA, by anyone, for products sold in the USA.

Regards
Crispin


-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.bioenergylists.org/pipermail/stoves_lists.bioenergylists.org/attachments/20170617/b630d14a/attachment.html>