[Stoves] Aprovecho's ISO certificates

[Kirk H.]

All,

I cannot comment on the legalities of your discussion, but  I can tell you about my experiences with Aprovecho’s testing equipment.  Dean Still has offered the use of Aprovecho’s lab to others as well as myself.  He tells me that I am the only one who ever took him up on it.  I spent two weeks at Aprovecho in March of 2016, using their equipment to improve the turn-down and emissions of my TLUD-ND.  I repeatedly tested iterations under the hood.  The resultant stove finally worked as desired, being able to burn clean at various power levels.  Dean then gave me a test at Lawrence Berkley National Labs burn lab which Aprovecho had received in an EPA grant.  The stove tested at tier 4 in most catigories.  This would not have been possible without Aprovecho.  

I noted that Aprovecho’s equipment was not as sensitive as Berkley’s, but it was also a fraction of the cost to build.  If used properly there is a place for both types of equipment.  Apro’s equipment is excellent for pounding away at a problem and cleaning up the stove.  Berkeley’s equipment is great for getting final detailed lab test results.  I don’t see one as being good and the other bad, but that each has it’s strengths and its place.

Kirk H.

Sent from Mail for Windows 10

From: Crispin Pemberton-Pigott
Sent: Wednesday, October 18, 2017 11:44 AM
To: Discussion of biomass cooking stoves
Cc: Dean Still
Subject: Re: [Stoves] Aprovecho's ISO certificates

Dear Nikhil

>Trustworthiness does not come by claims alone. 

Fair comment.

>I believe EPA did go to UL for certifying cookstoves. 

I was not aware of that.

>Maybe, after the ISO issues standards of performance from TC-285, US would incorporate them in law and then approve UL, Aprovecho, or other suitable body for testing and certification.  

ANSI, headed by John Mitchell from EPA, declared at the very beginning that the USA would not be using the product of ISO TC-285, even though they are co-sponsors of its creation. France commenting on the creation of the TC, questioned whether the result would affect existing regulations governing cooking appliances in Europe (which are covered by an omnibus standard for all stoves). That comment was addressed by saying the TC-285 product was for use by developing countries, which excludes France and the USA. I have no idea how the ISO determines which counties are ‘developing’ ones, nor where there should be different ISO standards for developed and developing countries.

>When a product manufacturer's claims fail, the buyer ought to have legal recourse in addition to merely voting with money. 

I guess there are two targets for such ire: the vendor making claims that are not valid, and the lab that certified that it has the performance claimed. If a claim is outside the Limit of Quantification of the apparatus, then a priori it is not a valid claim.

>The manufacturer then cannot hide by merely appealing to UL certification. A court would hold UL liable if it made a finding that UL used improper protocol - not an "industry standard" - or wrong equipment. 

Well, the relevant way to talk about it is: is someone is using a pre-2016 LEMS and making claims that a stove ‘performs at tier 4’ for some or other measurement, say PM2.5, then someone’s leg is being pulled. It is not ‘wrong equipment’ it is that equipment has limits with respect to detection and quantification, and there are standards ways to rate it. Nothing about this is unusual. That is how equipment ratings are done.

> "Anyone can claim to be following any protocol they like." What do you think - Gold Standard would be next, or GACC, or me? 
You are free-with-abandon to invent your own test method and assemble equipment and make claims within the constraints of the equipment and protocol. 

>UNF could. If it is an "international organization", it may be above US jurisdiction for certain liabilities. I will have to look up the IO law. 
I understand there is a legal USA definition of an IO. Surely there is also an international one?

Regards
Crispin



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