[Stoves] News (Uganda): Government official cautions on standards for cookstoves (aDALYs next?)

Sat Sep 30 15:32:51 CDT 2017

Dear Nikhil

>You seem to be endorsing Ron Larson's view that the ISO TC-285 is just a sport of "voluntary" gathering.

On many levels it is. There is nothing coercive about the ISO process. Most countries use ‘the ISO process’ which means the rules for creating a Standard. Participants especially at the Working Group level have a vested interest in the outcome. I got involved with stove standards because I manufacture stoves. At the time I intended to manufacture paraffin stoves and in fact one of my designs won a large sum in a competition for clean burning stoves. That was shortly after I won 3 design awards for the Vesto stove which I hoped would become a major export product. Times change, however…

>A standard may not be adopted or "Any standard can be applied (required) in part, not in entirety, depending on the whim of the Minister relevant."?? Sorry, things may not be that simple.

Agreed it is not simple, but it is up to the Minister in nearly all countries.

>If you don't involve any government or multi-governmental actor in your stove project, anything goes.

Totally agree. That becomes a private contract. The CSI project is like that except there is a government involved as well. It is ultimately a government pilot, not a WB-as-NGO project.

Re: the Government of Uganda when creating the National Mirror Committee of TC-285; see Establishing and Running a National Mirror Committee  for ISO/TC 285 –Uganda’s Experience<https://share.ansi.org/Shared%20Documents/Standards%20Activities/International%20Standardization/Standards%20Alliance/Ghana%20NMC%20training/Est%20NMC%20TC%20285%20%20in%20Uganda.pdf> (2014?). Or for Malawi, ISO MIRROR COMMITTEE IN MALAWI – THE BIG PICTURE<https://share.ansi.org/Shared%20Documents/Standards%20Activities/International%20Standardization/Standards%20Alliance/SADC%20National%20Mirror%20Committee%20Training/Presentation%20on%20MALAWISs%20MIRROR%20COMMITTEES%20(1).pdf> (2014?)

In order to fully participate a country’s standards body needs a mirror committee that will discuss things at the national level and make recommendations to their body, which if approved, are passed along to the ISO TC. These bodies frequently do no transfer all comments and suggestions to the TC. It depends on what they want to say. In short there is politics involved.

>All the 45 participating and observing national members of TC-285 and the international organizations that are liaison - including GACC - are surely waiting for standards. Nationally adoptable, useful and enforceable standards. (Enforcement may be limited only to certain procurements under public control).

And other countries that are not participants, I expect.

>If a standard corresponding to a product cannot be enforced, it is useless. Means of enforcement may vary, but I am assuming TC-285 is not simply card-games-and-coffee club or billiards-and-beer bar for experts.

Well, that is not really the whole picture. You can have voluntary standards for decades. It depends on the market. If Uganda implemented a national standard for all domestic stoves it would just create a massive illegal market for products already being sold. It would be better to say there is no point in making a standard compulsory unless there is a viable enforcement mechanism and staff to do it. South Africa has only 4 people to manage their kerosene stove market, worth about ZAR300m per year. That is nearly hopeless.

>Why was IWA 2011:12 constituted?

At first blush, because the EPA wanted to create a set of tiers for performance similar to the ones they have for other industries, and to embed the WBT as the go-to test method before it was seriously challenged in academic circles. Obviously it was already being challenged by the private sector.

> "Although progress has been made to establish interim fuel use, emissions, and safety guidelines, further development and adoption of voluntary industry consensus standards is required to provide transparency to governments, donors, investors, and others regarding the potential benefits of different solutions and to develop certification procedures, performance benchmarks, and meaningful test infrastructure for the global cookstove market." (emphasis added)  Cleaner Cooking Solutions to Achieve Health, Climate, and Economic Cobenefits, Environ. Sci. Technol. 2013, 47, 3944−3952 dx.doi.org/10.1021/es304942e<http://dx.doi.org/10.1021/es304942e> |

The code word there is ‘fuel use’ which they meant to include ‘clean fuels that are by definition ‘clean; and avoid ‘dirty fuels’ which they said were coal and kerosene (both to be avoided). Biomass was only to be tolerated in the interim because of a lack of choices.

>What does "required" mean for "voluntary"? There is no "voluntary" except that non-standard stoves will sell to non-standard cooks using non-standard fuels in non-standard homes.

Voluntary means it is not a requirement for production and marketing. Required means needed for production and marketing. Enforced means there are consequences for not meeting the requirements.

>International trade in manufactured woodstoves is minuscule. There is no "clean cooking sector" (LPG companies and electric utilities belong to energy sector, not "cooking sector").

I feel that is an important observation. The energy sector would agree with it.

>And I do not know any public health ministries at national or provincial levels in developing countries interested in developing indoor air quality standards, leave alone enforcing them.

India might.

>Why, Anenberg, et al. (2013) claimed that the June 2012 publication of IWA 2011:12 "serves as interim guidelines for evaluating stove performance" and GACC<https://cleancookstoves.org/binary-data/ATTACHMENT/file/000/000/46-1.pdf> also claims that the IWA 2011:12 is serving as a "guideline". I suppose "guideline" was enough to force regional test centers and stove projects to use the WBT and Tiers.

The GACC required the use of their test method in order to get funding. That was for a while, then they backed off putting it in writing, but in practice it still meant the same thing. No WBT results, no money. Which version? That is a very important question. The WBT in the IWA refers to v4.1.2 which in Oct 2011 was really defective. The defects were pointed out in the public comment stage prior to the meeting. It was not corrected (at all) before the IWA was created. It was corrected several times afterwards, with the addition of numerous new calculations and the generation of almost all of the metrics named in the IWA (only one metric was generated by v4.1.2 when it was said to be ‘not the only valid test methods’. I do not see how a test method that doesn’t produce the metrics can be ‘valid’.

Once the invalidity of the three low power metrics was known, then published, there was a problem: the IWA required them, they had no logical legitimacy, yes the WBT was edited to produce them. Which external, expert reviewers approved the version of the WBT that was created to generate those metrics, such review required by a resolution in the self-same IWA? No wonder there is chaos.

>IWA itself  says "This.. serves as a guideline for policy-makers..."

Well, that is true whether the metrics are valid or not even generated by the test method. It is ‘guidance’ of a sort.

>If IWA and WHO "guidelines" are forced upon developing countries, why does one need TC-285? Only if TC-285 "voluntary" standards are made "required" by developing countries.

That is a very good question. If the metrics of the IWA are definitively judged to be scientifically invalid, those cannot be applied to anything. If there are conceptual errors invalidating other claims, such as the ‘fuel consumption’ metric, that too is out the window. What is left? You see, before a standard can be made a National one, it is reviewed by experts at the national level. They might review the literature and interview experts about the protocol, tiers, methods, investigate anything they like. Following that, like China and India and South Africa and Kenya, they would ignore it.

>…IWA "guidelines" have perpetrated an ideology of WBT as the golden protocol and the IWA Tiers as golden Tiers; just ask GACC or Xavier.

True, I guess.

>Every standard - by whomever, enforced or not, governmental or private -- has to be justified in reference to a purpose and a product.

For private purposes that can be a very slim report.

>With the ISO TC-285 exercise, I cannot tell what the purpose is. Whose purpose is it? Who had the authority to decide a standard had to meet some "climate" objective, a "deforestation" objective, a "health" objective, in an inter-governmental forum, which is what TC-285 is?

No idea. Whoever it is does not attend meetings, or is doing so from behind a screen. One can always ‘try and be helpful’ but that doesn’t mean there is transparency on every front.

>I repeat - there is no service standard in a vacuum, only for specific contexts and purposes of cooking.

That is the big problem with cooking stoves standards for a nation – which context constitutes a valid assessment framework, Without a contextual test and target, there is no value save in the most abstract sense. Product regulations are not supposed to end at abstract assessments. Usually this is handled at the national level with a contextual framework, and a contextual testing regimen. Obviously one size will not fit all, even within one nation.

>This is no sport.

It is to some.

Regards
Crispin
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