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  3. Sunday, 02 May 2004
POST 00669E : PQS DOCUMENTS Follow-up on Post 00658E 2 May 2004 ______________________________ Ville Lehto ( comments PQS documents published earlier (POST 00658E) ______________________________ The whole PQS package is quite big and it contains many interesting aspects. Here are some of my thoughts. First I have couple of comments about small details in "From PIS to PQS" -document: - About product verification and which route to follow: If I follow the decision tree with our incinerator in mind, I end up with "Prepare quality assurance protocol". It is possible to transport it in one piece, but it is much more cost effective to pack it in few pieces. These rules would change the case totally, because running full emission tests in the field can easily cost three times the value of the product. Considering other requirements there is no need to adjust the product for different field/climate conditions. I'm afraid we are not the only company that is faced with this problem. I think this procedure needs some further clarification. - When assessing the strengths and weaknesses of the methods for obtaining feedback on product performance in the field the weaknesses for electronic reporting included "requires internet access" and "requires motivated country staff". In some cases these problems could be avoided by including automated transmission of data via GSM e.g. daily or every time the product is used. However this would be suitable only with durable products for which adding the system wouldn't cause relatively excessive raise in price. Another requirement would naturally be the existence of GSM-network. Then a bit wider aspects about the waste management: The waste management is about how to transform the material flows of the industrial system into a form that the ecosystem is able to take and handle. It should be seen as a process where we have inputs and outputs. If we have e.g. carbon in our inputs, it is likely to come out in some form. Considering incineration, if the process would be perfect, all the carbon would come out in form of CO2, which is one of the normal compounds of the ecosystem. The point is: When planning for specifications for environmental performance it is important to standardize also the input. We need some standardized waste inputs with which to assess the performance of the devices. We should also carefully determine in which forms we hope to get that material out. Another alternative is to transform the waste material into a form that the industrial system can use again (recycling). Many times this calls for several steps like sterilizing the waste (if infectious), segregating the different material subsets, transforming them in the form that is suitable for the customer… Transporting is often needed between these processes, or at least from the point where the waste is created to the point where the recycled material is re-used. All these steps create costs and emissions and some part of the material is still always lost as waste. Here we are working with so many situation specific factors that it is better make assessment case by case. My question is: Should final disposal devices have specifications different from those devices that just treat the waste some way? It should be carefully assessed which solution to choose. When doing so one should take into account all the outputs, costs and emissions. I agree that it is definitely good to use performance specifications. The results are important, not the way they are achieved. However, establishing specifications for waste management devices might be quite complex task. It is probably very hard to find common specifications that would cover all the technologies. Considering environmental performance some technologies might create liquid emissions, others gaseous or solid or any kind of combination of these. The problem is: How to valuate different emissions and their impact? Is the global warming more serious than pollution of local river system, and if so, with what factor should the seriousness of these effects be multiplied? It is not easy to find answers to all these questions. Discussion and opinions of experts are needed. We would like to know when the waste management working group begins its work on the specifications, and how could we be contributing/involved in this process. We are expecting the full results of our new emission tests by the end of the month. We will let you all know as soon as we get them from the Oulu University Energy Laboratory. Best regards, Ville Lehto Marketing Manager Mediburner Ltd. 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