POST 00669E : PQS DOCUMENTS

Follow-up on Post 00658E

2 May 2004

Ville Lehto (mailto:[email protected]) 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.
Oulu, FINLAND

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