Can the batch size be increased so that the fewer test costs required are spread more effectively?

No, the batch size can not be changed.

It is REACH Directive. While we may say that it is off base, the recent events in china give pause to our plaintive whine. Just consider it to be an inflationary cost of doing business in china.

REACH

What is REACH ?

REACH is a new European Community Regulation on chemicals and their safe use (EC 1907/2006). It deals with the Registration, Evaluation, Authorisation and Restriction of Chemical substances. The new law entered into force on 1 June 2007.

You are unlikely to out argue europes full corps of Green Bureaucrats.

milo

We already have two NSF International certifications, EU RoHS certification, USDA, and pass all USEPA standards for hazardous materials in drinking water. Sb,As,Cd, Cr,Pb,Hg,Ni,Se, Mo, etc, are all non-detectable at the release rate of the product.

And I totally understand about Chinese products. We do not/will not use them even if the products cost more.

I know that arguing with the EU Greenies is a losing battle. It is totally unreasonable that the EU will not accept USEPA test methods for some of these procedures. A residual of .5 ppb or less of those metals is SO MUCH SMALLER THAN THE AMOUNTS ALLOWED IN THE TAP WATER.

The question still is: Will Cyanide survive the process? I do not think so. If someone could show me how it could, I'd be a happy camper.

Well I can look up the high temperature properties of KCN at work tomorrow;

After the 1700+ temperature excursion, what can you show the compound to have dissociated to? Send me by direct email (click on my name above) with list of all chemical species in this process at temperatiure and I'll look for them too.

My approach would be to 30 tests, and use student t distribution to give thwm an error band, Mean, and standrd deviation, but then again i m a rational empirical trained in science guy; they remain touchie feelie fearful greenie bureaucrats.

30 tests and statistical relevance is cheaper than testing each batch for ever and ever.

I will send you the name of a law firm that specializes in REACH issues tomorrow if you like.

milo

Thanks anyway. I think I'll just let the Europeans continue to drink scale inhibitors that don't meet the specs required because they are made in the EU. I know they don't pass because we have had them tested for those metals and other impurities.

Well, they will have to deal with it, themselves, the REACH regs don't apply only to imports.

miles

Thanks for your help.

http://www.freepatentsonline.com/5238581.html

You're welcome.

milo

Some facts about reach.....NO-ONE Knows how this is going to work yet, least of all the enforcement bodies. It's going to be run out of an office in Finland (I think!) and they are going to rely on companies and/or organisations to report to them what substances they are importing/using. When they have enough information from all those co-operative....errrr...entities, they will then start making decisions.

As you can see, this is the usual well thought out and organised EU legislation. So, you could be breaking the law, you could go to the authorities and prove to them that you are breaking the law, and they still couldn't take any action, because no-one knows how to apply the law.

You couldn't make it up!

Makes you really want to do business there doesn't it?