Motie,

--- motie_d <[EMAIL PROTECTED]> wrote:
>snip<
>If they choose to risk distributing
> it
> > (or fail to catch it in house) they become subject
> to
> > loss of bonds and actions from the regulators
> which
> > are also economically undesirable and can include
> > shutting down of the facility until independent
> tests
> > show that the product is consistently "to spec".
In
> > fact the independent testers are randomly tested
> as
> > well.
> I perhaps don't know enough about making Biodiesel
> to form a 
> qualified opinion, but can the same procedure be
> used for Biodiesel? 
> I'm asking out of honest ignorance, not trying to be
> facetious.

I believe so.

> Is there any evidence that Yellow doesn't have such
> a system in place?

None I am aware of.


>If the required testing will cost Yellow $1Million,
will the cost of 
>rebuilding the regs be even higher?

I don't think the testing will cost a million. This is
a miscommunication I think.

>> In fact I do not believe that membership in the NBB
>> exempt a BD producer from anything...it just makes
>> certification a simpler process.
>I really don't understand this portion, and haven't
from the start. 
>If the testing required for non-members, will cost
$1Million, how 
>does membership reduce the cost, if it doesn't exempt
him from the 
>tests?

See above regarding the Million. Testing of the actual
product won't cost a million. Duplicating the
"pollution" tests that the NBB has provided the EPA
might though. These are separate issues... e.g. the
miscommunication.


Ah, yes... Certification.
Certification really does not guarantee a standard is
being held to as your illustration with the welder
showed. Certification is only effective if it can be
"yanked" for failing to live up to the standards set
at certification. If that welder would have thought he
could lose his certification (and access to pay he
obviously ,at least in that case,  did not earn or
deserve) he might have done a better job. The
intention of the implementation of certification was
that critical welding should only be performed by
those that have at least proved they have the ability
and knowledge to do it for those who certify. This
unfortunately is only half of the equation as without
subjecting those so certified to close scrutiny after
they are certified there is little incentive to
actually produce welds that are up to those standards
after receiving the certification(except pride in ones
work) and there if a sloppy weld will produce the same
income as a decent one...well you know the rest of the
story. If the paperwork said the weld was done by a
certified welder you are off the hook if the bridge
fails due to the sloppy weld...if not you are liable.
The public interest is not served...only the public
officials interest.

I was once a certified welder...it was too easy to
become one and some of the folks that were certified
alongside me needed extensive coaching to pass. This
is one reason  why all welds are x-rayed on pipelines
and nuclear plants...and why certification does not
mean "squat" to the Supervisors on such projects. It
seems a second layer of regulation was "needed" for
such critical project welds as the first one is
useless for all PRACTICAL purposes. I agree that a
strong random testing program is usually much more
effective than a "certification" program...but for the
EPA's purpose certification is more practical. The
meat inspector testing program was an example of what
happens when you put the govt. in charge of doing the
tests...there are simply not enough inspectors due to
budget constraints and the siphoning off of funding at
management levels...and those inspectors are low paid
and so susceptible to..er...supplemental income offers
from those they are supposed to "police". Whew that
was close.....I almost inadvertently accused govt.
officials of corruption. That would have opened up a
can of worms!!!!

Dana





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