Thursday, January 26, 2017

EPA sends “Compliance Reminder” to Stove Manufacturers

There are six accredited test labs that
issue confidential and non-confidiential
test reports.  Non-confidential ones are
required to be posted on company websites.
On January 10, 2017 the EPA Office of Compliance sent a “Compliance Reminder” letter to all stove and boiler manufacturers because some manufacturers were not complying with transparency, reporting, and record keeping requirements.

At issue is the requirement that manufacturers 1. Post non-confidential certification test lab reports on each of their stoves on their websites, 2. Implement a quality assurance plan that is approved by a third party certifier, and 3. Submit a report to the EPA every two years about sales and other information.

The Alliance for Green Heat reached several manufacturers who did not consider these requirements overly burdensome and welcomed the prospect of a level playing field. Representatives of HPBA, the industry association that represents most stove and cordwood boiler companies, were not immediately available for comment. (Their position will be added to this blog when it is available.)

In May 2016, the Alliance for Green Heat wrote a blog on which companies were complying with EPA regulations and posting test lab certification reports on their websites. We wrote: “The EPA has not started enforcing some of the provisions of the 2015 regulations that are being ignored by many companies. And, its enforcement capabilities are slim, a fact that is not lost on the industry that it regulates.”

We found and commended companies like Blaze King, Jotul, Kuma, J.A. Roby, Seraph, Travis, and Woodstock Soapstone who posted some or all of their test lab reports. However, we found the largest company of all, Hearth & Home Technologies, did not. Two weeks later, they had posted the required reports.

A pdf of the full compliance reminder letter, signed by Director Edward Messina, can be downloaded here. It was copied to HPBA, NESCAUM, WESTAR, NYDEC, and NYSERDA. The Alliance for Green Heat obtained a copy on January 24. The Alliance for Green Heat is concerned that in many instances, some stakeholders, including the stove retailer community, are not privy to such letters that the EPA shares or directs to industry, states, and air agencies.

When there is widespread non-compliance, the EPA has relied on compliance reminder letters in the past, partly to assure manufacturers that there is not selective enforcement, but that all manufacturers need to play by the same rules. In May 2013, the EPA sent a tougher letter to manufacturers of qualified outdoor boilers, giving them seven weeks to remove exaggerated efficiency numbers from their hang tags and advertisements. This letter did not give any deadline for compliance.

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