GBE > Encyclopaedia > Code > Opinion > G#182
Barriers Drivers towards more Sustainable Profitable UK Cement Industry
Barriers Drivers towards more Sustainable Profitable UK Cement Industry
About:
Opportunities are enormous
- But the cement industry is like an ocean tanker
- almost impossible and very slow to steer away from its current course,
- it is slowing down, but not nearly quickly enough
- and it will never stop by its own means
- it needs a bigger barrier or lateral thinking to come to an effective stop
- Unable or unwilling to meet its full potential to escape its production of carbon
- at a time of global carbon crisis
- In favour of fiduciary rules (legal obligation to make profits for shareholders).
Relevance?
- I used to so get frustrated with University Professor’s controlling the subjects adopted by students carrying out MSc or PhD research;
- Focusing on academic prowess over doing anything useful, either for industry or the student who could potentially became an industry specialist in the topic of their research.
- So I nod my head to Cardiff Metropolitan University School of Management when Joana Malato chose to focus on the cement industry and see if it could be improved and to the Professors that said “Yes”.
- What a challenging project!
- My suspicion is that Joana had detected some of the problems described below and wanted to see if they could be resolved in favour of a lower carbon future with strong Small to Medium Enterprise (SME) involvement.
- And what career could be carved out after this research?
- I could see a place for Joana helping develop those SME innovative and alternative cement manufacturers to become key players in a joined up low carbon cement Industry.
- ‘In your dreams’
- But I think Joana is made of sterner stuff.
- Pun intended: we need some concrete solutions, Joana has them.
End of summer all will be revealed:
- I will not be able to reproduce Joana’s work here, nor would Joana, until after it is completed, handed in, peer reviewed, assessed and released, so I will restrict my comments to the roundtable discussion between a select few stakeholders who also participated in the sector wide survey carried out by Joana.
- Their names will remain undisclosed but their role in the industry is now declared:
- University researcher
- Cement manufacturer
- Sector manufacturer’s association
- Big design consultant
- Alternative cement manufacturer
- Builders merchant
- Big industry sustainability advisor
- Environmental specification consultant
- You probably worked out who the first and last are and guessed a few of the others.
- Sorry no prizes.
- Permission was granted to record the discussion to enable detailed review
- In true Michael Jackson spirit I recorded the recorders.
Stakeholder Round table
- Joana set the framework with a detailed canter through:
- Sustainability and change,
- Current situation,
- A low carbon industry,
- Drivers,
- Barriers,
- Bringing it together;
- 4 main Drivers and 4 main Barriers were presented for simplicity of delivery of the messages
- It was quickly decided that ‘Costs’ should be pulled out as a separate item in Drivers and could potentially also be a Barriers.
- Followed by discussion focussed on barriers, drivers, order of importance in barriers and drivers and interrelationship between barriers and drivers.
- Nice simple format that got a good discussion going.
Global Imperative:
- 6th May 2015 it was reported that globally we broke the significant 400ppm milestone of Carbon Dioxide (CO2) in the atmosphere in March 2015
- Whilst in 2013 we produced 4 billion tonnes of cement releasing 4 billion tonnes of CO2,
- 7% of global CO2 production down to global cement production.
- I hate to break the bad news, but I think there might be a link there.
- Despite being heavily regulated and taxed the cement industry continues to pollute CO2 with impunity.
- Ozone depletion was sorted but carbon continues to escape.
- We need a shift in mind set from Sustainability to Environmental when such large levels of CO2 are released.
- The coal mining industry was disbanded for a whole swathe of reason and the coal-fired power stations were predominantly replaced by gas to meet CO2 targets, so the politicians could pat themselves on the back.
- At what point does global government step in and say ‘enough cement is enough’?
- Oh no, we just voted the business-friendly blues in, no hope there then.
To misinterpret one of Joana’s diagrams
- Boiled frog syndrome suggests the cement industry is heading for a big impact with rock bottom before and if it can bounce back as a sustainable industry.
- Rock bottom is probably where profitability & Gross Value Added (GVA) clash and the maths won’t work out.
- This industry is worth £ 1 billion/annum and a lot of profit for shareholders.
- Until they follow suit with Shell shareholders Annual General Meeting resolution demanding greater transparency about the group’s impact on climate change,
- we will continue to head for 4C degrees increase in global temperatures,
- double the level considered safe for human habitation of the planet.
Low hanging fruit:
- The Cement Industry will not drive to ultimate carbon reduction but continue to pick off the low hanging fruit:
- Renewable energy in place of UK mains supply
- (Taking care to avoid nuclear?)
- High carbon fossil fuel replacement
- (Taking care not to pollute with dioxins and other nasty’s from plastics, rubber and animal waste?)
- (Budgeting for replacing the excessively expensive filters at correct and regular intervals and not turning them off, like some of the waste to energy brigade)
- Avoiding acid rain by cleaning flue gases
- (Generating another by product de-sulfurized gypsum to sell?)
- (National Industry Symbiosis Programme (NISP)’s can help find customers)
Harder to reach carbon reduction methods:
- Carbon Capture and Release (CCR):
- To be bottled in fizzy drinks and sold? No that won’t solve anything
- Carbon Capture and Photosynthesis (CCP):
- Feedstock for other industry symbiosis opportunities: e.g.
- Growing fruit and vegetables in greenhouses
- Growing bio-based construction materials (Oh no, the competition!)
- (NISP can help find non-competing customers)
- Feedstock for other industry symbiosis opportunities: e.g.
- Carbon Capture and Storage (CCS)
- Feedstock for other construction industry players: e.g.
- Carbon8Systems manufactured aggregates with carbon sequestration
- To go into the concrete mixes of low embodied carbon concrete
- Or piped to store in rock below ground
- Not piped to the ocean as was suggested by one stakeholder
- Not pumped to the atmosphere, but to the oceans, as if that’s a solution.
- The oceans need to be cool and oxygenated not carbonated
- To concentrate algal blooms to kill the already overfished oceanic food chains
- Oceanic carbon sequestration is not the answer
- Growing timber buildings with carbon sequestration is a better answer
- Not added to the Fracking’s toxic, chemical and radioactive mixes
- Percolating through fractured rock towards and polluting water sources
- Not piped to the ocean as was suggested by one stakeholder
- Feedstock for other construction industry players: e.g.
Expensive investment at infrastructure level
- Steel, low carbon cement and sequestered carbon aggregate production co-located
- On top of or near to both limestone and Iron ore deposits
- (if this exists anywhere, ideally next to a hydro-electric power station)
- Sharing and reusing waste heat as feedstock for processes
- Generating co-products more efficiently and with net lower carbon
- Steel, Ground Granulated Blast-furnace Slag (GGBS) cement and Aggregates
- Taking care not to use highly polluting toxic waste at core of manufactured aggregate
- Example in South America (Steel and GGBS)
- On top of or near to both limestone and Iron ore deposits
Invest upstream or downstream?
- Where should the cement industry or wider construction industry invest its money and effort, upstream CCS or downstream better buildings?
- g. Passivhaus standards reduced energy demand whilst thermal mass can exploit solar gains and further reduce demands, but only if you know what you are doing and getting it right.
- But most of 27 million homes would need to be refurbished to:
- 80% energy efficiency and a comparable carbon reduction
- or to Passivhaus’s EnerPHit retrofit standard,
- This is a time consuming and socially complex process,
- It has its own set of barriers to overcome.
- GreenDeal the refurbishment programme is not working:
- 5000 properties in 2 years
- Compared to 3000 properties per day until 2050, needed to meet the carbon targets.
- On the other hand CCS has the capacity to improve cement production carbon emissions reduction to a maximum 80%,
- However it is immature technology and consequently expensive to implement, if at all possible.
- There needs to be a bigger stick to bring about these levels of investment,
- So a compromise position is adopted in the latest efficient plants,
- to make them CCS-ready to adopt the technology:
- When the legislation arrives or the economics come right;
- Rather than invest, get ahead of the competition and compete on the global market.
- The share holders could take a short term dip to get a rise later
- CCS needs only to be fitted to 4 players’ plants (an easy job by comparison)
- The EU Emissions Trading Scheme (EUETS) needs to see the value of carbon in as strong a condition as possible and consistent to see the financials work in their favour to successfully carry out this work
- There are no easy answers (but CCS looks easiest)
- We do have to tackle the problems from both ends, its not a choice of one or the other
- To quote Tesco out of context: “Every little helps”.
Market Structure and Technical Barriers to entry
- 4 UK cement manufacturers is effectively an Oligopoly (monopoly of more than one party) of international Parent Companies
- Access to GGBS is restrictive and controlled but already exploited in blended cement
- When competitors with innovative low carbon alternative try to break into this market they are confronted by commercial resistance, looking after commercial interests of the sector.
- Historically industry-lobbied standards committees were used to exclude imports
- But CEN standards have limited their power of influence
- Construction Products Directive (CPD) and Regulations (CPR) prevent Technical Barriers being created to exclude any country or company
- European Union (EU) Procurement Rules (EUPR) prevent exclusion and now permit inclusion of environmental and social issues in specifications and contracts
- So now low carbon cement can be specified in Green Public Procurement (GPP) too.
- The newcomers become the most competent and greenest companies imaginable by necessity to prove their green credentials and competency.
- whilst the establishment procrastinates in their ‘safe’ market failing to maintain highest standards
- The newcomers have to go to great lengths to import via the back door and make supply chains that are not easy to see or to be broken by Business as Usual (BAU) and Status Quo Prevails (SQP).
- They still suffer at the hand of value engineering (posh for cost cutting) and substitution,
- Profits before People before Planet
- But they can also succeed with their lower costs and deliver on Profits and Planet.
- If they import and manufacture locally they can also deliver on People and Planet.
Collaboration for Innovation
- Whilst the Oligopoly’s attention diverted by ‘competition’ they have failed to realise that their competitors are the answer to their problem, if only they knew how to collaborate and innovate.
- GGBS in silos and Blended GGBS low carbon cements in bags are routes to significant carbon reduction across the whole of the industry.
- Blended GGBS low carbon cement enables low carbon construction to be available to the SME builder, the backbone of the industry.
- Blending already occurs at the ready mix plants, this is happening to reduce their costs and whilst the blend stays maximum 65% GGBS, is happening with or without the site engineer’s awareness.
What could you justifiably say about GGBS and Blended GGBS cements?
- I think the following statements are too long for marketing purposes and will still need to be justified with some number crunching but they feel safer statements than some manufacturer’s current straplines.
- © “Whilst concrete is the second most widely used material in the world after water, GGBS as an Ordinary Portland Cement (OPC) replacement has the greatest capacity to improve the environmental impact of the construction industry globally”
- © “OPC replacement with GGBS probably has the greatest capacity to reduce the environmental impact of conventional building than any other material choice”
- © “GGBS cement has the lowest environmental impact of all cements”
- © “Bagged blended GGBS & OPC cement probably has the greatest capacity to reduce the environmental impact of the SME builder and hence the conventional construction industry as a whole”
- © “Its time for all structural/civil engineers to ‘stop permitting and to start requiring’ the use of blended GGBS & OPC in most cement applications”.
- © “Its time for all specifiers to ‘stop permitting and start requiring’ the use of blended GGBS & OPC in most cement applications”.
- © “Its time to ‘start specifying’ the use of blended GGBS & OPC in most cement applications”.
- © “Push for the highest permitted blends of GGBS with OPC since they can work just like OPC”
- If only the establishment could join forces with the SME manufacturers they could be part of all of that.
What are the other options and Research & Development (R&D) opportunities?
- While we are blessed with a market driven industry you have to have a cost driver that makes it economic sense to use less.
- We use too much cement anyway:
- We use too much cement in our recipes
- Why not look more carefully at use of low strength concretes in structural designs: e.g.
- Whilst we specify 30 N/mm2, due to statistics, we routinely see 70 N/mm2 concrete in our buildings
- Just how inaccurate are our concrete mixing plants anyway?
- I am sure they may have a thing or two to say on that
- If beams can be deeper and more slender, the concrete does not have to be so strong,
- and we use less cement.
- Foundation concrete is routinely over specified.
- Alternative materials:
- Also focus on other waste and materials:
- there may not be enough GGBS to go around whilst market penetration is so difficult
- Pulverised Fuel Ash (PFA)
- Volcanic ash,
- Rice husk ash, etc.
- Silica, alumina
- Other pozzolans are available particularly if we thinking globally.
- Magnesia
- Extending cement:
- cement can be very effectively extended,
- but this of course all reduces demand and potentially return on investment in very expensive plant already on the ground.
- Precast options:
- Many concrete products are autoclaved and pre-stressed,
- Key here is modulus and creep,
- Research in these areas may pay dividends
- To see if low cement content mixes can be made to perform.
- Many concrete products are autoclaved and pre-stressed,
- there may not be enough GGBS to go around whilst market penetration is so difficult
- Also focus on other waste and materials:
Credible evidence:
- “Credible evidence, is needed to show Cradle to Cradle impact and benefits”
- They are needed by all to prove their benefits including:
- Real materials and product Life Cycle Assessments (LCA) based on actual information,
- In preference to Environmental Product Declaration (EPD) including some future gazing;
- Display Energy Certificates (DEC) based on actual annual building performance,
- Not Energy performance Certificates (EPC) based on guesswork by inexperienced guessers.
Common metrics:
- Common Metrics are desired by this industry but claimed to be missing;
- EN 15804 is the construction industry Life Cycle Assessment (LCA) method to align all LCA methods in the sector
- An European Commission (EC) mandate for all to align with it within 3 years means we have a consistent metric
- LCAs look at the negative impacts of material and product production
- All LCA practitioners are aligning with it,
- EcoPlatform is a good collaborative effort by all European EPD Programmes
- Old LCA data and EPC certificates need to be replaced by current and consistent data that this change will bring;
- Formerly Building Research Establishment, now BRE’s Environmental Profiles are aligned
- As will Green Guide to Specification;
- But it will remain unfairly biased towards violet materials
- But the more powerful tools needed to analyse the energy efficiency benefits of thermal mass over the life time of the building compared to the embodied carbon in the building
- Are still in short supply or so expensive to be unaffordable by most SMEs
- (SMEs are the vast majority of our bigger industry).
Muddy water:
- EPD are coming but the industry was characterised by poor data collection, the culture is changing and so comparisons should be possible soon.
- But the PE International created sector wide EPD for a non-product, double-generic material is a stop gap that needs to be replaced rapidly with something significantly better;
- Is not only unhelpful:
- no accurate and true data for Building Information Modelling (BIM) tools
- but also misleading:
- All UK cement production is aggregated into one LCA score for a cement that does not exist,
- Low carbon cement statistics making Ordinary Portland Cement (OPC renamed CEM 1) look better than it is
- Low carbon cements burdened by OPC, to look worse than they are.
- There is no incentive to outperform your internal competitors when you can hide behind industry wide averages.
- “Business as Usual” (BAU) and “Status Quo Prevails” (SQP).
Thermal mass:
- No exposure of thermal mass means no exploitation of thermal mass;
- buried thermal mass only offers inter-seasonal stability;
- but surface thermal mass is needed to moderate solar gains over intense hot periods
- night time purging needs to work over surfaces or through hollow ducted/piped construction.
- Clearer accurate and evidence based data on Thermal Mass is needed to tell better stories to willing audiences at exhibitions;
- instead we see full-scale mock-up of concrete buildings with floors, roofs and walls insulated and isolated by carpets with underlay, suspended ceilings and propped floors, wall linings and claddings.
- Side by side with ‘Concrete is good for Thermal mass’ messages
- Presence of concrete does not always offer thermal mass to a buildings performance
- The Cement Industry needs to cut the greenwash and produce better demonstrations and communicate better than this; and its marketers need to be consistent with messages,
- no more Insulating Concrete Formwork (ICF) manufacturers pronouncing thermal mass is irrelevant to give this product some questionable competencies.
Embodied Carbon and Embodied Energy:
- For a while we had the Inventory of Carbon & Energy (ICE) 2008 and its revision 1.6a,
- but by its own admission it is full of inconsistency
- generated by inconsistent LCA methods before EN 15804 arrived
- I converted the datasets into a simplistic whole building calculator
- for Architectural Students to work out their own early designs
- I released this to the professions shortly afterwards, which has proved very popular
- It was all we had until we received:
- WRAP’s Embodied Carbon Database in 2014
- Shaped Earth Embodied Carbon Database in 2014
Decrement Delay:
- This is the time it takes for radiant solar heat gains to pass through opaque construction
- Also known as ‘thermal lag’
- The Concrete Centre (CC) and Arup produced a Decrement Delay calculator
- this enable the justification for choice of relatively high carbon OPC choices in concrete or concrete blocks in conjunction with brickwork or stone with accessories of conventional insulation materials using conventional methods of construction.
- Like BRE tools, it conveniently left out the innovative and modern methods of construction being considered by the wider construction industry,
- so it is another ‘level playing field’ with only the violet team on the pitch:
- denying us the opportunity to discovered the amazing properties of carbon-negative plant based middle thermal conductivity insulation and high thermal radiation insulation
- that make lightweight construction act like heavyweight construction
- And avoid overheating in well thermal conductivity insulated buildings that let the heat in but don’t let it out.
Soft Issues and Hard:
- As for the ‘soft issues’ like:
- Health and wellbeing;
- Good working conditions v absenteeism;
- Good building for education;
- Thermal mass and thermal comfort conditions;
- Views outdoors v solar gain, glare and ability to work v reduced heat loss;
- These are some of the ‘hardest issues’ to tackle.
- We have a long way to go and must work hard to persuade clients of their benefits and even harder to persuade then to spend money on them.
- With the help of the Feeling Good Foundation (FGF) and other health and wellbeing focussed organisations
- They run events bringing together specialists in the human condition;
- g. understanding those spare receptors in the eyes, until recently not understood;
- Those developing the tools to analyse working spaces for ‘worker efficiency attributes’,
- One day we will have these tools too.
Corporate Social Responsibility
- Social Innovation, Social Investment and Social Value issues are beginning to become an important issue for annual business reporting;
- In the past not always for the right reasons: ‘talking the talk v walking the walk’.
- They need to be quantified and the LCA world has been trying,
- More recently bigger drives to create metrics off the back of ISO 26000 are coming,
- Projects like GreenSpecLight.co.uk for the lighting sector could be a model
- EU projects like SEISMIC seismicproject.eu are setting out the framework and engaging communities and business;
- In the UK Social/Earning Ratio (S/ER) and Price/Earning Ratio (P/ER) are developed in seratio.com more will come that get closer to really useful in this sector.
- The Cement Industry should encourage others rather than make their own.
In their absence what do we do?
- In the mean time all of us must keep designing and specifying with gut instinct based on decades of experience tempered by limited Post Occupancy Evaluation (POE) data
- We must continue to learn and adopt new know-how as it is released.
- Data is being collated: PROBE, Usable Buildings, Carbon HUB, AECB’s CarbonLite
- Feedback loops like: RIBA’s new Plan of Work and Government Soft Landings (GSL);
- In time all the sophistication of Building Information Modelling (BIM)
- will come to bear on those that can afford the software
- and the computing substantial Random Access Memory (RAM),
- then the time to learn it and use it.
- Until then we need:
- Training in consistent and comprehensive adoption of BIM principles in design;
- Big data generation,
- Formally organised comprehensive unbiased assimilation
- Open accessibility to all
- Prolific development of the BIM Applications (APPs) to interrogate that data.
- “One day over the rainbow.” 2016 actually.
Missed opportunity?
- I do not see precast or ready mix concrete manufacturers promoting low carbon cement use.
- Is anything being done at sector level to encourage blockwork and precast concrete manufacturers to reduce carbon by cement replacement?
- If anybody should be doing this formally it should be Mineral Products Association (MPA) or the Concrete Centre (CC).
- It would seem nothing is happening.
- Its members might get a bit miffed if it promotes its competitors products, so it won’t.
- Under the Resource Efficiency Action Plans (REAP) for Precast concrete and Ready-mixed concrete promoted by WRAP and BRE this should be a default solution for every company.
- Blended cements with up to 65% GGBS (CEM III/A 52.5L) cement’s OPC content will cause the GGBS content to hydrate and set sooner so its performance reflects that of unblended OPC.
- So any excuses about slow set and slower production, due to longer period until formwork removal, is not valid.
Industry under achievement:
- The construction industry has always been slow to change,
- the normal practice for Structural Engineer’s to issue standard specification covering every material and method permissible as a project specification
- relying on the project drawings to prescribe the materials required, often by performance (concrete strength for example).
- The performance spec allowing the contractor to choose from various recipes of OPC and GGBS
- Their own inexperience or prejudices will steer their decision without full awareness of the facts
- “Permission is not the same as Requirement”
- With the requirements of Environmental Assessment Method (EAM) e.g. BREEAM, Code For Sustainable Homes and their reliance on Green Guide to Specification using LCA at its core has potentially changed this practice for the better
- Big and better practice standard specifications now require for example 40% cement replacement and justification for any reductions that would erode BREEAM materials credits.
- Considering 65% replacement can result in same performance, as OPC or CEM1 this 40% recipe is already very conservative.
- The bigger practices may have dedicated specification teams maintaining the practice specification used by all project teams, but may also have more inertia to overcome
- Smaller practices may be lighter on their toes to keep them up to date, but may not have specialists to keep up to date with recent developments
- But one thing is for sure the level of consistency across the professions will be variable, and many if not most, will not be at the optimum level.
Standards externalise the environmental issues:
- Since British Standards Institution (BSI) and European Standards body (CEN) the standards machines tend to follow industry rather than set standards and are subject to industry lobbying for business as usual (BAU) then the Standards and the Codes only include safe, familiar, tried and tested methods that should not go wrong.
- Like National Building Specification (NBS) they strive for competency.
- Only occasionally the industry discovers an ‘internal’ problem like alkali-silica reaction then the standards machined act relatively quickly to stamp out the problem.
- Sadly it won’t act as quickly in relation to Carbon emissions and relies on Government and other industry initiatives to deal with this ‘externalised’ problem.
National Sector Standard Specifications:
- These include:
- material specific: e.g.
- National Steel Specification,
- recent addition Timber Research and Development Association (TRADA) Timber specification
- Infrastructure sector specific: e.g.
- Ministry of Transport
- Rail Infrastructure
- Do these create barriers?
- Waste Resource Action Programme (WRAP), Institute of Civil Engineers (ICE) and Demolition Protocol when looking at recycled content in hardcore, sub-bases, concrete mixes, discovered that the national specifications had been updated to embrace recycled content but nobody told anybody and everybody assumed recycled was not permitted.
- material specific: e.g.
Industry Authoritative Guidance
- Concrete Centre (CC) publications could be stronger on promoting cement replacement and cemnt alternatives
- but it may not be seen as in the best interest of the UK cement industry’s oligopoly.
- Access to alternatives appear to be restricted.
Risk Aversion:
- Add to this the risk aversion of clients and Professional Indemnity Insurance (PII),
- when clients want to settle for tried and tested methods,
- engineer’s defence can be that the Standards and the Codes have been there ‘forever’
- so reliance on them to be a little more innovative than Business As Usual (BAU) is a very safe place to go
- even if the individual engineer has little experience of blended low carbon or innovative cements.
- A decade ago Aggregates Industries experimented with GGBS cement concrete blocks before blended cements were so readily available and gave up, remaining with secondary aggregate substitution instead.
- Marshalls have now started to report low carbon products in literature.
- Specifiers can expect adoption of ISO 14021, which says data supporting manufacturer self-declarations, need to be available to scrutinise as long as the materials are available and remain in use.
- I will be asking in future.
- Private self-generated green labels may not have a great deal of credibility in the market but those based on Ethical Trading Initiative (ETI) and the likes of Fair trade are probably more credible initially.
Investment & Innovation Opportunities
- EU research is going on and potentially undermines UK industry,
- It makes it easier to invest outside of UK and even outside EU
- The Cement Industry thinks a big cash injection by Government is needed;
- But that may be seen as undermining local competition and SMEs in particular.
- Innovate UK offer 50% to 100% funding for research projects
- HMRC offer R&D tax incentives, Enhanced Capital Allowances for Energy and Water efficiency measures.
- Interreg, Horizon 2020 and LIFE funding offer EU money 50% to 100% depending on the partners and institutions involved.
- What more could be asked for?
- Match funding: which could come out of the sector’s marketing budget
- (£12m per annum last time I looked, probably reduced during the recession?)
- Government will match every million the cement industry invests.
- So what are you waiting for?
- Get building the metrics or tools you want.
- Get developing the CCS now rather than later
Innovation without risk:
- Construction Products Directive and Regulations (CPD and CPR) require use of Proper Materials;
- CEN Standards permit only 27 cement recipes. 27 sounds like a lot to me.
- If the industry feels it’s a strangle hold,
- Then Agrement Certification releases you from this restriction if you fancy Innovation
- It offers Agrement Certification as a route to market,
- Welcomed by designers and Professional Indemnity Insurance (PII) providers
- With Agrement you:
- break the rules,
- establish new rules,
- test the limits of those rules
- set out the new rules and limits in the certificate
- permit others to break the rules, follow new rules and succeed
- This route is not being exploited to escape those restrictions of CEN standards and codes.
- To quote Nike out of context “Just do it”
© GBE NGS ASWS BrianSpecMan aka Brian Murphy
16th May 2015 – 18th May 2015 A00; 19th May 2015 A01; 14th June 2015 A02;