GUIDELINES FOR DEVELOPMENT OF PERFORMANCE CLAIMS
A performance claim should, first and foremost, be meaningful to your customers. It should also be clear and concise. To be verifiable a performance claim must: be measurable using accepted scientific and engineering test procedures/methods; specify the operating conditions under which the claim is applicable; meet minimum Canadian standards/guidelines for the release of environmental contaminants (where a Canadian federal standard is not available, the least stringent provincial standard shall apply); specify the minimum performance that is achievable with the technology, rather than the maximum performance (e.g., an unacceptable claim would state that a technology reduces emissions of a contaminant by up to x%, whereas an acceptable claim would state that a technology reduces emissions of a contaminant by at least y%). Caution: Comparative terms or expressions in a claim such as “better than” or “superior to” would require the applicant to provide quality data for their technology and for each of their competitors’ technologies. Similarly, terms such as “the best” or “the only one in the world” require the applicant to provide quality data on all comparable technologies. Such claims must be considered as not economically verifiable. The expression “improves” would be acceptable if it is used to describe an advancement of the applicant’s own technology and if the applicant has suitable data for both the baseline conditions (prior to the improvement) and for the improved version. In general, and without meaning to restrict creativity beyond the four criteria above, a performance claim should have the following format and elements: “The technology [name], as applied to [effluent, emission, chemical sample, …], under operating conditions [volume flow, temperature, input concentrations, …], will produce [reductions, readings …] of [at least, a minimum of , accuracy criteria, …].” Examples Of Typical Claims That Could Be Verified Are:
- contaminant removal/recovery: a claim specifies that a technology removes/recovers at least 95% of specified contaminants in specified matrices (air, liquid, solid) with specified initial (feed) concentrations. This claim could be verified by providing data on the amount of the contaminants removed/recovered by the technology to the total amount of contaminant treated by the technology. The amount of contaminant could be measured on a mass basis or a concentration basis, and could be expressed per process unit or per unit of time.
- contaminant destruction (conversion): a claim specifies that a technology destroys cyanide in a cyanide-bearing solution to a maximum effluent concentration of 0.01 mg/L, under specified operating conditions. This claim could be verified by providing data on cyanide concentrations in the solution and the effluent.
- mass conversion: a claim specifies that a technology converts a specific quantity (on a mass basis) of a material from a contaminated matrix (such as soil, air, water) to another matrix. The conversion process must not yield extraneous contaminants or by-products which may be deemed contaminants.
- effluent/emission characteristics: a claim specifies that an air pollution control device has an efficiency of 99% in reducing the emissions of particulate matter from a process, under specified operating conditions. This claim could be verified by providing data on the total mass of particulate matter at the inlet and outlet of the control device over a period of time, to allow a mass balance for the system to be calculated.
- product/process characteristics: a claim specifies that a product or process has certain performance attributes.
- resource utilization requirements: a claim specifies that a product or technology uses a specified level of resources to accomplish the environmental performance.
- testing/monitoring equipment: a claim specifies that testing/monitoring equipment can provide quantifiable measurements with a specified accuracy and/or precision and/or efficiency.
- instrumentation: a claim specifies that an instrument can provide measurements and/or control of environmental measurements with a specified accuracy and/or precision and/or efficiency.