Regulatory Constraints

2010 May 6
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In any design, there are constraints which must be considered. Some typical constraints are cost, manufacturability, and the properties of materials. One of the aims of the Roaster Project is to minimize constraints to allow for a more innovative design. A category of constraint that cannot be easily minimized is regulatory constraints. In the case of a coffee roaster, the two primary regulatory constraints are product safety and air quality.

Product Safety

The roaster will be a gas powered machine. Furthermore, there are motor-powered rotating components. As such, there are safety issues to consider. The primary risks are risk of fire/explosion, electrical shock, and rotating parts catching a person’s clothes or limbs.

The Town of Gilbert (the town in which we live) generally requires any gas powered machine within a building that can be accessed by the public to be UL approved (or equivalent). UL is Underwriters Laboratory and their purpose is to certify that potentially hazardous equipment has been designed and constructed in accordance with certain safety standards that reduce the risk to negligible levels. We will be using UL Recognized components such as burners, motors, valves, regulators, blowers, and electrical components. These recognized components have been certified by UL to be safely used in systems. The systems (such as the roaster) must themselves be certified as a whole, but the use of recognized components helps. We will not have to send the roaster to UL, which would be very expensive and difficult, but will have it inspected on-site.

The only issue is cost, which will be about $4,500 for the certification process. We’ve already applied for a quotation letter from UL.┬áThere are other certifying firms that are accepted by the Town of Gilbert and we will investigate those, as well.

Air Quality

When coffee is roasted, it causes the emission of particulates (mainly chaff, an outer thin skin on the green coffee bean), volatile organic compounds, and combustion byproducts (carbon monoxide, nitrous oxides). This is accompanied by visible smoke as you roast more darkly and various aromas. These aromas vary during the roasting process from a bread-like baking aroma to pungent “burned toast” aroma for darkly roasted coffee. The aroma of roasting is distinctive and is viewed favorably by many people.

The EPA does not have specific regulations for coffee roasters. It has devolved rule making and enforcement to the local jurisdictions, which must meet overall air quality standards. Our local jurisdiction is Maricopa County. An initial study of their regulations does mention coffee roasters. At The Coffee Plantation, we did not have any emission controls on our 12kg shop roaster. It was generally seen as a pleasant neighbor for the rest of the shops on Mill Avenue. When we opened our roasting plant in Tempe, we added a 1-bag roaster (70kg) and decided that the emissions in an office park would be excessive and added an afterburner to “burn off” visible smoke and much of the aroma.

We intentionally sized the roaster of the Roaster Project to be small enough that emission control shouldn’t be necessary. That’s important because an afterburner uses much more gas than the roaster itself. It must heat the exhaust gas from 400F up to 1,400F to be effective. We could recirculate some of the combustion gases, but I am not convinced that this is best practice for roasting (I will need to study further). In any case, I would buy an afterburner, not design one and it would be connected in-line with the exhaust stack.

Why Comply?

It has been suggested by some that we simply build the roaster, install it and not worry about the regulatory constraints. If we get caught, deal with the problem then. I see two issues with this. First, upon being caught (which is likely), the cost of remedial action will be more than if were just done correctly in the first place. It would involve disassembly, possible redesign, and ceasing operations for an extended period of time. This would damage the fledgling roasting operation and reputation. Second, one must consider the moral implications. Biblically (in Romans), there is the clear teaching of obeying those in authority over you. Since I know the law and am under the authority of the Town of Gilbert and Maricopa County, I am called to obey those laws. The teaching also indicates that their authority is for our own good. Clearly, the Town of Gilbert is guarding the safety of customers inside buildings by insisting on safety law compliance. That’s good for me as a resident of Gilbert and the guy closest to the roaster for the longest period of time. The county is interested air quality for the health of the citizens. That’s good for me also. The only reasons people try to avoid these regulations are cost, additional time, and paperwork, not the inherent goodness of the regulation.

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