Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted AT ge The conditions for Method B only provide a very “soft” digestion with the risk of a large amount of undissolved sample. Especially for the sample types (soil sludge, biowaste and waste) a “stronger” digestion (which is technical possible, see Annex 1 aquaregia for further details) is strongly recommended. That is true; the conditions of microwave digestion will not dissolve the sample totally or to a great amount. The conditions of method B should lead to comparable results according to method A and not to the best available dissolution. (see data report 4.2.2.2, Figures 8-13) see Annex to answers U: validation of additional high temperature method AT 2.1.1 ff ed The VWR art. Numbers of nitric acid and hydrochloric acid are interchanged! This mistake is applied in the whole document! Will be checked VWR art. Numbers removed AT 8.2 te Method B…(at least 100ml???): What is the reason tu use such big vessels for a sample intake of 0,2 – 0,5 g and 6 ml HNO3 and 2 ml HCl??? ..suitable quartz or Teflon vessel… accepted AT 10.2.2 te Raise the temperature of the reaction mixture slowly to reflux conditions: Although the condensation zone will differ between various digestion apparatus no minimum temperature is defined!!! The temperature for Method B is clearly defined! Define temperature for Method A! Boiling temperature is 103 °C AT 10.3.1 ed 7.2 ≠ 8.2 …into the vessel (8.2). accepted AT A.1.1. ff ed The VWR art. Numbers of nitric acid and hydrochloric Will be checked 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 1 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted acid are interchanged! This mistake is applied in the whole document! AT DE A.1.2. 3.8 te Te VWR art. Numbers removed Digestions performed at UBA Wien: Procedure 1: Added reagents are of subboiled quality 2 ml HNO3, p.A., subboiled Heating block or other equipment is missing add accepted 6 ml HCL, p.A., subboiled Is explained in 8, no further definition necessary Not accepted DE 3.10; 3.11 Te Delete paragraphs no deeper information given delete accepted DE 5 Te Delete note This is not an open standard Should be discussed –see NL comments U: Delete note DE 6.1, 8.1 Te Cooking in 10 % nitric acid is not necessary Standing several days is suficient For trace metal analysis cooking with acid should be preferred Not accepted DE 6.1 Te Particle size versus homogeneity and sample intake must be addressed or related to a pre-treatment standard Pb is not volatile under this condition. accepted DE 6.1 Te “…. Some elements of interest can be lost because of precipitation with some ions of the solution. It is the case for insoluble chlorides, fluorides and sulphates for example. In this case the precipitate can be analysed separately.” Aqua regia extraction is a conventional method with regard to temperature, kind of chemicals used and time. Only under strictly following the prescribed procedure comparable results can be achieved, which do not represent the totalcontent. What shall be done with the precipitation? Digestion with fluoric acid? It is only mentioned in interferences that this may occur. The sentence: Delete sentence “In this case the precipitate can be analysed separately.” Will be deleted 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 2 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted DE 6.2 Ed shift this § to10.3 ff microwave digestion DE 8.1 to 8.9 Ed Separate open digestion method A and pressurized digestion in method B and all technical descriptions in sub-clauses. Include description of ISO 11466 for open reflux method A Should be discussed accepted Separation accepted DE 8.5 te modification of the text microwave oven either temperature or power controlled with temperature calibration in combination with pressure measurement accepted DE 9.1 Te “… Samples should be stored in suitable containers with an appropriate closure material. Samples should be kept cold (< 8°C). The sample pre-treatment should take place within 1 month of sampling. Alternatively, samples may be frozen (-18 °C) directly after sampling and kept frozen before sample pre-treatment.” There is no reason that aqua regia extracted elements undergo any change at room temperature conditions (e. g. volatilization ). Should be discussed, for some samples and elements cooling may be necessary Not accepted Delete sentence. DE DE 9.1 9.3 Te Note te For element determination in soil samples cooling to 8 °C or -18°C is not used For soil an other inhomogenous material It is common to grind < 2 mm fraction to < 150 µm prior to aqua regia digestion (ISO 11466). Should be discussed, for some samples and elements cooling may be necessary It is common to grind < 2 mm soil to < 150 µm prior to aqua regia digestion. Revise note related to method A and B Reasons: more homogeneous sample and increased There should be one grain size for all types of samples, therefore 250 µm was proposed (according to the discussion in the Workshop 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 3 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted efficiency of acid attack by increasing the surface area of the particles Inorganic) Not accepted DE 9.3 NOTE te For soil samples it is more common to use the fraction < 150 µm (see ISO 11466). To be discussed. There should be one grain size for all types of samples, therefore 250 µm was proposed DE 9.3 last sentence te “The mass of laboratory samples shall be sufficient …” Change to: “The mass of test sample shall be sufficient …” accepted DE 9.4 te For thermal heating (Method A; sample portion 3 g) the material should contain less than 20 % (m/m) organic carbon. Materials containing more than 20 % organic carbon require treatment with additional nitric acid (see 10.2.2) Method A) For thermal heating under reflux conditions the material should contain less than about 20 % (m/m) organic carbon according to EN xxx. Materials containing more than about 20 % (m/m) organic carbon require treatment with additional nitric acid (see 10.2.2) In this horizontal draft standard an eventual need of additional HNO3 is described in 10.2.2 DE 9.4 te For soil analysis, sample intake for method B should not be smaller then 0,5 g. Fix this sample intake. Delete note, combining parallel digestions is not common. Address pre-oxidation of organic matter. A mass of test portion of about 0,5 g would be preferable. Because of manufacturers’ instructions of different apparatus and the need of taking into account the organic content of the sample this is not possible Note U: 0,5 g is fixed DE 10.2.1 Note Te The relation 3 g to 28 ml aqua regia should be fixed Delete note A mass of test portion of about 3 g would be preferable. Because of manufacturers’ instructions of 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 4 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted different apparatus and the need of taking into account the organic content of the sample this is not possible U: The mass to volume ratio is fixed. DE DE 10.2.2 10.2.2 te Note te The absorption vessel should be filled with 15 ml 0,5 mol/l nitric acid, not aqua regia. fill the absorption vessel with 15 ml 0,5 mol/l nitric acid Should be discussed The time of standing at room temperature should be 16 h to allow a slow oxidation of the organic matter of the material. Ad 16 h standing over night, delete note The experiments showed that standing overnight influence the results evidently, therefore it was necessary to delete this sentence U: accepted U: add Note: The time standing at room temp. may have influence on the digestion rate… DE 10.3.1 te The amount of the test portion should be constant by 0,5 g. The ratio sample / aqua regia is important. Extraction efficiency depends on mass to volume, T, p and time A mass of test portion of about 0,5 g would be preferable. Because of manufacturers’ instructions of different apparatus and the need of taking into account the organic content of the sample this is not possible U: accepted, mass of test 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 5 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted portion fixed at 0,5 g DE 10.3.2 te The microwave assisted digestion should be controlled only by temperature and time not by power. A procedure to establish the relationship between microwave power and temperature for power-controlled systems with pressure measurement has to be added. See water standard…. A test portion of the sample mixed with aqua regia is heated in a microwave oven to a temperature beyond the boiling point (103 °C at 101.3 kPa) and maximum 175 °C. Increase the temperature of the digestion mixture with a rate of 6-10°C/min to a temperature between the boiling point and 175 °C. Maintain digestion for a period of at least 10 min and at most 480 min. The duration of the digestion depends on the final temperature. The conditions of method B should lead to comparable results according to method A. The theoretical relation between temperature and time proved not to be applicable. (see data in chapter 4.2.2.2 of report, Figures 8-13, table 17 ) U: validation of additional high temperature method controlled by temperature DE 10.3.2 Te “…. NOTE If a temperature controlled microwave unit is used the appropiate temperatures of 110 to 120°C should be obtained for about 5 minutes. These are the temperatures that should be reached with the power programme of table 1, otherwise the power should be adjusted to reach these temperatures.” As it is written a sample would only be heated for 5 min at 110 to 120 °C. This definitely woulld not lead to comparable results with reflux extraction, at which samples are heated for 2 h at a specified temperature. Delete or re-write sentence. The experiments and the validation data for sludge in EN 13346 prove that these conditions lead to better comparable results than the theoretical ones.The conditions of method B should lead to comparable results according to method A. The theoretical relation between temperature and time proved not to be applicable. (see data in chapter 4.2.2.2 of report, Figures 8-13, table 17 ) Note rewritten to normative 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 6 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted text with temp. 115±5°C for temperature controlled microwave digestion. U: validation of additional high temperature method DE 7.5, 8.4, 10.2.1, 10.2.2, 10.3.1, 10.3.2 ed wrong reference numbers DE 10.3 ge Waste and biowaste may be rather heterogeneous materials and require significantly more time and effort for homogenization than soil samples. If the mass of test portion is limited to less than 0,5 g there is a high probability that it is not representative for the laboratory sample. That´s why the question: Is the proposed microwave assisted digestion method really appropriate for such materials? To be discussed. Thie time and power settings in table one are only exemplary, different models of microwave systems use different programs. The temperature calibration of the system is to be integrated in this chapter. Table 1: Example of Power/Time Programm DE 10.3.2 Table 1 te Accepted and corrected This depends on the quality of test portion preparation. Therefore an additional reference to EN 15002 was made. U: mass of test portion fixed at 0,5 g Add the description of the temperature calibration Temperature/power calibration is in annex A According to the ruggedness study the temperature /power programme has to be fixed to the extend possible (taking into account that different apparatus are used all over Europe) in order to achieve comparable results. U: validation of additional 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 7 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted high temperature method controlled by temperature DE Annex A Power calibration is only useful if related to temperature under same constellation as sample digestion used delete Temperature/power calibration in annex A is necessary Deleting the power control method as proposed by TG 6 cannot be followed by the author as many labs in Europe have no temperature controlled microwave oven and this method has proven to be applicable alt least for sludges ( EN 13346) DE Annex B This can only be used for open thermal heating method A, method B should be checked for conditions used Microwave digestion should be adapted to the procedure of US EPA 3051A: 175 °C, 10 min time or longer if temperature is lower (same energy transfer) For this round robin test the conditions used for method B were according to Table 1 of horizontal draft standard. But some more precise conditions as prescribed in the new horizontal standard were at this time not prescribed, therefore the data are rather scattered. The EPA method will not lead to comparable results as shown in report 4.2.2.2 U: validation of additional 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 8 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted high temperature method DE Annex B DS Report Fig 3 4 DS Table 7 and 9 ge Data for microwave assisted digestion in a semi-open vessel are of no concern to this draft standard. Revise Annex B. Will be replaced in the final version by the actual validation data It is not clear if the temperature/pressure represents the inner oven or a sample. As the temperature governs the dilution process and as the temperature of pressurized digestion does not exceed 100 – 110 similar temperature curve for the open digestion would be similar? Temperature is usually measured within the sample CV % (repeatability variations) for closed microwave digestion are larger than 10 % for 12 out of the 17 elements in the table, which indicate that the ruggedness of the described digestion is questionable, and reproducibility CV (between different ovens, laboratories) are expected very high. In this table variations of digestion procedures are included Temperature of open digestion usually is performed at the boiling point of aqua regia (103°C) as a consequence performance characteristics are fixed in more detail and open microwave digestion has been deleted from the horizontal draft standard (see report 4.2) Will be replaced in the final version by the actual validation data 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 9 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted DS Table 7 DS Table 11 Open microwave digestion seem more robust that the described closed, however yields for 9 out of 17 elements are lower which indicate that methods are not comparable. Repeatabilities of Hg 20 %, B 70 %, Cd 11 %, Cr 23 % etc. for closed MV are very high. Similar for thermal heating – for e.g. B, Co, Cu, Na, Pb should be remarked as such figures indicate that very high reproducibility standard deviations are expected. Therefore it was deleted in the new version of horizontal draft standard In this table variations of digestion procedures are included - as a consequence performance characteristics are fixed in more detail (see report 4.2) Will be replaced in the final version by the actual validation data DS Table 16 XRF methods results to be quoted with care – may not represent the “true contents”. These data have been taken from the characterisation study of JRC, they are the reference values for this study. In order to check the methods two certified reference materials were analysed in addition (results in annex 2) Will be replaced in the final version by the actual 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 10 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted validation data DS Conclusion DS Clause 8.5 DS General Couldn’t it be questioned if the digestion time can be reduced from hours in the thermal heating method to 30 minutes in the microwave oven methods, without setting strict control of the temperature in the digests during digestion and raising the “mean” temperature? Method B – a focused microwave …. This has be done (See report 4.2.2.2 and 5) Incert option for using oven controlled by temperature (new generation ovens) It is not possible to draw conclusions on the effect of Treatements due to the rather big scatter in the data. accepted More detailed analysis of the data in the report show that some conclusions can be drawn, especially that the performance characteristics have to be fixed in detail. (see report 5) 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 11 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted GB General GB General T T This method is not fit for purpose because it does not refer to the need for additional nitric acid when samples have large amounts of organic matter. Sludges and treated biowastes can contain more than 60% organic matter. EN 13650 notes that samples containing >28%OM will require additional nitric acid. In the classical aqua regia extraction this was assessed visually from the colour of the residue. Lime stabilization of sludge is a frequent type of treatment; this type of material will have a large neutralizing capacity and presumably need more aqua regia, but it is not mentioned in the text. Change the method to fit the Scope of materials Do we really need aqua regia? Evaluation_nitricacid appears to show that there is not much difference in extractability between aqua regia and nitric acid digestion overall, except maybe less “noise” with nitric acid. Some elements are extracted a bit more in one and some in the other. Nitric acid is less hazardous than aqua regia and it is more fit for purpose for high thoroughput automated analytical service providing laboratories. “Pseudo-totals” are operationally defined, Evaluation_nitricacid has shown the methods are more or less equivalent so why not settle on the less hazardous, less noisy nitric acid? Recommend dropping aqua regia because it is intrinsically more hazardous than nitric acid and no advantage over nitric acid extraction. In this horizontal draft standard an eventual need of additional HNO3 is met by reducing the mass of test portion in case of high organic amount or Carbonates in the sample See chapter 9.4 “mass of test portion” and validation data of EN 13346 and 13657, where it was proven that these methods are fit for purpose even for samples with high organic amount In Europe, 4 international standards are broadly used for digestion with aqua regia of similar matrices, EN 13657 is prescribed by European Landfill Directive Could be discussed - See German comments U: Aqua regia method will be validated 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 12 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted GB Evaluation_Aq uaregia T Why is there no reference to: EN 13650:2001 Soil Improvers and growing media – aqua regia extraction? Include this standard in the consideration This has be done in the first horizontal desk study (reference1), EN 13650 can be added in the references of the Evaluation study too GB Title T The title was corrupted in the file on the website. It should reflect the Scope of HOR which is “soils, sludges and treated biowaste” [not necessarily in that order] it is not “biowaste” and it is not “sewage sludge”. Aqua regia is a pseudo-total extract – not total Determination of aqua regia extractable elements in soil, treated biowaste and sludges Should be discussed GB Table of applicability T The descriptions are imprecise – does the method really purport to be applicable to all of these? Improve the precision of this table – the current terminology is inadequate, misleading or wrong. This table is in all horizontal standards, “sediment” and “waste” are outside the scope of HOR Restrict the table to the Scope of HOR, i.e. soils, sludges and treated biowastes The methods were validated for these matrices as cited in the table U: scope limited only to sludge, treated biowaste and soil GB Scope T GB 4 Safety remarks E NL Whole doc Ed The Scope of HOR is Soils, sludges and treated biowastes” - “waste” is outside the Scope of HOR Restrict the Scope of the method to the Scope of HOR Should be discussed “has to be” “have to be” are not standards terminology Rewrite as “shall” “Have to be” is a normative wording too All references should be checked; an addition chapter has been introduced and not taken care of in the references change Has been checked and corrected U: scope limited only to sludge, treated biowaste and soil 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 13 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted NL 1 scope Ge Waste is part of the scope; overlap is imminent. Prevent overlap Has to be discussed U: scope limited only to sludge, treated biowaste and soil NL 3.11 Ed NL 4 safety Ge NL 5 Principle Te Focused microwave is not a common instrument for closed vessel digestion Toxic is not true for these chemical; the general description is harmfull The fixed 20 min period for digestion in closed vessel is not common practice in the lab; several other studies (see work for ie ISO TC 147) show other relations between time and temperature that can be applied. remove accepted Change in harmfull. accepted The conditions of method B should lead to comparable results according to method A. (see data in chapter 4.2.2.2 of report, Figures 813, table 17 ) U: validation of additional high temperature method NL 5 note Te What other heating devices are meant? Specifiy ie autoclave etc Should be discussed see DE comments (delete this sentence) U: Delete note NL 6 Ge NL 8 Te Part of the information is (or should be) part of other standard like sample containers etc. Method B: Quarts vessels are not suitable for these matrices. The nominal volume of the vessel is set at 100mL. A very commonly used microwave has vessel of nominal 50 mL and is excluded by this criteria. Make a reference to other standards accepted Remove quartz and nominal vessel volume. Partly accepted, quartz proved to be suitable in some labs, 100 ml deleted 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 14 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted NL 8.5 Te Focused microwaves are not common equipment. NL 9.3 Ge The grain size is fixed at 250 um; refer to sample prep standard but can not be achieved by mixing of sludge Remove focused accepted Partly accepted Sewage Sludge is usually totally dissolved by aqua regia even without particle size reduction (see EN 13346) NL 9.4 Te The amount of C is also linked to the amount of nitric acid used. Yes, the amount of HNO3 is fixed NL 10.3.2 Te The described method deviates from other studies on MW digestion (water, EPA etc); the prescribed temperature is to low for the time stated. The relation between temperature and time has been investigated before and is missing. The conditions of method B should lead to comparable results according to method A. The theoretical relation between temperature and time proved not to be applicable. (see data in chapter 4.2.2.2 of report, Figures 8-13, table 17 ) U: validation of additional high temperature method 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 15 of 16 CEN electronic balloting commenting template/version 2001-10 Date: Document: 2006-09-30 Digestion of solid matrices. Part 1:Digestion with aqua regia 1 2 (3) 4 5 (6) (7) MB1 Clause No./ Subclause No./ Annex (e.g. 3.1) Paragraph/ Figure/Table/ Note (e.g. Table 1) Type of comment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted 1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. FR for France; comments from the CMC editing unit are identified by ***) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 16 of 16 CEN electronic balloting commenting template/version 2001-10