Home Heating (Smokeless Coal)

Radio advertising for Stafford Fuels featured the sound of rain trickling against a windowpane with a wind blowing in the background. The sound of a cosy fire crackling cut through the wind and the rain.

A female voiceover delivered the following information:

“But sometimes you just can’t wait for a wet, windy day. Because on days like that, nothing compares to the warmth of a real fire, fuelled by Stafford smokeless coal.

We’ve been proudly warming Irish homes since 1891, and when only the highest quality smokeless coal meets our standard, you get a fire that burns hotter and longer with 75% less smoke and micro-emissions.

For a greener home, make the switch to Smokeless. Stafford smokeless coal makes it home”.

The complainant challenged the reference to the smokeless coal having “75% less smoke and micro-emissions”.

Issue 1
They said there was no substantiation provided as to how the ‘75% less’ figure was arrived at or what the product was being compared to.

Issue 2
They considered this reference could be interpreted by the public as being the safe amounts required.

Issue 1
The advertisers said that the debate about air emissions and the need to use smokeless coal rather than bituminous (smoky) coal had been ongoing since 1990 when the ban on bituminous coal was put in place to cover Dublin City to combat a very visible smog. Over the last 29 years the ban had been extended to cover over half the population. In 2013, the then Minister for the Environment announced a specific date of 1st September 2018 for a legal ban with a final date beyond which bituminous coal could not be sold or burned as being 1st September 2019.

The advertisers said that there had been much political debate and media coverage of the ban on bituminous coal in the last three years. They referred to the fact that there had also been much recent coverage of new research into the damage of small particle emissions (micro emissions) particularly PM10 and PM2.5. The comparison had been made against bituminous coal in the context of the national debate around emissions and switching to smokeless coal.

The advertisers said that the main purpose of their advertisement had been to get people who were currently using bituminous coal to consider switching to smokeless coal, bearing the upcoming nationwide ban in mind.

With regard to the specific claim made by them in relation to “75% less smoke and micro emissions”, the advertisers referred to the document issued in 2012 by the Department of the Environment entitled “Delivering Clean Air”, as well as providing the document in full, they also provided a table from that document which outlined the relative emission levels for PM10 and PM2.5 versus bituminous coal as follows:

Extract from “Delivering Cleaner Air
Smoky Coal Ban Regulations- Review and Public Consultation”
April 2012 (page 13)


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Fuels	Particulate Matter
	PM10	PM2.5
	kgs
Smoky Coal	11.3	4.3
Anthracite (Smokeless Coal)	1.2	0.3
Smokeless Solid Fuel	2.7	0.7
Peat	11.9	4.5
Wood	12.7	9.0
Home Heating Oil (Gas oil)	0.1	0.1
Natural gas	0.0	0.0

The advertisers calculated the difference in particulate matter for PM10 and PM2.5 as follows:

PM10– smoky (Bituminous Coal) 11.3 Kgs
Smokeless Solid Fuel 2.7 Kg (2.7/11.3) = 23.4%.

PM2.5 – smoky (Bituminous Coal) 4.3 Kgs Smokeless Solid Fuel 0.7 Kg
(0.7/4.3) = 16.3%.

The advertisers also provided information from an article written on Fuel Processing Technology as part of their substantiation. They said that this research provided the following information:
Fuel Processing Technology
Volume 142 (1) , February 2016, Pages 115-123
The impact of fuel properties on the emissions from the combustion of biomass and other solid fuels in a fixed bed domestic stove
E.J.S.MitchellaA.R.Lea-LangtonaJ.M.JonesaA.WilliamsaP.LaydenbR.Johnso

The advertisers said that the following table from the above referenced document demonstrated the fact that there were significant differences in the emission factors reported for the two products PM10 and PM2 .5 as follows:


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Table 6
PM10 and PM25 emission factors for selected fuels by the cyclone method at 170C and comparison with the gravimetric method at 70C
Fuel	Emission factor (mg MJ-1)
	Cyclone			Gravimetric
	PM10	PM2.5		Flaming phase
Wood A	95	91		111
Torrefied briquettes	40	32		69
Peat briquettes	214	210		230
Coal	189	185		313
Smokeless fuel	15	14		30

The advertisers calculated the differences in emissions between the two products as follows:

PM10 – Smoky (Bituminous Coal) 189
Smokeless Solid Fuel 15 (15/189) = 7.94%.

PM2.5 – Smoky (Bituminous Coal) 185
Smokeless Solid Fuel 14 (14/185) = 7.6%.

Flaming Phase emissions – Smoky (Bituminous Coal) 230
Smokeless Solid Fuel 30 (30/230) = 13.0%.

The advertisers also said that there were many other reports written by the Government and Independent researchers all of which showed the efficacy of Smokeless Fuels.

Issue 2
The advertisers said they had at no stage in their advertising made any claims in relation to what the safe levels of emissions should be.

Footnotes:
(1) https://www.sciencedirect.com/science/article/pii/S0378382015301843

Complaint not Upheld.

The Complaints Committee considered the detail of the complaint and the advertisers’ response.

Issue 1 – Not Upheld
The Committee noted that in relation to the claim “75% less smoke and micro-emissions” that evidence had shown for PM10 and PM2.5 that smokeless solid fuel could deliver 75% less emissions compared to smoky coal”.

The Committee noted that the advertisement had referred to “…real fire fuelled by Stafford Smokeless Coal” and “highest quality smokeless coal”. They then noted that the advertisement said, “switch to smokeless”. They considered that the advertisement was comparing “smokeless coal” to non-smokeless coal, i.e. Smokey coal. In light of the information relating to PM10 and PM2 .5, they considered that the claim “75% less smoke and micro emissions” had been substantiated.

Issue 2 – Not Upheld
The Committee noted that the claim had not referred to safe levels but was a comparative against another fuel type. In the circumstances, they did not consider it to be in breach of the Code on the basis of this complaint.

ACTION REQUIRED:
No further action was required in this case.