Rebuttal to Points in MCPS Memo from Superintendent

This document reflects the December 23rd Memorandum from MCPS Superintendent Jerry Weast in response to the PBES Dishwasher Feasibility Study conducted by Burke Design. The indented text highlighted in peach (this color) represents the PBES PTA’s response point by point to the Memorandum.

A pdf file of the December 23rd Memorandum is available at the bottom of this page. Scroll down.

Also see our response to the April letter from Dr. Weast and Mrs. O’Neill (Chair of Board of Education) at Response to April 2010 BoE Letter.

December 23rd Memorandum from Jerry D. Weast, Superintendent of Schools

Subject: Piney Branch Elementary School Dishwasher Feasibility Study (11-11-09-04 and 11.11-09·05)

11-11-09-04
Ms. Berthiaume asked for a staff response on the Burke Design feasibility study for a dishwasher at Piney Branch Elementary School.

11-11-09-05
Mrs. O’Neill would like to see salary and benefits included in the feasibility study for a dishwasher at Piney Branch Elementary School

Response

Staff has reviewed and analyzed the feasibility study for a dishwasher at Piney Branch Elementary School provided by Burke Design that was included in the testimony of the Young Activist Club sponsors at the November 11, 2009, Capital Improvements Program (CIP) hearing. Attached are two documents. Attachment 1 is an item-by-item analysis of the Burke Design feasibility study. Attachment 2 is a comparison of costs between the Montgomery County Public Schools’ (MCPS) estimate and the Burke Design study. Both attachments include salary and benefits costs.

From the analysis, the cost of staff time (including benefit costs) to operate the dishwasher is $11,323. This amount exceeds the total cost estimate in the Burke Design feasibility study of $11,079 that purports to include all equipment and labor costs. This one discrepancy alone is reason to question the validity of the feasibility study and to reject the idea that the use of a dishwasher is a cost-effective alternative to the current practice of disposable trays. When all of the other costs associated with equipment, installation, supplies, and utilities are included, the cost effectiveness of the dishwasher proposal remains unreasonable. Our cost analysis of the project suggests that the cost to install and operate the dishwasher will be about $70,456. This is not a responsible use of school system resources and I will not pursue it.

PBES PTA Reality: The MCPS $70,456 figure for our overall project is grossly inflated. Note, this represents an increase of $13,500 over their previous $57,000 estimate which was already inflated. MCPS maintains that we need a new dishwasher (called “ware washers” by the industry) at a cost of $27,000, that installation costs are a whopping $12,000, and that labor costs are almost twice as high as they in reality are expected to be. These could not be farther from reality. For these reasons alone, we question the validity of the MCPS response to our feasibility project.

In specific, the MCPS $11,323 figure for staff time is inflated. It is based on several unsubstantiated claims, any one of which could be reason to “question the validity” of the response of MCPS. Installation is not $12,000. A new ware washer at $27,000 is not needed. The Burke Design study noted that a NEW Hobart LT1-1 ware washer is available for $4,500 or a NEW Jackson Conserver XL ware washer is available for $3,100. An exhaust hood and ductwork for $15,000 are also not needed.

We are concerned that this represents part of a pattern of the use of inaccurate, inflated or unsubstantiated claims, information and cost analysis which has been a documented problem within MCPS. For example, please see http://www.montgomerycountymd.gov/content/inspectorg/finalreport.pdf, for the Montgomery County Inspector General’s report documenting MCPS giving the Council incomplete cost data on the construction of Seven Locks Elementary. Inflated cost estimates serve to try to kill projects supported by students and community members but opposed by MCPS staff.

Regarding labor costs, MCPS insists that two workers are required by MD Health Code to operate the ware washer. Hobart Corporation (a leading manufacturer and provider of dishwashers), Burke Design, Ecolab (a leading provider of cleaning, sanitizing, and food safety products and services) and other users of dishwashers have never heard of this, nor can we find a Maryland regulation to support this claim, as we have noted for the past year. We have previously requested proof of this requirement from MCPS but none has been presented. This false assumption alone essentially doubles the labor costs. Secondly, the MCPS “time study” analysis of labor requirements included in its Attachment 1 is not based on any actual data and represents mere assumptions leading to inflated time estimates. Our research with Hobart, EcoLab, Burke Design and other dishwasher users have given us alternative information, on which we developed the estimate of 1.5 hours labor per day total for one person – a figure included in the first proposal that was submitted. With the new information presented by MCPS in this round, labor costs should include 54% benefits. This will increase our bottom line by only $1,600 (which is not a significant difference for this community which has pledged to cover the costs of the pilot and has already raised more than $10,000.)

There is every intention to make this a successful project and that includes accounting for appropriate staffing. There is no incentive for underestimating any costs associated with this trial project, as the PBES PTA has committed to covering all costs, especially related to staffing. NOTE: One main goal of the proposed pilot project is to document and track ACTUAL LABOR time.

Dishwashing equipment was removed from schools more than 25 years ago as a cost-cutting measure. Polystyrene trays have been used since that time. The Division of Food and Nutrition Services continually reviews non-polystyrene options for trays; however, these options have become very expensive over the years. As you are aware, the financial status of the Division of Food and Nutrition Services has progressively worsened with the poor economy. The division will end this fiscal year with a $2 million deficit. If the Division of Food and Nutrition Services purchases non-polystyrene trays for student use systemwide, there will be an additional expense to the division of more than $1 million, which will increase the deficit further. The cost of meals to the paying student would have to be increased significantly to cover this additional expense. Although there appear to be some compelling arguments for discontinuing the use of polystyrene trays, the trays continue to be safe, affordable, and are disposed of in an environmentally responsible manner.

PBES PTA Reality: The assertion that this project will increase the MCPS deficit or the cost of providing school meals is absolutely not true. This project in no way will contribute to the MCPS deficit or increase the cost of meals. Our proposed pilot project will actually save the county school system money in the first year as the PBES PTA is paying for all the pilot program and labor costs. Once implemented, the county will immediately start avoiding the cost incurred to purchase polystyrene lunch trays and disposable cutlery for PBES. If the pilot cannot demonstrate savings, there will certainly be no system-wide implementation of ware washers. And even if the pilot succeeds, there will be no obligation by MCPS to act on this data and implement a dishwashing system in other schools (which would require the upfront funding) until funds are available to do so. The refusal to learn the results of the pilot, at no cost to MCPS, continues to puzzle us.

Furthermore, polystyrene for food service ware should no longer be assumed safe and healthy for our children to use and eat on. The public health impacts of styrene — from which polystyrene is made and still contains — are well documented.

Styrene is a known neurotoxin and suspected human carcinogen. Indeed, almost two dozen US communities have banned the use of polystyrene for food service ware in large part due to its health hazards. Outside the US, other jursidictions have gone even further. End users are not the only recipients of health effects from styrene use and production: production workers, communities around production facilities, and the local ecosystems are all negatively impacted throughout the entire life cycle of polystyrene production. See the web sites listed at the end of this document for more information.

All of the MCPS polystyrene trays are currently incinerated in the county waste incinerator further contributing to air pollution and the release of toxics. This is the farthest thing from being “disposed of in an environmentally responsible manner.” For an example of polystyrene’s health impacts when burned, please visit the Firefighters With Parkinsons web page: http://www.firefighterswithparkinsons.net/index.cfm?section=10&pagenum=208.

You may wonder why polystyrene remains in wide use for food service ware if it is linked to such severe health problems. Unfortunately, it takes time for policy to catch up with the science and facts. History proves this: cigarettes, lead-based paint, lead-based gasoline, CFCs in aerosols, arsenic-treated wood, and more recently, bisphenol A in polycarbonate plastic used for baby bottles of all things. It often takes change at the local level to force needed changes at the state and federal level. Polystyrene’s days as a food service ware material are numbered and the sooner the county embraces alternative options, the better. As the head of Food Services for Prince George’s Public Schools said, “The price of oil is only going up… affecting transportation costs, and costs of the trays… In 20 years, everyone will want to be us (with our dishwashers instead of styrofoam trays…).”

If the Piney Branch Elementary School Parent Teacher Association (PTA) feels strongly about the issue of eliminating the use of polystyrene trays in its school, MCPS has proposed a pilot program to allow the PTA to use the funds collected by the Young Activist Club to cover the additional cost to use an alternative type of tray. I hope that they will take advantage of this opportunity to pilot a different type of tray. Given the cost and our already tenuous fiscal situation, I will not proceed with the installation of a dishwasher at Piney Branch Elementary School.

PBES PTA Reality: Kathy Lazor at the Division of Food and Nutrition Services told us at our July 28th, 2009 meeting that the paperboard trays are at least three times more expensive than the polystyrene trays. So using our funds on paperboard trays would not be a pilot because it would not yield any new data, but would simply use up our funds for a temporary solution. We want to use the money we have raised to test the economics of a reusable system, not a single-use disposable system which we know to be more expensive than polystyrene. Furthermore, while other school districts in the country have switched to this type of system, they are piloting the composting of these biobased trays. Montgomery County does not yet have the composting infrastructure to collect and compost biobased lunch trays. Also, to be clear, we have not asked MCPS to install the ware washer or incur any installation or operating costs. All we are requesting is that MCPS allow the PBES PTA to work with PBES school staff to implement the pilot project.

I applaud the spirit of the Piney Branch Elementary School students who believe in their quest to eliminate polystyrene from the environment. However, in reviewing the students’ goals, I must balance the impact of implementing a dishwashing pilot program against the cost of providing food services to all students at their school and all other schools. To me, the choice is clear–the cost effectiveness of the food services program that serves a growing number of free and reduced-price meals to students is a more worthy goal than installing a dishwashing machine that will increase operating costs.

PBES PTA Reality and Conclusion: Given that the pilot has real potential to demonstrate savings to the county, the Superintendent’s conclusion is counter-intuitive. The pilot is just that: a trial program. The concept of this trial program is to test the economic feasibility of and gather data on using reusable lunch trays at an elementary school. The pilot in no way will increase operating costs to MCPS or student meals. Indeed, the PBES PTA’s Young Activist Club is committed to helping save MCPS money. As part of this commitment, Club members will be suggesting additional ways MCPS might try to reduce lunch tray costs and waste. For instance, as part of their research, they have learned that a student-led effort at a MCPS high school in Bethesda resulted in one-third reduction of tray use just by moving the polystyrene trays to a less convenient location. The students worked in concert with staff at that school to implement their idea. If this simple act could be replicated at all MCPS high schools, imagine the positive impact on the Division of Food and Nutrition Services’ looming deficit.

Perhaps more serious is the fact that this MCPS response and false assertion that the pilot program will cost $70,456 represents yet another example of inflated cost data in order to support certain decisions made by MCPS Division of Facilities and Maintenance. The Inspector General’s findings from the Seven Lock’s case were serious: they called for Board and Council action to ensure oversight of financial and other information used to present facility projects and particularly highlighted the need for more complete and reliable cost data to analyze facility construction options. We are deeply concerned by this pattern and question the reliability of data provided by staff to Superintendent Jerry Weast and the Board of Education.

Frankly, it appears that the Acting Director of MCPS Facilities and Maintenance, Mr. Joe Lavorgna, has been against our project from the moment he heard about it and has put forward an inflated cost estimate in order to support this position. Mr. Lavorgna stated during our July 29th meeting that he would “fight us to the end.” It is clear from this statement and all data provided by MCPS staff to date, that Mr. Joe Lavorgna made up his mind to fight the pilot project from the get-go before any on-site analysis was completed. We urge Superintendent Weast, the Board of Education, and the County Council to take action to prevent this sort of decision-making and data manipulation to prevail at the MCPS Division of Facilities and Maintenance. Please push to get our trial pilot program approved so we may proceed to TEST a system with the potential to SAVE MCPS money as well as leverage private money to capitalize improvements. The PBES PTA has raised more than $10,000 to date in private individual, business, and foundation grants. We are committed to undertaking a pilot and to cover all of its costs.

December 14, 2009: Analysis of Burke Design Tray Washing Feasibility Study for Piney Branch Elementary School (November 9, 2009) (hereafter referred to as the Proposal)

1. Space Availability

MCPS Discussion/Question: A number of items are omitted from the proposed Kitchen Design – location of dollies, dish racks, tray storage rack, tray/dish cart – and need to be included in the overall kitchen layout.

PBES PTA Reality: The PBES kitchen has ample space for dollies, dish racks, tray storage, and carts. The proposal can easily be updated to clarify this. There are already 4-6 unused carts/dollies that currently live in the kitchen, including four (4) five-shelf rolling cart racks that could accommodate dishwasher racks with trays, and dishwasher racks for flatware, as well as clean trays.
Also, according to Burke Design, the storage racks proposed by MCPS at $611.00 each (Metro-Max, 5 tier, 18″x60″x72″) can be matched with more affordable metal carts @ $100 each if we do indeed need additional racks, which is not determined at this point given the on-site inventory.

Missing: Proposal design does not address the hand wash sink and needs to specify that it will not be moved or if it must be moved, where it would be relocated and the cost of reinstalling it.

PBES PTA Reality: The Feasibility Study only addresses changes to the current kitchen that would be necessary for the addition of a dishwasher. The current hand wash sink remains in operation in the current location. It does not need to be moved. The Proposal Diagram only illustrates the proposed changes, everything else in the kitchen remains unchanged. This is essentially as simple as installing a new dishwasher into one’s own home.

2. Power Needs, Availability and Cost

MCPS Discussion/Question: It is unclear what type of electricity monitor is proposed or how it will be used.

PBES PTA Reality: The proposal specifically listed a “Kill A Watt” model monitor. By simply plugging in the dishwasher to this monitor, we can assess electricity consumption by the kilowatt-hour, allowing this pilot project to calculate the additional electrical expenses for the ware washer by the day, week, month, or an entire year. These monitors are easy to use and highly recommended. See
http://www.killawattplus.com/?gclid=CO6PyfPD0Z8CFQqF7QodjlnD0A (note price reduction).

3. Water Needs, Availability, and Cost

MCPS Discussion/Question: Water and energy usage cannot be determined until a machine is identified and purchased.

PBES PTA Reality: While it is true that the specific machines will vary in water and energy usage, it is also true that external factors must be taken into account for true accuracy. This is the exact reason the PBES PTA is proposing a trial project to gather specific information in situ. The best we can do now, indeed, prior to an operating trial period, is to go with manufacturer information. In the Proposal, two dishwasher models were identified: the Hobart LT-1 and the Conserver XL. The Hobart machine is representative of the machines we will use, and the specs are similar throughout the field. The Hobart LT-1, as noted in their spec sheet, https://my.hobartcorp.com/resourcecenter/ProductDocumentation/F-8314.pdf, uses 1.7 gal/rack, and it does 37-40 racks/hour. Hobart technicians have verified that the size of the racks is 20″x20″, and the vertical opening is 16″ min; they say that if MCPS is using a 8.5″x10.5″ tray, at least 20 trays will be accommodated per rack, since the trays can easily stand on end and maintain the appropriate spacing for recommended cleaning.

Energy Usage: To reiterate, ware washer manufacturers do not release specific energy use information for low-temperature machines because in actual use it varies by site since the energy usage reflects the water heating capacity. Most low-temperature ware washing machines operate at 120-140 degrees. Energy will be used to heat the water to this level for 1.5 gal x 25 rack cycles. The trial project is needed to monitor energy consumption.

Inaccurate: The proposal estimate for 45-minute total wash time represents a small portion of the total time needed for the complete ware washing process.

PBES PTA Reality:
As mentioned above, the ware washer rate = 37 racks/hour. On the highest numbers of lunch served day (Pizza Fridays), there are approximately 350 trays used for both breakfast and lunch. 20 trays can fit per rack, which equates to 18 racks (which would actually accommodate 360 trays), with an additional assumption that 5 racks would be needed for miscellaneous and flatware. Total of 23 racks are needed on the biggest wash day.

Time Study (with input from Hobart, EcoLab, Burke Design and others)

NOTE: The only way to completely verify this estimate is to engage in the trial project.

6 min Set up, fill dish machine, etc. (30 minutes over the course of a week)
5 min Roll carts of trays from cafeteria to dishwasher

**Students currently do all of the sorting, piling and disposal work at the end of each lunch period.
Nothing would change except that the students would place their trays in a dishwasher rack instead of in a pile in a plastic garbage bag, and, they would place their flatware in sorted racks for spoons and forks. Currently, a PBES staff person spends the entire lunch period for all 3 grades monitoring this process, overseeing correct garbage, recycling and tray loading.

That would also not change. There is every indication that the students who currently sort, dump and stack their garbage, recycling and trays can continue to do so effectively.

36 min 360 trays @ 20 trays/rack =18 cycles @ 1.5 min/cycle (this could be a high estimate)
0 min Pre-rinse: As of now, pizza is served on paper plates, not directly on the trays. No pre-rinsing is
called for. If MCPS would choose to serve directly on the trays, a cost-benefit analysis of paper
plates vs. direct service can be done.
6 min Flatware: 360 meals served x 2 = 720 pieces (assuming all children take both spoons and forks,
which is not likely) @ 200 pieces per rack with appropriate cannisters x 4 cycles (this is a high estimate)
9 min Unload dishracks, stack dishes, 30 secs/rack x 18/racks (30 secs/rack is MCPS number)
0 min Sort flatware — done prior to washing by students
5 min Drain machine (open one plug), clean scrap accumulator (slides out, knock against garbage can), clean drain boards, backsplash with spray
4 min once/week: weekly overall cleaning. 20 minutes total over week if daily cleaning done.
5 min Other: Given the limited nature of use of this dishwasher and part time operator, our consultant operators do not think any time is needed for this on a regular basis, but we leave in 5 min/day (25 min/week) for outstanding issues.

76 minutes total, 1 hour 16 minutes for one staff person.

** In our proposal, labor costs are based on 1.5 hours

Waste Water Removal Discussion/Question: Unclear if the cost of materials and labor for installing the PVC tubing are included in the proposal.

PBES PTA Reality: The cost of materials and labor for installing the PVC tubing are included in the proposal, at the line item “Plumbing Work” with a range $450-$750 from Burke Design’s plumber (includes materials which are minimal). It was estimated at 1/2 to 3/4 of a day’s work billed at $800/day. The proposal includes this although we also have an offer of a donation of time and materials for this installation from a licensed plumber in the community, which may lower our estimate further.

4. Ware Washing Machine–Types and Costs and Ventilation System

MCPS Discussion/Question:
Low- vs. high-temperature machine. COMAR regulations require wares treated with low-temperature sanitizing agents to be allowed to air dry; stacking of wet wares is prohibited. This will add time to the cafeteria worker schedule and may require additional inventory of trays to allow for one set of trays to be in use, one in the dishwashing machine and one drying.

PBES PTA Reality: Air drying is industry standard for this kind of operation. Current washing protocols include the use of a rinse aid that speeds sheeting and drying. Hobart and EcoLab report that trays dry in 30-60 seconds. The PBES kitchen has ample space for air drying racks (note “Wall Racks” in proposal), which were included in the proposal. However, it is likely that as one rack of trays leaves the washer and is moved to the clean table, it will be dry in the time it takes to run the next 90-second cycle. It is entirely likely that in the 90-second wash cycle, the operator could both air dry and stack a rack of trays. If for some other reason, having additional trays is preferred, doing so is easy and affordable. It will take a cafeteria worker seconds to unload each rack onto a cart or wall rack to air dry.

NOTE: To reiterate, the point of conducting a pilot project is to document the actual time it takes for cafeteria workers to operate the ware washer and handle the trays.

MCPS Discussion/Question:
Re: New vs. refurbished machine. Potential lifespan of a machine is determined by the age when purchased. Used or refurbished machines are typically sold “as is” without warranty and require ongoing repairs.

PBES PTA Reality: One of the options stipulated in the proposal is buying a rebuilt machine with a warranty. Hobart itself will come to PBES to certify any machine that we purchase, and then offer a service contract. The cost of certification is based on the following: Hobart charges normal labor rates for any repairs that are needed ($105/hour, with 1/4 hour interval base, and a one-time fee of $98 to walk in the door to do the assesment. If work is needed, that one-time fee is not repeated). The proposal’s costs include a maintenance contract. Hobart offers contracts to certified machines that start at $500/year for the LT-1, which includes all parts except expendable items. If deemed necessary to move forward, we can choose to only buy a rebuilt machine that comes with a warranty. The huge savings that can be realized from buying rebuilt versus new can cover the costs of maintenance and any other repairs for years to come.

MCPS Discussion/Question:

Summary of Buying Options:

Footnotes [3] and [4] indicate that used dish tables “…may or may not be available in the size needed” but final Summary Budget does not allow for purchase of new equipment at nearly twice the cost if used equipment is not available.

PBES PTA Reality: We are in the enviable position of being able to purchase at auction or used equipment precisely because we do not have exacting size requirements. The PBES kitchen is spacious and the available space for the dishwasher so flexible and unconstrained by typical constraints that exist in restaurants or other industries with limited space due to high rents and priority of cooking areas that we can use a wide range of dish tables. Even if we purchase a new dishwasher, there is every reason to purchase as much of the rest of the needed equipment at auction or from a used retailer. Where a 1/2″ width will make or break applicability in a restaurant setting, it will be inconsequential to our application, allowing PBES to save money and be flexible while getting the highest quality product.

[7] Estimated quantity of six dish racks is inadequate–more racks are needed to store trays and utensils while air drying while other racks are in use in the machine and in staging wares for washing.

PBES PTA Reality: See above. Purchase of extra racks is easy, if needed. Note: Flatware serving, storage and washing containers will be one and the same. And, to reiterate, it is entirely likely that in the 90-second wash cycle, the operator could both air dry (30-60 seconds) and stack (30-40 seconds) a rack of only 20 trays.

[11] [12] and [13] Shipping, pickup, delivery costs. Elsewhere in the Proposal the advantage of purchasing a dishwashing machine at auction is touted, yet the summary for shipping, etc., are calculated on the lower estimate of buying used/refurbished equipment ($250) vs. the auction estimate ($700).

PBES PTA Reality: We are not sure what you are referring to, as in the proposal it is clear.
Here is the range we included:

BUY NEW OPTION BUY USED RECONDITIONED OPTION AUCTION OPTION
$5,096 – $6,696 $2,557 – $2,987 $1,219 – $3,816

Subtotal Washing Equip.

Here is what was included in the Summary Budget:
Reused ware washer, spray arms, tray racks, wall unit $3,000

This number, $3,000, is INCLUSIVE of shipping, with a high estimate for the total final cost of $3,000 (rather than the low estimate of $1,219.)

“Please Note” states that purchasing used/refurbished equipment at auction limits the potential for finding the appropriate equipment.

PBES PTA Reality: As noted above, we are in the enviable position of being able to purchase at auction or used equipment precisely because we do not have exacting size requirements. The PBES kitchen is spacious and the available space for the dishwasher so flexible and unconstrained by typical constraints that exist in restaurants or other industries with limited space due to high rents and priority of cooking areas that we can use a wide range of dish tables. Even if we purchase a new dishwasher, there is every reason to purchase as much of the rest of the needed equipment at auction or from a used retailer. Where a 1/2″ width will make or break applicability in a restaurant setting it will be inconsequential to our application, allowing PBES to save money and be flexible while getting the highest quality product.

Missing:
Low- vs. high-temperature machine: Time to allow for air drying of trays and utensils is omitted from this proposal, as is space and equipment to store items during the time they are air drying.

PBES PTA Reality: As mentioned above, air drying does not present a problem. The PBES kitchen has ample space for air drying racks, which were included in the proposal, and for storing items. It will take a cafeteria worker time to unload the ware washer and put the crates of washed trays on a rack to air dry. This is included in the timing section above. We do not believe this will require substantial time and submit that the point of conducting a pilot project is to document the time it takes for cafeteria workers to operate the ware washer and handle the trays.

Missing:
New vs. refurbished machine: Cost of anticipated repairs for a used/refurbished dishwashing machine without a warranty at the expense of MCPS is omitted.

PBES PTA Reality: To reiterate, there is no discussion of utilizing a machine without a warranty or repair contract, and there never has been. One of the options stipulated in the proposal is buying a rebuilt machine with a warranty. Hobart itself will come to PBES to certify any machine that we purchase, and then offer a service/warranty contract. The cost of certification is based on the following: Hobart charges normal labor rates for any repairs that are needed ($105/hour, with 1/4 hour interval base, and a one time fee of $98 to walk in the door to do the assesment. If work is needed, that one time fee is not repeated.) The proposal’s costs include a maintenance contract. Hobart offers contracts to certified machines that start at $500/year for the LT-1, which includes all parts except expendable items. If deemed necessary to move forward, we can choose to only buy a rebuilt machine that comes with a warranty. The huge savings that can be realized from buying rebuilt versus new can cover the costs of maintenance and any other repairs for years to come.

As stated, this pilot project is designed to not cost MCPS anything. The PBES PTA has agreed to pick up the full costs of the pilot, including labor and equipment, and ongoing maintenance.

Missing:
Water filter for new or used/refurbished machines are omitted. All kitchen equipment using water (combi oven, ice machine, steamer) require a commercial water filtration assembly (example: Everpure EV 9797-21A). Most recent bid: $417.84 (9/09).

PBES PTA Reality: According to our research, there is no regulation that requires dishwashers to use filters. Hobart, Burke Design, EcoLab all confirm this. It rests on MCPS to find this regulation. There is a regulation that requires combi oven, ice machine, steamer to use water filters as stated because this water is consumed or comes in direct contact with food, unlike the water in a dishwasher. If there are concerns about water in dishwashers, it is only in relation to scaling, which is appropriately addressed with a deliming cycle, perhaps every 3 weeks if needed, the time for which is included in the once/week cleanings (though it would happen most likely once every 3-4 weeks with the kind of usage that PBES will have.)

Labor: It appears that this Proposal accounts only for labor and omits materials and parts

PBES PTA Reality: See #4 above re: PVC tubing.

6. Cost of Accessories for Necessary Operations

Discussion/Question:
Trays and flatware-Proposal cost indicates very low-end materials. Recommend specifications and/or sample of item to evaluate quality and durability. Knives are typically not provided.

Flatware racks–Cost is grossly understated. The lowest cost of a low-end rack from the company with the current Division of Food and Nutrition Services Small Wares Bid is $23.30 each x 12 racks = $279.60 (Carlisle 34SAI, flatware and 34SA8, trays).

Flatware caddy–COMAR 10.15.03.17, A.I and F prohibits the use of flat, compartment-style utensil holders specified in this Proposal with unwrapped flatware (see Proposal, Requirements/or Storage and Handling of Cleaned Trays and Flatware). A serving line caddy that holds flatware cylinders (example: Hubert silverware holder 80067, $71.29 and silverware cylinders, 51544, $2.29 each x 18 = $41.22 [6 in caddy, 12 in use in ware washing area]) would be required.

PBES PTA Reality: To cost out flatware and trays we looked at the existing process in the PBES kitchen. Flatware is currently served via flat, compartment-style utensil holders, both for wrapped and unwrapped utensils. Upgrading to metal flatware and durable trays is way above the quality of products currently in use. COMAR 10.15.03.17, A.I and F if put into practice would be easily done with flatware cylinders that can go from serving carts to dishwasher, for example: Vollrath 52644 Six Hole Plastic Silverware Cylinder Holder, $28.49 and plastic flatware cylinders @ $1.19 each are readily available (http://www.webstaurantstore.com/plastic-flatware-cylinder/271C35P.html).

Trays are easily and inexpensively purchased at the highest quality online. For example, Carlisle CT1014 Standard Plastic Fast Food Tray case of 24 for $28.99 (http://www.webstaurantstore.com/carlisle-ct1014-10-x-14-standard-plastic-fast-food-tray-24-cs/271CT1014.html). Note: this tray is slightly larger than the trays in service now, but will still fit 20 trays per rack for cleaning.

Magnetic garbage can lid–This type of product has been unsuccessful in both large and small commercial operations in the past in the Division of Food and Nutrition Services staff experience. If used, a minimum of three to four of these would need to be placed throughout the cafeteria as more than one trash can is needed to accommodate the 270 trays used daily at lunch.

PBES PTA Reality: Again, our proposal is based on the reality and current functioning of the PBES kitchen and lunch room now. As noted above in our time study, students currently do all of the sorting, piling and disposal work at the end of each lunch period. Nothing would change except that the students would place their trays in a dishwasher rack instead of in a pile in a plastic garbage bag, and they would place their flatware in sorted cylinders for spoons and for forks. Currently, a PBES staff person spends the entire lunch period for all three grades monitoring this process, overseeing correct garbage, recycling and tray loading. That would also not change. There is every indication that the students who currently sort, dump and stack their garbage, recycling and trays can continue to do so effectively. (We anticipate that this would dramatically reduce overall garbage).

Furthermore, our research and information about the functioning of elementary school lunch rooms indicates that with oversight, as is the current practice in PBES at the waste station, very little mishandling of trays and flatware occurs. In PBES right now, there is one garbage can for dumping of liquids, one can for recyclable plastic, one large bin for trash, and a bag for the trays.

There is no reason to change this. One garbage can with a magnetic rim will serve the lunch room well. If this becomes a make-or-break issue, it is easy enough to purchase an additional magnetic lid.

Missing
Space and equipment to store wares while air drying appear to be omitted. One or two storage racks (example: Metro-MAX, 5 tier, 18″x60″x72″ with casters, $611.00 each).

Dollies for dish racks appear to be omitted. Existing dollies are used for transport and storage of elementary meal hot packs and are not designed for use with moisture and chemicals. The purchase of two to three additional dollies would be needed to move dish racks within the kitchen (example: dolly with handle, Carlisle 572222A, $143.10).

Tray/Dish cart appears to be omitted. A can is needed to move the trays from the ware washing area and for storage and dispensing on the serving line. (example: Intennetro 57DSDII, S554.00).

PBES PTA Reality: All of these items have been addressed above.

7. Operating Costs

Discussion/Question:
Replacement trays and flatware–Industry standard for annual replacement of flatware ranges from 15 to 20 percent depending on the type of operation. MCPS estimates replacement rate at 20 percent.

PBES PTA Reality: Replacement information for use in elementary schools with supervision at the waste stations indicates very low loss and/or abuse of trays and flatware. West VA elementary schools Food Service noted that the only replacement trays they needed were for occasional damage in the kitchen, not from the students’ use. This is not the case for high schools though; for high schools, it would be possible to use the model of colleges and universities that have simply done away with trays altogether (resulting in unforeseen benefits of lower costs overall from reduced food waste, reduced garbage stream, and better eating habits for students). But to reiterate, trays and flatware are inexpensive and easily purchased. If the trial project disproves our 10% allocation for replacement, we commit to purchasing additional items.

Labor
Labor cost of $3,960 is insufficient. The estimate of 1.5 hours per day for a cafeteria worker I is grossly understated. Average daily participation in 2008-2009 at Piney Branch was 74 breakfasts and 269 lunches. The procedure stated in the Proposal of allowing trays to stack up at breakfast and be held until lunch is not recommended for a number of reasons. However, if this procedure was followed, the estimate of 45 minutes for operation time remains unrealistic. The dish rack capacity of 24 trays is overstated, as doubling the manufacturer’s recommended maximum load of 12 would not allow for the space between trays necessary to expose all food contact surfaces to the washing and sanitizing agents per the manufacturer’s specifications.

Time Study –
10 min set up, fill dish machine and check settings, gather equipment.
30 min retrieve trays from cafeteria, load dish racks x 3 lunch periods @ 10 minutes per period
45 min 360 trays @ 12 trays per rack/cycle = 30 cycles @ 1.5 minutes per cycle
3 min Pre-rinse trays [1]
22 min 1440 pieces flatware (720 forks and 720 spoons)@ 100 pieces flatware per cycle = 15 cycles
@ 1.5 minutes per cycle
15 min unload dish racks when dry and stack trays on tray/dish cart @30 seconds per cycle @ 30 cycles
15 min sort 1440 pieces flatware @ 100 pieces per minute
15 min drain machine, clean scrap accumulator, clean drain boards and backsplash
9 min once a week–dean interior and exterior of machine, clean and sanitize storage shelf,
tray/dish cart, flatware caddy: 45 minutes over 5 days
20 min Other [2]

184 min or 3.1 hours TOTAL

[1] No time was included in the Proposal for pre-rinsing, as the type of meal service in elementary schools generally does not require it. However, on pizza days (once a week) or days where other items that are placed directly on the tray are served, pre-rinsing would be required and would add about 12-15 minutes per day minimum (360 trays @ 30 trays per minute). The additional time for pizza day spread over 5 days = 3 minutes per day.

[2] Proposal ware washing schedule allows for continuous operation without deviation, interruption, or break of any kind. A minimum of 20 minutes is allotted daily for interim draining or cleaning of machine (see Proposal, Requirements for Ware Washing Machines, “… machines should be cleaned as often as needed throughout the day… “), restroom breaks, changes in lunch schedule, fire drills, etc.

Actual labor cost is $11,323.07. The average salary of a cafeteria worker I, grade 6, effective July 1,2009, is $13.32 per hour. The 2009 fringe benefit cost for the Division of Food and Nutrition Services was 54 percent and is forecast to increase annually at an undetermined rate.

PBES PTA Reality: To reiterate, as mentioned above, the dishwasher rate = 37 racks/hour. On the highest numbers of lunch served day (Pizza Fridays), there are approximately 350 trays used, including breakfast trays. According to Hobart, 20 trays can fit per rack (of the size that PBES uses); that would be 18 racks (which would actually accommodate 360 trays), with an additional assumption that 5 racks would be needed for miscellaneous and flatware. Total of 23 racks are needed on the biggest wash day.

Time Study (with input from Hobart, EcoLab, Burke Design and others)
NOTE: The only way to completely verify this estimate is to engage in the trial project.

6 min Set up, fill dish machine, etc. (30 minutes over the course of a week)
5 min Roll carts of trays from cafeteria to dishwasher

**Students currently do all of the sorting, piling and disposal work at the end of each lunch period. Nothing would change except that the students would place their trays in a dishwasher rack instead of in a pile in a plastic garbage bag, and, they would place their flatware in sorted racks for spoons and forks. Currently, a PBES staff person spends the entire lunch period
for all 3 grades monitoring this process, overseeing correct garbage, recycling and tray loading. That would also not change. There is every indication that the students who currently sort, dump and stack their garbage, recycling and trays can continue to do so effectively.

36 min 360 trays @ 20 trays/rack =18 cycles @ 1.5 min/cycle (and this could be a high estimate)
0 min Pre-rinse: As of now, pizza is served on paper plates, not directly on the trays. No pre-rinsing is called for. If MCPS would choose to serve directly on the trays, a cost-benefit analysis of paper plates vs. direct service can be done.
6 min Flatware: 360 meals served x 2 = 720 pieces (assuming all children take both spoons and forks, which is not likely)
@ 200 pieces per rack with appropriate cannisters x 4 cycles (this is a high estimate)
NOTE: for some unknown reason, the MCPS flatware number is inflated by a factor of 2.
9 min Unload dishracks, stack dishes, 30 secs/rack x 18/racks (30 secs/rack is MCPS number)
0 min Sort flatware — done prior to washing by students
5 min Drain machine (open one plug), clean scrap accumulator (slides out, knock against garbage can), clean drain boards, backsplash with spray
4 min once/week: weekly overall cleaning. 20 minutes total over week if daily cleaning done.
5 min “Other” Given the limited nature of use of this dishwasher and part time operator, our consultant operators do not think any time is needed for this on a regular basis, but we leave in 5 min/day (25 min/week) for outstanding issues.

76 minutes total, 1 hour 16 minutes for one staff person.

** Burke Design used 1.5 hours in its study for its calculations, which includes an additional 14 minutes a day for any outstanding needs.****Using the above information, 1.5 hours of labor per day is clearly satisfactory. Most days the actual tray use will be under 300 trays per lunch. We have used the highest figures from Pizza Friday to come up with this number, and originally used 190 days as the base, although there are less operational days.

Again, this puts the actual wages at $3,676 for the school year (based on the average salary of a cafeteria worker I, grade 6, $13.32 per hour). With 54% added as the fringe benefit cost for the Division of Food and Nutrition Services, that would be an additional $1,985.21 cost. Total cost of salary with benefits would be $5,561.21 for a year of the trial project. NOTE: This figure is still under the current annual monetary cost to MCPS for the disposable trays and flatware, and does not yet account for health, environmental or other external benefits.

# of days avg hourly rate hours worked/day annual salary annual benefits Total Annual Costs worked per year @54%
184 $13.32 1.5 $3,676 $1,985 $5,561

NOTE:
The MCPS inflated estimate of 3 hours per day needed to operate the ware washer resulted in doubling the labor costs. There is every indication that this is not correct. However, the Burke Design study did not take into account benefits and the 54% benefits rate. Including this, the labor cost increases by only an additional $1,600, which is not a significant difference for this community which has pledged to cover the costs of the pilot and has already raised more than $10,000. Furthermore, the Burke Design budget overestimated some line items such as the chemical supplies and service contract. In addition, the installation may be donated and the actual cost of the dishwasher may be less than the Burke Design budget.

Issue
It appears that the chemical service contract only includes service on the chemical dispensing unit. Proprietary dispensing equipment requires use of the manufacturer’s chemicals. The cost of a service contract for a single unit is most likely higher than estimated.

PBES PTA Reality: Everyone in food service knows that the chemical service contracts for dishwashers are based on the purchase of soap, disinfectants, and other supplies, not on the dispensing unit rental;nor are they the same as a repair or warranty contract that would be carried by a manufacturer or supplier of the dishwashing unit. Contracts for cleaning supplies/chemicals are not carried by Hobart but by a cleaning service contractor like Ecolab. Costs are $0.04 (yes, 4 cents!) per rack washed. If PBES washes 25 racks/day, that is a total cost of chemicals of $1.00 (EcoLab). This includes detergent, a sheeting agent, and a chemical sanitizer. According to EcoLab, a state pricing platform is already in place, you just order what you need and there are no service fees, no contracts, you just pay for what you use.

Our proposal included the $500 for a service contract with Hobart, as quoted above. Thus, the cost for a service contract for a single unit and the detergent/chemicals is most likely significantly lower than our estimate of $1,200.00/year, and more likely to be half of that, a total of $684 ($184 based on $1/day for chems) and $500 for a service contract.

Summary and Recommendations

Please note:
The environmental impact of the energy expenditures and washing and sanitizing chemicals has been excluded from this Proposal.

PBES PTA Reality: We are confident that the environmental benefits of avoiding single-use polystyrene outweigh the environmental impact of washing durable trays. The amount of energy, washing and sanitizing chemicals that will be used in this trial project are minimal, and the impacts well defined and easily managed. Since only 1.5 gal per rack are used, and there would be at most 25 racks/day, that would be 37.5 gallons of water a day to operate the dishmachine. Please see EcoLab’s web site for information about the low impact of the washing/sanitizing chemicals: http://www.ecolab.com/document-library/sustainability-reports/~/media/B2D1111F5A6A4A9EA76086E5BE26AAE2.pdf.

A complete analysis of environmental impacts of disposable trays versus reusable trays would have to take into account many variables in addition to washing and sanitizing chemicals. The environmental impact of the entire life cycle of polystyrene from raw materials (oil and gas extraction) to production (toxic chemicals, poisoned ground water, energy needs, and compromised human health), to use (human and ecosystem health impacts), to disposal (incinerator air pollution, non-biodegradability, and litter) must also be included. All of the MCPS polystyrene trays are currently incinerated in the county waste incinerator further contributing to air pollution and the release of toxics.

The potential adverse health impacts of using polystyrene for serving food to young children may be the most compelling reason to embrace an alternative. According to a 2000 World Health Organization report, “The ability of styrene monomer to migrate from polystyrene packaging to food has been reported in a number of publications and probably accounts for the greatest contamination of foods by styrene monomer.” [Styrene Chapter, Air Quality Guidelines-2nd Edition, WHO Regional Office for Europe, Copenhagen, Denmark, 2000.] See below for some web sites with information on the health impacts of styrene, on communities that have banned the use of polystyrene for food service, and on incineration as one of the largest sources of dioxin (which is one of the most toxic substances known to humans).

As the head of Food Services for the Prince George’s Public Schools, Dan Townsend said, “You either pay for labor and hot water, or you pay for disposables and trash dumping fees. The cost difference appears to very little… We went with dishwashing because it was the right thing to do for safety and sanitation.” Not only that, Dan mentioned, “As styrofoam is a petroleum product, and you also have to pay for petroleum to get it to your site, and it will only be going up in cost… Twenty years from now there will be a lot of people wishing they did what we are doing now.”

Moreover, the Burke Design study did not take into account other potential savings such as reduced trash collection and disposal costs. According to Montgomery County recycling staff, Augustine Diaz, “If you use less trays, because they take so much space, you could save on trips with trash trucks.” A county recycling report noted that a reduction of two trips per depot per week could save 40 hours/per week in staff time (http://www.montgomerycountymd.gov/content/council/olo/reports/pdf/2008-11.pdf). Moreover, this doesn’t take into account reduced costs of fuel and operation of trucks, or the reduced pollution from truck diesel exhaust.

Reference web sites on health impacts:

Firefighters With Parkinsons: http://www.firefighterswithparkinsons.net/index.cfm?section=10&pagenum=208.

Toxicity information on polystyrene leaching: www.ourstolenfuture.org/NewScience/oncompounds/styrene/2001ohyamaetal.htm

World Health Organization information on styrene: http://www.euro.who.int/document/aiq/5_12styrene.pdf

OSHA web site on styrene: http://www.osha.gov/SLTC/styrene/index.html

EPA’s Air Toxics web site on styrene: http://www.epa.gov/ttn/atw/hlthef/styrene.html

Toxipedia web site on styrene: http://toxipedia.org/display/toxipedia/Styrene

Healthy Child web site on styrene: http://healthychild.org/easy-steps/know-your-plastics/

J.R. Whithey, “Quantitative Analysis of Styrene Monomer in Polystyrene and Foods,” Environmental Health Perspectives, Vol. 17, pp. 125-1.53, 1976:
http://www.mindfully.org/Plastic/Polystyrene/Polystyrene-Foods-Styrene-Monomer.htm

World Health Organization information on dioxin (lists waste incinerators among the worst sources): http://www.who.int/mediacentre/factsheets/fs225/en/index.html

Also see, City of Takoma Park, Maryland, Resolution Supporting the Young Activist Club:
http://takomapark.granicus.com/DocumentViewer.php?file=takomapark_327760f7dbf4a780ddca3b751c57b192.pdf&view=1

Summary Budget

See attached table for comparison of MCPS estimate with Burke Design estimate.  Note: The statement that MCPS would be able to recoup a significant part of our initial financial outlay should this pilot be successful is inaccurate. MCPS conducts an annual auction of used equipment from all areas, and historically food service equipment brings in only a few cents on the dollar. In addition, the statement that MCPS would be able to use the double sink that would be removed to accommodate a dishwashing machine also is inaccurate. Double sinks have not been specified in school kitchens since 1997 when the central production facility was built and meals were no longer prepared in school kitchens.

PBES PTA Reality: We stand by our budget. The MCPS budget attachment referenced above is full of inflated figures and inaccuracies. Installation is not $12,000. A new ware washer at $27,000 is not needed. The Burke Design study noted that a NEW Hobart LT1-1 is available for $4,500 or a NEW Jackson Conserver XL is available for $3,100. A ventilation hood of $15,000 is also not needed. Maryland health code clearly states that a ventilation hood is only required for high-temperature ware washers.

We stand by our commitment to cover all expenses for a trial pilot project for up to one year at PBES. We stand by the opportunity for MCPS to save at least $5,000 by allowing this one year project to move forward. We have utmost confidence in our community of support, our unfailing environmental commitment, and the overwhelming desire and necessity of building a greener, more equitable, and healthier future for all of our children.