The Industrial Emission Directive (IED) - Driving closed systems in surface cleaning

The European Council Directive 1999/13/EC (known as SED Solvent Emissions Directive or VOC Directive), which Member States needed to transpose into national legislation put into force not later than 1 April 2001, became fully active for all new as well as existing installations on 31 October 2007. The SED was implemented in 2010 into the Industrial Emission Directive 2010/75/EU (IED).

It covers a wide range of solvent-using activities, such as printing, surface cleaning, painting and coating activities, dry cleaning and manufacture of footwear, and pharmaceutical products.

The IED establishes emission limit values for VOCs in waste gases and maximum levels for fugitive emissions for solvent. Although chlorinated solvents have negligible ground ozone formation potentials, they were included into the IED directive because of their overall hazard profile.

For Surface Cleaning the directive is driving the use of enclosed equipment by setting tight emission limits, not only reducing emissions into the environment but also reducing to a high extent the risk for worker exposure. Proper implementation is seen by ECSA as a basic element for gaining and increasing sustainability of the chlorinated solvents.

ECSA is helping users through guidance to properly implement the directive and ECSA member companies are offering the tools to establish closed systems not only during cleaning but also for handling and storage and run the closed equipment with chlorinated solvents in a highly economic manner enabling equipment integrated recycling and constant re-use of the solvents.

To extend the benefit of closed systems and to assure adequate risk control of R45 labelled solvents in surface cleaning also in units below 1mt/year solvent consumption which are exempted from the IED directive, ECSA has developed the trichloroethylene charter (TRI Charter) as an voluntary industry commitment.

Read more on 
The TRI Charter page.

The IED-Directive document (pdf). 

The ECSA Guidance on the Industrial Emission Directive for Chlorinated Solvent Users document (pdf).

DCM & the Ozone Layer

November 2017 

Dichloromethane (DCM) is a highly Volatile Organic Compound (VOC) with a short atmospheric lifetime of only 0.4 years, hence defined as a Very Short Lived Substance (VSLS), but a negligible Ozone Depletion Potential (ODP). Recent publications (e.g. Hossaini et al.) discussed the effect of DCM on the stratospheric ozone, which postulated a high future growth rate of global DCM production and emissions, which led to discussions to include DCM into the Montreal Protocol on the protection of the ozone layer. ECSA and HSIA have provided factual information on global production and emissions by industry, global natural production, behaviour and effect on the stratospheric ozone, and other regulatory developments at a UNEP meeting on the Montreal Protocol in Nov 2017 (available here), based on a scientific assessment of Archie McCulloch (full paper available here; a one-pager summary is also available here).


 

TRI Authorisations granted

September 2018

Trichloroethylene (TRI) can be used safely under controlled conditions. Five authorisations have been granted to BlueCube Germany (a subsidiary of Olin) to continue to produce TRI for specific uses, for example Industrial Parts Cleaning. Customers of this producer can use TRI for these applications under the conditions set by the EU Commission and the defined risk management measures.


 

UBA PMT criteria published

February 2018

The German Environment Agency (UBA, Umweltbundesamt) has published the assessment of "Persistence, Mobility and Toxicity (PMT)" with the desire to protect drinking water sources. Applying conservative criteria for PMT as defined by UBA, perchloroethylene (PER) and trichloroethylene (TRI) appear as number 2 and 3 on the report. UBA also aims to establish PMT as an equivalent concern to identify SVHC substance for authorisation under REACH. ECSA does not consider SVHC identification using PMT criteria as the appropriate tool to improve drinking water quality due to this being a pure hazard based approach and thus does not consider risk. TRI is already listed in Annex XIV (authorisation) and today PER is handled almost exclusively in closed systems with no intentional emission to water or soil. For further information see the ECSA position paper on PER here.


 

New Study on Dichloromethane

February 2018

Together with HSIA, ECSA supported a study to clarify the mode of action of cancer formation for Dichloromethane (DCM). The study results have been published end of 2018. The outcome of the study shows that below the threshold there is no risk of cancer formation related to DCM.

The full paper is available here.