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- Krupanek, Janusz, et al.
(författare)
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Sectoral Guidance for Chemicals Management in the Surface treatment of metals and plastics Industry : HAZBREF-project Activity 4.1 report
- 2021
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Rapport (övrigt vetenskapligt/konstnärligt)abstract
- BackgroundThe main instrument on EU level to control industrial releases is the Industrial Emissions Directive (IED), particularly through the publication of BAT reference documents (BREFs) and related BAT Conclusions, which is the reference for setting the permit conditions throughout EU for IED installations. However, the BREFs published so far do not contain adequate information on specific hazardous chemicals used and released from industry which makes the control difficult for the industry and the permitting and supervising authorities.One of the case sectors in the HAZBREF project is the surface treatment of metals and plastics (STM). This sector was chosen due to the use of chemicals, potential emissions, the wide range of products as well as technological processes and the upcoming STM BREF review. The other HAZBREF case sectors are textile industry and chemical industry which are addressed in separate reports.The lack of knowledge on the use and flow of specific hazardous chemicals in the industrial processes makes chemical control and reduction measures difficult. The problem is that often neither plant operators nor authorities know which substances are relevant to be treated and which handling measures are needed. Surface treatment of metals and plastics is covered by the STM BREF document, published in 2006. According to the last work programme of the EIPPCB the review of the EU STM BREF is planned to start in 2021.Purpose of the documentThis sectoral guidance contains information on uses of hazardous chemicals, the best practices in chemical management and recommendations on enhancing the permitting process in the STM sector. This document sums up the findings from HAZBREF project and is based on industrial case studies, interviews with authorities and expert judgment. The aim is to describe good practices in chemical management to be utilized by STM installations as well as environmental and chemical authorities. These include technical, organisational and management aspects and concrete tools supporting chemical management.The report addresses the STM sector as a whole in Europe, although the main part of the findings is generated from HAZBREF case installation and other experiences in the Baltic Sea Region. The document provides also general descriptions of BAT proposals related to management of hazardous chemicals and substances. These findings of the guidance will feed into in the forthcoming revision of the STM BREF. They are also to be used for HELCOM recommendations on how to reduce the discharge of hazardous substances into the Baltic Sea.Moreover, the document provides an overview of applicable legal requirements, procedures and other obligations of installation operators regarding use of chemicals and releases of hazardous substances. This includes guidance for tools to identify and assess relevant hazardous substances used and released from the STM installations.Main findings and proposalsImprovement of chemical management systemA Chemical Management System provides a systematic way of managing chemicals through the whole process on the site. Most of the companies have implemented quality management standards such as ISO 9000, ISO 14000, EMAS and integrated EHS programs which also address certain aspects of chemical management. The quality of chemical management systems in the companies differs depending on the scale of operation, ownership and awareness. Integration of good practices of chemical management within already implemented management systems strengthens the ability to reduce environmental risks. HAZBREF project strongly recommends the establishment and regular use of a chemical management system at IED installations.Development of a chemical inventoryThe establishment and maintenance of a chemical inventory is an importantprerequisite for effective and responsible chemicals management in the STMsector. All chemicals and raw materials along with information on their propertiesused in all processes and activities at the site should be listed in a database. Such adatabase is a key part of chemical management allowing for systematic riskassessment, management of chemicals flows and their storage. The information in the chemical list/database must be searchable and should be updated regularly. Most of the information needed is available in the safety datasheets (SDS). If some information is missing from the SDS, the supplier should be asked to provide this. Good routines to handle new and updated SDSs are crucial to have an up to date and reliable chemical database. These routines should involve on-site handling and updates as well as communication with suppliers on how SDSs are delivered. Well-managed chemical inventories can significantly simplify the environmental permit application process both for the operators and the permitting authorities.Better use of Chemical Management Tools and training of stafNumerous references and tools are available to support STM companies and competent authorities in implementing the good chemical management required in the IED. HAZBREF recommends that operators use proper tools for risk assessment and evaluation of the efficiency of chemical management.Use and improvement of risk assessment tools such as extended SDS and material flow analysis should be promoted among installation operators in this respect. The HAZBREF project has developed a comprehensive tool that helps the operators to identify the site-specific hazardous substances that should be considered in strategic and operational decisions.Awareness raising and training of staff in the use of chemical management tools and systems is crucial for implementation of good chemical management practices at the installations.SubstitutionA regular check aiming at identifying potentially new available and safer alternatives to the hazardous chemicals used is an important measure to minimise chemical risks at the installation. A successful substitution work can be performed in four stages: - Identification of hazardous substances - Screening for possible alternatives - Evaluation and choice of alternatives and Development of new alternatives.Substitution can be aimed for any hazardous chemical used at installation level where it is needed in order to protect environment or human health. However, regrettable substitution (i.e. move to use new chemical that is equally or more hazardous than the substituted chemical or results in cross-media effects) must be avoided.Assessment and improvement of SDSEfficient chemicals management requires high quality of the Safety Data Sheets (SDS). The SDS should sufficiently describe the chemical properties and include information about exposure (including use and emissions), eco-toxicology and proper storage and handling. A SDS must also contain information on whether the chemical product contains substances on the SVHC list, priority substances under the Water Framework Directive WFD and the POPs convention. In case a chemical supplier fails to provide a SDS of sufficient quality, it is the duty of both the operator and the competent authority to demand the missing information. This is already required by law in some countries, e.g. Germany. It is also important that the operators know how to extract and consolidate the relevant information from the SDS to their permit applications and verify the quality of different information sources.The development of an extended SDS including exposure scenarios and improved data on environmental effects would facilitate better risk assessment of individual chemicals used in specific processes. This would lead to more efficient monitoring and help focusing on substances of concern. Improved SDSs for raw materials with information on impurities or additives would facilitate more complete chemical inventories.Continuous improvement of BAT implementation The implementation of BAT needs to be continuously monitored and improved at the installation considering site specific technological, economical and environmental aspects. The findings from Polish HAZBREF case studies is that fulfilment of BAT requirements can be challenging if all improvements need to be done in a short time period. For example, closed-loop systems are considered necessary additional process-integrated techniques that it is important to implementstep by step in the installations.Circular economyThe STM sector is a significant user of non-renewable resources (metals), and recycling of recovered metal containing materials such as metal substrates orelectrolytes back to the process is good practice. Such recovery processes are widely used for basic metals, such as zinc, copper and nickel, which are used as valuable secondary raw materials SRM. High costs of recovery processes and high energy consumption as well as the variety of chemicals and metals used in STM processes often hinders recycling. In cases where recycling is not feasible, pretreatment of contaminated waste water on site and subsequent off-site treatment of generated metal containing sludges is standard practice.Permitting processBeside best practices in chemical management, the project also elaborated recommendations on enhancing the permitting process in the STM sector. It can be concluded that the existing general structure and content of the permit application procedures are as such sufficient to deal with hazardous substances and chemicals. Nevertheless, in practice the permit process could be improved with more communication between the applicant and the permitting authority during the application phase. More co-operation between chemical, environmental and occupational health authorities is suggested to achieve a smooth information flow and reduce double work regarding requirements under different legislations concerning chemicals and hazardous substances. In some countries, for example in Finland, the supervising practices in different parts of a given country need harmonising s
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