For anyone dealing with solvents over the past 15 years it will have seemed a period of uncertainty and change.

For most people, manufacturing finished or semi-finished parts inevitably involved solvent cleaning using a vapour degreaser. For the UK at least this was the tried and tested method that could provide consistent results.

During the 1980's you could probably have split users product choice equally into the Trichloroethylene camps.

Then came concerns for the environment. In particular ozone depletion and its potential damage to our stratosphere. Since Trichloroethylene had the greater ozone depletion potential and an atmospheric lifetime beyond 5 years it was phased out. No absolute science existed at the time but a precautionary principle and the alternative availability of Trichloroethylene seemed to provide a necessary response to an uncertain dilemma.

I'm often asked "was it for politics or science?"

I believe the science was never validated if it ever existed. As the years have passed the precautionary principle has 'ruled' and resulted in major debate about the solvent legislation that has followed.

No-one would wish to argue against responsible protection of environment, operators and the community around us. It is of course reasonable to expect a full scientific argument to exist prior to regulation and this cannot always be assumed.

In the end of course we must ensure all legal obligations in law are met to protect our business and show our due diligence.

The trends driven by the European parliament looks set to continue to provide challenges. With a stated intention to test and approve 30 - 100,000 chemical products their own study prepares the UK for a loss of £3.42 billion a year! (see leaflet "your business is under threat" - BCDTA).

The fear remains that no budget exists to ensure a diligent scientific approach. Inevitably our options to achieve chemical cleaning will reduce. The precautionary principle may yet be held as the final word for legislation. I hope it never becomes a substitute for hard science.

Coming up to date the majority of solvent users with a vapour degreasing system will be using Trichloroethylene. Others may have chosen Methylene Chloride or Perchloroethylene as the other alternative chlorinated group.

Beyond chlorinated solvents the fastest growing alternative comes from n-Propyl Bromide technology. All are direct replacements for vapour degreasing. At the onset we must understand one constant thread of solvent legislation. USE LESS. In time a typical solvent user will be 1 to 3 tonnes per annum. That's your immediate challenge.

Trichloroethylene faces the most immediate issues. Why? Because the legislation is in place and you now need to respond to the legal obligations outlined. Two potential areas of solvent legislation that you should be aware of are:

The Environmental Protection Act - 1990 and

Integrated Pollution Prevention and Control (IPPC) - 1999

However, my intention is to focus on two other vital areas:

•  Reclassification of Trichloroethylene by the European Union in June 2001 and

•  The Solvent Emissions Directive (1999/13/EC)

Each has a serious impact on a users continuing ability to use Trichloroethylene.

Oddly, reclassification has been better understood whilst the Solvent Emissions Directive appears to have caused confusion.

One constant of both is that Trichloroethylene must now be considered as carcinogenic under COSHH with an obligation to seek its elimination.

In general your choice of product classifications are:

R45 - May cause cancer

R40 - Limited evidence of carcinogenic effects

R20 - Harmful by inhalation

Our solvent choices fall into the following categories:

R45 - Trichloroethylene

R40 - Methylene Chloride and Perchloroethylene

R20 - n-Propyl Bromide

Debates about the rights and wrongs of classifications can be contentious.

A risk phrase (R) should be created where the potential risk might arise in 'Normal working circumstances'.

At times it may appear that a hazard, albeit highly unlikely, has unfairly been issued a risk phrase. In the end we are required to deal with the established rule of law.

Given the pressures on Trichloroethylene we should now be seeing some impact on its reduced use if the spirit of legislation is being upheld.

Looking at Western Europe back in 1996 101,000 tonnes were in use. By 2000 figures dropped to 74,000 tonnes and thereafter in 2001 to 62,000 tonnes. (a decline in 6 years of 53%). Figures for 2003 are likely 38,000 tonnes with a realistic prediction for 2007 being below 10,000. ( a 90% reduction over 11 years!).

The impact of legislation is clear.

The outcome brings product users back to assessing a suitable alternative. This must always be measured by performance benefits but science is a guide to safety.

Most toxicological studies to consider safety profiles are performed on exposure to rats or mice. These are important. No singular study should ever make another void. Risk assessment involves collecting as much data as possible to produce the best judgement.

One valuable comparative study by Dr Mark Stelljes, Ph.D. acts as one very useful aid. As a world renowned toxicologist with SLR International Corp (Concord CA) who specialises in risk assessment and management he concluded a human in vitro bioassay study of commonly used cleaning solvents. It is considered that this study marks the first time Trichloroethylene, Methylene Chloride, Perchloroethylene and EnSolv (stabilised n-Propyl Bromide) have been selected to an identical set of tests on human cells. It assists on judgement of the relative human toxicity of these solvents.

Most toxic were Trichloroethylene and Perchloroethylene.

Least toxic were EnSolv and Methylene Chloride.

(see full study in technical file of Surface World Issue of July / August 2001).

The real issue of the moment is the Solvent Emissions Directive (SED).

If you are a user of Trichloroethylene, Methylene Chloride or Perchloroethylene in excess of 1 tonne per annum or a brominated solvent in excess of 2 tonnes per annum you have obligations under this directive.

1 tonne represents the following litres:

Trichloroethylene 685

Methylene Chloride 752

Perchloroethylene 617

2 tonnes of n-Propyl Bromide (EnSolv) is 1504 litres .

Falling below these figures would provide the benefit of being exempt from this legislation.

To assist a simple understanding we need to consider some essential questions and answers.

Q Is this a UK directive?

A No. This legislation must be adopted by all European Union countries. Delays will result in infringement penalties. All must keep in mind the principle of this legislation. "The aim is to prevent or reduce the direct or indirect effects of volatile organic compounds (VOC's) into the environment, mainly into air and the potential risks to human health." In essence protection of workplace, environment and the local community is sought.

Q Who interprets the legal obligations under SED?

A The Secretary of State for the Department for Environment, Food and Rural Affairs (DEFRA) determines England and Wales whilst the Scottish Environmental Protection Agency (SEPA) offer advice for Scotland.

Q Who is affected / exempted?

A If you use more than 1 tonne per annum of chlorinated solvents or more than 2 tonnes per annum of brominated solvents you have obligations under SED. If you achieve product levels below these you are exempt under this legislation.

Q How long can I continue to use Trike?

A Trike is not banned for use. However if you currently use in excess of 1 tonne per annum (685 litres) you must seek substitution in the "shortest possible time".

Q Can improvements to machinery extend my use of Trike?

A Only if it places you below 1 tonne per annum and no safer alternative exists. Machinery is not the issue. Product volume is.

Q What if I cannot afford an alternative?

A This is often given as a reason to delay. A period of transition is built in from 1999 to allow companies to plan the necessary change. Given that it is possible to find an alternative a more appropriate question would be "why is it necessary to delay?"

Q What is expected of me?

A Strong advice has been given by DEFRA to determine any obligations under SED and thereafter to create a substitution or reduced emissions plan which will be viewed by the regulator. It is necessary to set your target with a timescale to achieve it. This information will become a public record and will form the basis of future permits to continue using your cleaning system. You should already have your plan in place.

Q What obligations exist for Perchloroethylene and Methylene Chloride?

A No obligation to substitute exists. However to achieve permit status the following emission standards will need to be achieved:

Perchloroethylene 3 parts per million

Methylene Chloride 6 parts per million

n-Propyl Bromide would be 50 parts per million.

Q Is there a final deadline to achieve the emissions target?

A Yes. The absolute deadline is 31 st October 2007.

Q What happens if I change my existing equipment or substantially change my process?

A Under these circumstances you would need to comply with SED with immediate effect. You should take specialist advice before considering changes to avoid any difficulties.

Q Can I delay, awaiting DEFRA guidance?

A Don't be misled by misinformation. Some suppliers promote this idea but guidance is available. A recent guidance document can be viewed on: www.defra.gov.uk/environment/airquality/lapc/default.htm Also see www.defra.gov.uk/environment/airquality/lapc/aqnotes/aq09(04).htm Statutory Instruments already exist to allow prosecution if a wilful abuse is considered to exist. It makes sense to seek compliance. Never forget that this legislation dates back to 1999. Ample time to prepare for adoption.

If you are a Trike user not affected by SED remember you are still required to seek a safer alternative under reclassification regulations. From a 2003 poll of UK companies it was found that the following five primary objectives were commonly sought:

Safe working environment 90%

Reduced solvent emissions 78%

Reduced solvent use 73%

Quality of product 70%

Regard for the environment 64%

These are commendable objectives. With so much legislation to consider always seek the advice of a specialist supplier who offers full technical support. Legislation is often felt to be burdensome but the spirit of intention is good. Working in line with it will bring benefits to your business, not least from the reduced level of product you will need to use to achieve good performance without compromising safety.

By Derek Carpenter - Enviro Tech Europe Limited

Other useful information sites:

www.ensolv.com

www.npb-is-safer.com

www.stowlin.com

 
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