With prevailing issues surrounding the continued use of Trichloroethylene (Trike) for vapour degreasing the same questions seem to arise for users.
Looking at trends in Western Europe the volume of sales has reduced dramatically. (See Graph)
From a starting point in 1998 when 101,000 tonnes were sold the decline by 2003 was to 38,000 tonnes. With predictions set for 2007 to be between 10,000 to 15,000 tonnes this produces a near 90% reduction!
What does this tell us?
Clearly, there is a mass move away from Trike as users recognise the risk of cancer.
A few years ago, chlorinated solvent manufacturers predicted perchloroethylene (Perc) would become the popular alternative to Trike for vapour degreasing.
I repeat what I said then. What nonsense!
Unless users have an unusual application requiring temperatures of 121 ° C this is not a suitable alternative.
Consider some common questions.
Is it right that my supplier encourages the continued use of Trike?
I doubt a supplier would admit to encouraging the use of Trike. The legal position is clear and to conform with the Solvents Emission Directive (SED) legislation users must seek a safer alternative. Suppliers should be discussing other options, generally Methylene Chloride, EnSolv and Perc.
As a user of Trike it is you who must justify why you are unable to replace Trike with a safer alternative.
What legislation must I consider?
Most people are currently trying to understand the Solvents Emissions Directive. (SED)
If you use 1 tonne of Trike p.a. (685 litres) you need to understand your obligations.
Two are very clear.
Firstly , you must replace Trike in the " Shortest possible time"
Second ensure no further use beyond 31 st July 2008 based on reclassification 6 years earlier.
See guidance note : www.defra.gov.uk/environment/airquality/lapc/aqnotes/aq09(04).htm
If you are below the 1 tonne threshold you are not required to register with your local Environmental Office under this legislation, which originated in 1999 and demands compliance by 2007.
Also the EU Cancer Directive requires replacement of Trike and overlaps other legislation. It is unavoidable.
In short, you must substitute with a safer alternative unless you can argue some unique inability to replace Trike.
My supplier says if I use a container system attached to my machine, which holds the drum sealed and protects when filling and emptying, I gain more time to continue with Trike.
Firstly, ask why the drum must be held in a sealed environment?
Does it not reinforce what hazards exist?
You must ask your supplier to fully justify this, since the legal obligations set, are your responsibility not your suppliers .
The risk phrase for Trike R45 - May Cause Cancer is clear.
You gain no performance benefits.
Handling product is clearly part of essential risk assessment. However, never become distracted from the most important area of a vapour degreaser to monitor and assess, the open top area of your machine.
Drum containment was designed primarily for closed systems or similar. Look at product literature that will confirm this.
Ensure proper controls of cooling systems and loading and unloading. These are crucial.
Ask why you might be offered drum containment.
Could it be...
It ties you to the suppliers' product which allows price increases in the future you will be "locked into" them.
Removing their system to resolve this will be problematic.
Always study the arguments put to you.
Get in writing how this system complies with SED and Cancer Directive legislation.
Never be misled.
How can I avoid misinformation?
Be alert. Demand validation.
Confirm things in writing.
Contact an independent specialist in all aspects of surface cleaning such as Core-Chem Limited, Tel 01753 819496. Email sales@core-chem.com
Why has Trike never had a Chemical Hazard Alert Notice (CHAN) issued when other less dangerous solvents have?
CHANs are only advisory. They appear in the absence of an established exposure standard. As Trike has a Maximum Exposure Standard of 100 parts per million and carries the risk phrase R45-May Cause Cancer, this is considered sufficient to guide users to their obligations.
Are there any websites worth viewing?
Look at:
www.stowlin.com
www.core-chem.com
www.ensolv.com
Also remember the DEFRA site listed earlier.
Meeting legal obligations protects staff, community and our environment.
Trike is disappearing. We are already in the eleventh hour.
Taking responsibility may come at a price but paying a price for irresponsibility should be avoided.
© Copyright Enviro Tech Europe Limited. 2005 |
