Remarkably, as the deadlines set for Solvent Emissions Directive (SED) compliance looms, confusion still exists for solvent users; this summary by Derek Carpenter may help
We might ask then, what questions are people seeking insight on? Chlorinated solvents are affected in two ways.
Trichloroethylene (Trike) needs substitution in 'the shortest possible time.
Methylene chloride and perchloroethylene have emission limits to comply with by October 2007.
If you use above the thresholds listed per annum you will be required to comply and your plan should already be in place.
Trike 685 litres; methylene chloride 752 litres; perchloroethylene 617 litres.
Be clear that this is an issue related to product, not machinery.
Any machine, and that includes hermetically sealed machines, which use in excess of these thresholds is not compliant.
Commenting on user needs recently, Cathryn Parkinson of the Barnsley Regulatory Affairs Department reminded users that they must register and apply for permits with their local authority if they are above the limits.
Should a solvent be reclassified and fall into SED definition, a period of six years applies to develop a substitution plan.
In the case of Trike that time would expire in July 2008 and be subject to permits in any interim.
For some time the argument that substitution is prohibitive due to potential costs is now considered flawed.
Article 7 of SED sets health, safety and environment as the leading priority.
When considering product transfer systems on open top vapour degreasers, remember this will not contribute to your needed solvent reduction programme.
Always weigh disadvantages with advantages in line with your expectations and objectives.
Suppliers report that with rapidly declining Trike sales the situation now exists that more profit comes from collecting waste that the original sale.
Users affected by regular increasing cost may find this hard to fathom.
If you feel unclear, your existing supplier is failing you.
If so, consult an independent specialist.
Take early action on your obligations to avoid difficulties later.
