VOC Regulation / IED

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).

IOELVs for DCM, CTC and PER published

February 2017

Indicative Occupational Exposure Limit Values (IOELVs) for DCM, CTC and PER have been published by the EU Commission (cf. DIRECTIVE (EU) 2017/164 of 31.1.2017), which are in line with the REACH DNEL(inhalation) for workers. 
These IOELVs have to be considered by member states for setting national exposure limits (OELs), which they have to accomplish by 21. August 2018. Only national OELs are legally binding for occupational safety, whereas the IOELVs have to be considered by users in case no OELs is set, yet.  The relevant OELs are provided with the SDS of the solvents suppliers (cf. chapter 8.1). 

 

IARC monograph on DCM

January 2017

DCM has been re-classified by IARC (IARC website) from Group 2B (Possibly carcinogenic to humans) to the next higher Group 2A (Probably carcinogenic to humans). This reclassification from 2014 has been published recently (Dichloromethane).In the opinion of ECSA the reclassification is not scientifically justified. IARC Monograph classifications are also questioned by other associations such as the American Chemical Council (ACC). However the IARC classification is of no regulatory relevance in EU as European legislation is triggered by classification according to the CLP (GHS) regulation (EC 1272/2008).  

 

New Study on DCM

October 2016

Together with HSIA, ECSA supported a study to clarify the mode of action of cancer formation for methylene chloride (DCM). A publication is expected soon in a peer reviewed scientific journal. The outcome of the study shows that below a threshold there is no risk on cancer formation related to DCM.

 

Use of Perchloroethylene is safe in Germany

October 2016

The German federal authorities published a comprehensive guidance on the safe use of PER in dry-cleaning based on German regulations (2. BImSchV in force since 1990). ECSA supported the English translation of this guidance, which is now available on the website of the LAVG, the federal authority in charge.

The exposure study, as referenced in the guideline, proved that the use of PER is safe, if PER is applied according to regulations such as the 2. BImSchV and exposure is very low, well below the current German OEL.