When all’s SED and done
Gavin Bollan, Senior consultant on air quality for WS Atkins, reports on the wider implications of the solvent emissions directive on SMEs
Dry cleaners across the UK could soon find themselves with more than just lost tickets and red wine stains to worry about if, as expected, a new EC directive on solvents is fully implemented this year.
It has been estimated the amount of VOCs entering the atmosphere could be cut by over 30,000 tonnes a year in the UK from presently unregulated sources alone once the directive is fully implemented. The final part of the SED process involves putting small industries, like dry cleaners under the microscope.
Solvents like toluene, present in most household paint, and the carcinogenic benzene, present in petrol, surround us in our everyday lives and the EU wants to reduce the compounds released into the atmosphere by industrial processes.
The directive cuts across a diverse range of businesses from huge chemical plants to the local family-run dry cleaners but whereas the big concerns have been regulated for years, the smaller businesses will have to prepare themselves for more paperwork and expense.
And the hard-pressed Local Authorities charged with regulating these smaller businesses will also have to prepare for a significantly increased workload.
Large Part A1 industries, like power stations and chemical plants already have their SED obligations covered by their IPPC permit and have their emissions regulated by the Environment Agency.
The smaller-scale A2 processes have all their emissions regulated by Local Authorities, who take the EA role.
Again, their SED obligations should already be covered by the existing LA-IPPC regulatory regime.
Smaller Part B industries, like vehicle respray bodyshops, also see their operations regulated by Local Authorities encompassing their SED obligations despite monitoring only their air emissions.
But, these Part B businesses are rated by their capacity and there are numerous other businesses which have ‘slipped the net’ to date but now face having to deal with the new directive.
Most of the companies having to prepare for change are smaller versions of industries which come under regulation but the world of dry cleaning has never before come under the umbrella of solvent emission regulation.
That is all about to change because Defra’s preferred method of extending the SED directive across all sectors of industry – a process they would like to complete to meet an EC deadline by the end of the year – is to expand Part B classifications to cover the smaller operators.
The owners of businesses which come under the SED will have to pay their local authority for an operating permit. They may also face a regular inspection from the pollution officer or environmental health officer and could find themselves having to pay a subsistence charge to fund such visits. Owners and managers could also have to draw up Solvent Management Plans.
These might be no longer than a sheet of A4 but will have to demonstrate an understanding of what goes into and comes out of their process.
While small businesses may not be asked to directly measure their emissions they will have to prove they know the figures they are dealing with.
It also looks likely that they will have to implement a basic management system to demonstrate they have good procedures for dealing with solvent issues and making sure their staff know about them.
This is the sort of thing managers may have told their staff informally in the past but now they will have to show evidence of it.
All of these demands will have financial implications and will make further time demands on managers and owners.
Although the directive could mean a welcome new source of revenue for cash-strapped local authorities it could mean that councils would face a heavier workload to monitor and enforce SED.
An increasing number of businesses will have to be inspected on a regular basis and local authorities may struggle to find the time to fulfill these obligations and write and issue permits.
It will mean an increase in income for authorities but that may be swallowed up by the need to sub contract to outside agencies to meet the increased workload.”
These measures look set to be applied to existing Part B processes (who may also have to deal with stricter emission limits in their LAPPC permits), so most local authorities will be running ever faster just to stand still.
The SED forms part of the EC Air Quality Strategy and aims to reduce VOC emissions from solvent using installations by 57 per cent of their 1990 levels when the regulations come into force in 2007.
In addition to health concerns VOCs are targeted because they are a contributory factor to photochemical smog when they mix with pollutants and sunlight, and most have global warming potential.
It is estimated more than 4m tonnes of solvents are used annually across Western Europe and SED is set to affect around 400,000 solvents users – more than 10m employees across 30 manufacturing sectors.
Solvent industry specialists have estimated up to 90 per cent of the businesses affected are small or medium sized and initially feared the cost of reducing emissions would be as high as ¥80bn.
All in all, getting that suit cleaned could never be the same again.