Make yourself aware of changes to solvent emission regulations
By Peter Morris

 Users of paints - and any other products containing organic solvents - will soon face a further change in the regulations governing the release of solvent into the atmosphere.

The Process Guidance (PG) Notes for the Environmental Protection Act 1990 are undergoing revision to incorporate the requirements of the European 'Solvent Emissions Directive' (SED).

The new regulations are likely to be published later this year, and will start to affect new (or significantly changed) coating installations straightaway. Existing installations will have until end October 2005 to become fully compliant with the new requirements.

The revised regulations will place a greater burden of responsibility on paint users to reduce their solvent emissions. Apart from some possible exceptions, the option of relying on 'Compliant Coatings' only, will no longer be available after October 2005.

By this date, paint users must have taken a number of steps to comply with the new regulations, the first of which is to have in place a functioning Solvent Management Plan. This will require them to keep records of all solvent used in their operation, including solvent used for thinning or cleaning purposes.

In addition, they will have opted for either :-

Putting in place a schedule for direct monitoring of emissions - to demonstrate that the levels of solvent, particulates, isocyanates etc. they emit are below the allowable limits, or Complying through a 'Solvent Reduction Scheme' approach.

The Reduction Scheme is favoured by the regulations, and requires users to demonstrate that they have used less than 'x' weight of solvent in order to apply 'y' weight of paint. The weight of solvent must also include all thinning and cleaning solvent used in the process.

Using information from the solvent management plan and from their suppliers, users can calculate the weight of solvent and of paint they have used - then providing they have not exceeded the ratio of solvent : dry paint (referred to as the 'Target Emission') stipulated in the regulations, they will be compliant.

While the Reduction Scheme sounds complex, it should be relatively easy to implement in practice. However, it is essential that the scheme is well managed on a routine basis, so that corrective measures can be taken throughout the year to avoid non-compliance at the year-end.

For both atmospheric monitoring and the Reduction Scheme, tighter limits apply to larger operations using >15 tonnes solvent / year, than to intermediate sized operations using 5 - 15 tonnes / year. The regulations do not apply at all to small operations using <5 tonnes solvent / year.

There will be a further tightening of all emission limits from end October, 2007.

While the regulations do not permit the industry to return to lower-solids products than are currently being used under the 'Compliant Coatings' VOC limits, there is no doubt that the new 2005 limits - particularly for those in the 5 - 15 tonne / year band - offer flexibility in the construction of cost effective specifications based on a combination of high- and lower-solids products.

For some users, therefore, there could be advantages in opting for the new regulations well ahead of the 2005 deadline.