HAZBREF Project Hazardous industrial chemicals in the IED BREFs

Transcription

1 HAZBREF Project Hazardous industrial chemicals in the IED BREFs Michael Suhr German Environment Agency, Dessau Tel:

2 Background Industrial Emissions Directive (IED): main instrument on EU level to control industrial releases; particularly BAT reference documents (BREFs) for different industrial sectors Gap to be addressed: BREFs do not always contain comprehensive information on specific hazardous chemicals and their abatement measures to guide the work of the permitting authorities or industries 2

3 Objective Identification of relevant hazardous chemicals, their characteristics, use patterns and potential abatement measures in selected industrial sectors covered by the IED Increased understanding of links between different chemical regulatory frameworks (REACH-WFD-IED) Improved [risk] management of hazardous substances and industrial chemicals Systematic methodology and background information for the inclusion of hazardous substances in the review work of BREFs 3

4 Specific objectives Increase knowledge of hazardous chemicals indicated in REACH and other legislative frameworks with regard to their relevance concerning emissions from different industrial processes options for substitution Improved consideration of hazardous chemicals in environmental permits and supervision by local authorities Practical tools for identification and management of chemicals for authorities and installations More targeted actions in HELCOM BSAP 4

5 How? The project will analyze the interfaces, references, links or gaps between the different pieces of EUlegislation and marine conventions, e.g: if the available substance information in REACH can be used in the revision of the BREFs can the information in the data safety sheets to identify candidates of hazardous substances be used under the BREFs for potential regulation can the information collected for BREFs be used in the ECHA framework 5

6 How? Case sectors and case studies Verification of the project desk study results in the real world (case studies) Assessment of sector relevance with regard to potential releases of hazardous substances to the Baltic Sea. Analysis of current practices of environmental permitting and chemical management Analysis of prevention options Both abatement techniques and use restrictions/substitutions Behavior during typical waste water emission treatment evaluated 6

7 Work packages WP1 Project management and administration (SYKE) includes communication and dissemination of results WP2 Identification of target substances (UBA) Selection of target substances Fate of substances during emission treatment WP3 - Policy improvement (UBA) Strengthened links between regulatory frameworks on different levels Developing method to include substance information into BREFs, improve communication & data flow WP4 Best practices in chemicals management in industry (IETU) Selection of industrial sector(s) and case studies Best practices, BAT candidates, supporting tools Analysis of permits and supervision; circular economy aspects 7

8 Information sources BREFs and IED information exchange REACH databases, studies, articles, experts permits different registers Nordic chemical register (SPIN) National registers NGO registers (SIN) other information sources 8

9 Target chemicals REACH; such as SVHC candidate list substances; Authorization list substances (Annex 14); Restricted substances (Annex 17) EU WFD priority substances, others? EPRTR; UNECE CLRTAP Stockholm POP convention; HELCOM recommendations, Baltic Sea Action Plan Emerging substances? 9

10 WP2 Selection of target substances (Lead: UBA, Jan Moltmann and colleagues) Analyze the information on hazardous substances under various regulatory frameworks; REACH, WFD, HELCOM and the Stockholm POPs convention and NGO initiatives. Find data on use, volumes used, substance properties and assess the fate of substances during the use and treatment Develop criteria for the procedure how to identify relevant substances for the IED sectors Output: Identification of the hazardous substances relevant for each IED industrial sector (consideration in the review process of the BREFs) Development of a tool (e.g. Excel-based) that will store the list and criteria to selected substances relevant for each IED industrial sectors 10

11 WP3 Policy Improvement (lead: UBA) Michael Suhr Analyze the interface, synergies or gaps between the different pieces of EU-legislations and HELCOM concerning hazardous substances Analyze different options to include information on hazardous substances into BREFs, e.g. by own chapter or sections on chemicals Consideration of requirements of circular economy in the reflection of information on hazardous substances (?) Outputs: Smoother information flow between REACH and IED and other legal frameworks Guidance for authorities how to act at the interface between the analyzed legislations in permitting and enforcement A methodology for addressing hazardous substances more systematically in BREF process. 11

12 Work packages (back-up slide) WP3 - Policy improvement (UBA) some details Strengthened links between regulatory frameworks on different levels Developing method to include substance information into BREFs, improve communication & data flow Some activities: UBA has commissioned a consultant in order to analyse e.g.: Interfaces between legal frameworks including communication and data flow between key stakeholders (synergies, gaps) communication and data flow between EU institutions responsible for the different pieces of legislation in both directions (IED, REACH, WFD) work practices in Technical Working Groups (TWGs) in different frameworks stakeholders responsible for communication between frameworks compilation of implementation failures and practical obstacles of better linking of provisions of the different legislations and conventions type of implementation failures at national and european level legal, institutional deficiencies or insufficient administrative procedures Outcome: report (Oct. 2018) Includes recommendations & proposals for authorities/operators 12

13 WP4 Best practices for chemicals management in industry: Case sectors and case studies textile industry (Brigitte Zietlow) Increase knowledge on the management of hazardous chemicals via co-operation between operators and authorities Assessment of case studies/sectors and relevance with regard to potential releases of hazardous substances to the environment (also Baltic Sea) Screen BAT techniques and measures for the identified hazardous target substances Identify hazardous substances preventing recycling and reuse in industry Output: Sector guidance reports and case study reports Recommendations for improvement of the chemicals management in the case sectors Description of potential candidate BATs, Recommendations to promote Circular Economy, A permit model concerning chemicals 13

14 Case sectors Textile (TXT) BREF review started in 2018 Waste water Air emissions Surface Treatment of metals and plastics (STM) BREF preparation start in 2019 Waste water Air emissions Chemical industry Selection of sector BREF WGC BREF reviews started in 2017 Other sectors (with different approach) To find best practices with regard to chemicals management (e.g. pulp and paper) 14

15 Partners and other stakeholders Partners SYKE (FI), UBA (DE), SEPA (SE), IETU (PL), KLAB (EE) 27 Associated organizations (support letter): o Ministries and governmental environmental and chemical agencies from EU countries o NGOs (EEB, CCB), WWAs National Stakeholder Groups in every partner country National permitting and enforcement authorities, Chemical agencies Industries and industry organisations, Advisory level: ECHA, EIPPCB, DG ENV, HELCOM, NGO 15

16 Timeline Project started in October 2017 Project concludes September 2020 Kick-off conference 19./20 March 2018 Workshops in the different work packages Case studies Expert meetings Final conference in spring/summer

17 Some points for discussion Question to stakeholders of the textile industry: Do you think the communication, coordination or collaboration should and could be improved? What obstacles do you see to improve the communication and data flow between the communities/stakeholders? Where do you see possible benefits if the communication and coordination between WFD, REACH, IED, Marine Protection (and respective authorities) would be improved? What can you contribute to the HAZBREF-project? Possible HAZBREF pilot actions in Germany and elsewhere in Europe Possible collaborations and involvement of Euratex and Members 17