SEA and Analysis of Alternatives: a pilot study for a metal building application

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1 SEA and Analysis of Alternatives: a pilot study for a metal building application Dr Steve Binks Regulatory Affairs Director International Lead Association

2 Background Pilot SEA completed in December 2008 to gain experience in conducting Socio-Economic Analysis in support of the Lead VRA Focus on potential socio-economic impacts resulting from hypothetical restriction for construction use of metal building material Traditional material used on buildings for centuries and can be found around windows, chimneys and doors, on roofs and in gutters. More than 95% of the material used in construction comes from recycling and it is product of choice because of its effectiveness in protecting against the weather, longevity, and aesthetic properties.

3 Background Study conducted before REACH SEA Guidelines were developed Contracted to consultant with input from a European Sheet Metal Trade Association Took approx 9months to complete Considered the following: The risks from the use of the metal in construction applications and existing and potential measures for further reducing the risk The availability of suitable alternative substances and technologies ( but no separate analysis of alternatives undertaken) Socio-economic impacts resulting from restriction in construction and to endusers (eg owners of buildings) Lost turnover, loss of jobs, impact on waste generation, impact on recycling sector, increased replacement costs, increased maintenance costs etc SEA compared effects of restriction with alternative RMOs such as enhanced risk management options

4 1. Scoping the SEA- Important to Set Boundaries Application Increasing specificity Critical before start the SEA to carefully define what uses should be evaluated so can focus the analysis being undertaken and downstream user involvement Level 1 Use of metal sheet for construction, cable sheathing, radiation shielding, sound attenuation, etc Level 2 Use of rolled metal sheet as a building material Level 3 Use of metal sheet for roofing and guttering in historic, domestic and public buildings Level 4 Use of metal sheet for weather protection of historic and public buildings

5 1. Scoping the SEA- Important to Set Boundaries Identify the Supply Chain Companies mining and processing the metal (~40) Companies manufacturing the metal sheet for construction (<20) Suppliers of the metal sheet for construction (<<100) Companies involved in installation of the product in construction projects (<<<100) Professionals/consumers who purchase the metal sheet (<<1000) Construction and demolition companies that may remove/replace the metal sheet from buildings (<1000) Recycling companies (~40) Other companies involved in management of waste product

6 1. Scoping the SEA- Important to Set Boundaries Evaluate Supply Chains of Alternative Materials Alternatives were identified by Sheet Metal Trade Association commissioning the study and by suppliers of construction materials SEA attempted to involve equivalent players to those identified for the metal sheet application but this proved difficult Set the Time Period Important to select time period reflecting lifetime of the product 75 years chosen based upon LCA data on this material and alternatives Identify What Geographical Areas Need to be Covered EU-27 Imports

7 2. Providing the Baseline Scenario Information (manufacturing and consumption volumes, identification of suppliers etc) gathered from Trade Associations and published sources on Primary and secondary production methods for the metal Uses of the metal Production and use of the metal sheet in construction Key properties of the metal and the metal sheet product Positive attributes Negative attributes Lifecycle Analysis for the metal and other building materials identified as potential substitutes for weather proofing of cavity walls, wall-roof junctions and valley gutters Lifecycle costs for the metal and alternative materials (based on each materials service life)

8 3. Definition of the hypothetical Regulatory Action Assumed Restriction In public spaces (roofing, guttering, flashing etc) In balcony areas In modern buildings (excluded historical or listed buildings) Rainwater harvesting Identify Alternative RMO s Defined by the Sheet Metal Trade Association (with little input from DSU) New installation Maintenance and refurbishment of existing

9 4. Analysis of Impacts Economic Impacts Estimated value of EU market for the metal sheet Cost and benefits of the restriction to all players in the metal supply chain and alternative material supply chains Cost and benefits from the alternative RMOs proposed Environmental Risks Comparison of the metal with alternative materials Durability Recycling LCA comparisons Human Health Risks Comparison of metal sheet vs alternative materials vs alternative RMO s Social Employment, training, skills, consumer welfare (durability, aesthetics, preservation of heritage) Impacts of the alternative RMOs

10 Lessons Learnt Important to define (and limit scope) Pilot was relatively simple SEA as scope was narrow BUT Still took 9 months and produced report >200 pages If using consultants to undertake the SEA do not underestimate the resource (and commitment) required from commissioning organisations external support is unlikely to have the same level of knowledge as those who make/use the substance More difficult to obtain information on risks of alternatives compared to the substance that was the subject of the SEA

11 Lessons Learnt Robustness and credibility of the SEA is dependant upon the quality of the input data.. Good input from metal sheet manufacturers who commissioned the study Underestimated importance of detailed engagement with supply chain downstream of the sheet metal manufacturers This resulted in adoption of many assumptions on benefits of the substance across the whole value chain and high level of uncertainty difficulty in obtaining quantitative evidence of effectiveness of existing risk management measures employed by downstream users Impractical for consultant to visit all relevant sites but need to quantify level of risk and effectiveness of existing and possible RMM difficulty identifying and objectively evaluating alternatives in respect of the technical and economic feasibility for downstream users and reduction in overall risk to downstream users In order to develop a credible SEA need to have access to information on alternatives so that can strengthen information on your susbtance where it is weak or lacking

12 A wise man learns by the mistakes of others, a fool by his own. Thank You For Your Attention!