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| Over 30 years experience of industrial chemical paint and powder coating removal | ||
Overview of some of the Regulations which restrict industry in the use of certain processes and some solvents.This should not be taken as legal advice nor is it necessarily complete. Customers are advised to consult with the appropriate competent authority and take professional advice at the earliest opportunity.
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The European Community Council adopted Directive 1999/13/EC on March 11th 1999 ("The Solvents Directive"). This places limitation on emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations. Certain activities includes "Coating Activities" and "Surface Cleaning". There is a limit of 1 tonne a year for "Surface cleaning using substances or preparations which because of their content of volatile organic compounds classified as carcinogens, mutagens or toxic to reproduction under Directive 67/548/EEC are assigned or need to carry one or more of the risk phrases R45, R46, R49, R60 or R61, or halogenated VOCs which are assigned or need to carry the risk phase R40." This limit applies to the use of highly volatile solvents like Methylene Chloride which has an R40 risk phrase. "Other surface cleaning" has a limit of 2 tonnes a year. The Environmental Permitting Regulations (England & Wales) 2007 which superceded The Pollution Prevention and Control (England and Wales) Regulations 2000 on 6th April 2008. The Solvents Directive is implemented in the UK by these Regulations. If your company is involved in surface treatment of metals or plastic materials using electrolytic or chemical processes and the total volume of the tanks is greater than 30 cu.m then these Regulations apply to you. Such a "Part A(1)"Process will require a permit from the Environment Agency. This permit covers discharge to air, water or land. Guidance for the Surface Treatment of Metals and Plastics by Electrolytic and Chemical Processes gives comprehensive details of the IPPC requirements If your company is involved in Coating Activities and if you are likely to use in excess of 20 tonnes of paint or coating material applied as a solid or 5 tonnes of volatile organic solvents or 1 tonne of halogenated vocs with an R40 Risk phrase in a year then these Regulations apply to you. Such a "Part B" activity has required an LAPPC permit from the local authority since April 1st 2003. This permit will impose an emission to air limit to implement the Solvents Emission Directive.Secretary of State's Guidance for Coating of Metal and Plastic Processes gives a comprehensive guide to this sector. If you are just involved in paint stripping or some other surface cleaning activities then the DEFRA Guide is Secretary of State's Guidance for Surface Cleaning Further useful guidance can be obtained from the Netregs website or Environment Agency - Business section In either case you will need to use "best available techniques". Best Available Technique Schedule 2 of the Regulations lists several ways of determining what is the "Best Available Technique". If you are using chemical strippers, many of the ways listed lead you straight to our processes. For example: -
What do you do?You could ignore it, carry on as you are now and hope it will all go away. Hopefully as you have arrived at our site you have already decided this is not an option. You could think about subcontracting the work out but you are concerned about waiting times, loss of flexibility and there is not a viable subcontractor near you. The exception being alloy wheel refurbishment where individual owners and the motor trade are being increasingly catered for by specialist companies. You could think about stripping by some sort of hot method but you may find your jigs will lose their temper and the work you can do will be restricted to steel. If your work has a complicated shape and you are thinking of trying a fluidised bed, then any hollow cavities will fill with sand. You will incur considerable expenditure and may still find yourself subject to the same amount of regulatory pressure. Any furnace based technique is a prescribed process, may require planning consent and uses lots of expensive energy subject to the climate change levy. Or return to the TOP of the page and click on the link for your stripping process to find our "best available technique"
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