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News Release from: Enviro Tech Europe | Subject: Solvent use - question of trichloroethylene
Edited by the Manufacturingtalk Editorial
Team on 20 November 2007
Trichloroethylene - is guidance biased?
In essence the enforcement agencies are tasked with protecting solvent uses and say their advice is consistent and reliable - but are they biased or responsible asks Derek Carpenter.
Breathtaking Bias or Responsible Guidance? In a remarkable twist of events, former users of trichloroethylene have been left gasping by an announcement, seemingly supported by HSE, DEFRA and the Environment agency These are the enforcement agencies tasked with protecting us and who say their advice is consistent and reliable
This article was originally published on Manufacturingtalk on 7 Apr 2008 at 8.00am (UK)
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Sadly the numbers of population raising doubts about this is continuing to grow.
As you read this you may already be hearing a voice in your head that confirms you are already a sceptic.
I, like everyone, have the desire to offer my trust to these organisations but sadly I have had such trust destroyed in recent years.
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While users are keenly interested in the advantages of process cleaning, they can be confused by the amount of misinformation that seems forever presented to them, writes Derek Carpenter.
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Rigorous performance testing has enabled a solvent cleaning product to become the favoured choice for former aerospace manufacturing users of the carcinogen trichloroethylene.
Updating the use of trichloroethylene in factories
On the regulated use of trichloroethylene in European industry, Derek Carpenter writes that he had never seen more confusion resulting from the guidance given to users.
I ask myself whether these institutions have lost their way or whether we are being let down by a handful of staff who have long since moved beyond good reason? I hate politics in anything, rife as it is, so I won't dwell, other than to wonder what lobbying exists that is so powerful as to corrupt credibility and lead to bias.
Before anyone rushes to claim innocence, I ask them to step into the real world and at least consider the complete perception given by recent actions.
It's for them to justify a stance that has not been left in doubt but it's for the rest of us to judge what drives such a stance.
If you need some background to my comments visit the Surface Engineering Association Web site, which lists a Voluntary Scheme for users of trichloroethylene.
A report is covered in their Autumn 07 edition of 'Watchword'.
There, you will see each of the organisations logos I mention above.
It begins with a note of a meeting in which HSE provided a Trichloroethylene Working Group, quoting clearly some connection to the Solvent Emissions Directive (SED).
This meeting was not notified to the wider industry, who had an interest in this subject, something which is becoming all too common.
Never forget HSE was a limited voice in Europe to oppose reclassification of trichloroethylen ('trike') so their acceptance of it appears to remain alive.
Having written to DEFRA I should quote their response as follows: 'The reference to 2010 you mention would seem to align with a voluntary agreement for health and safety purposes, unrelated to SED'.
My first question of DEFRA then is obvious: "If, as enforcers of SED you say it is unrelated to SED, why is your logo used as support for the scheme along with HSE and the Environment Agency?" Having written to HSE twice I await a response.
* History - let's begin first as far back as the 1990s.
Those of us involved in legislative issues for solvents were faced with two issues.
1 - As a carcinogen, trichloroethylene became affected by the law governing the use of carcinogens to comply with EU Directives.
What was the aim? To move away from it by substituting the product.
2 - The Solvent Emissions Directive of 1999 (1999/13/EC) set the rule that use in excess of 1 tonne per annum of a carcinogen allowed a six year compliance period to seek substitution.
Contrary to October 2007 being held as that date for 'trike', it is more accurate under this legislation to have July 2008 as the deadline.
Hundreds of companies have complied already, under great pressures from local authorities, to meet these legal requirements.
No wonder then that this responsible and pro-active group are fuming at recent events.
* Why is there such a fuss? Having pressed for substitution by mid 2008 with sales fast diminishing, we now hear of a 'saviour' scheme for 'trike'.
In spite of clear legal obligations it seems it is now suggested we can relax our concerns, but whose interest will it serve? We are told the European Chlorinated Solvents Association (ECSA) has pro-actively worked with EU authorities to develop an industry wide voluntary commitment on the use of 'trike'.
Of course they have.
The alternative is to lose sales.
As ever the EU is being used to make decisions affecting us with no consultation.
The clue is in the framework, which says: "To safeguard the long term sustainable use of 'trike'." Knowing a question of who it safeguards, given that it is a carcinogen, would arise, the scheme proposes the use of closed systems, which are expensive and not overly popular or convenient in the UK.
Process times are very long.
On this matter DEFRA comment that the machine is irrelevant to SED as you are required to seek substitution when using over 1 tonne per annum.
I can vouch for modern open top systems achieving this as well, if not better, than closed systems.
I know of closed systems using in excess of 5 tonnes per annum where open tops use 5 to 7 litres per week.
Don't be misled.
Exceed 1 tonne per annum of 'trike' in any machine and you must comply with substitution demands.
So, here we have our first 'red herring' with no comparative data in the UK to support high investment in this system.
Of course the original question arises of DEFRA.
Why are you involved with supporting this scheme then as you rightly admit it does not generally impact on SED issues? * Closed 'trike' systems - the scheme asks remaining 'trike' users to sign up by December 31st 2007 to the idea of committing to purchasing a closed system.
By when? - December 31st 2010.
If signatures are not forthcoming by the end of 2008 can we expect the dates to be extended? Even more relevant, can anyone who has already signed give notice of withdrawing? In essence Trike gains 2.5 extra years beyond the original dates set for moving to an alternative.
During this period there is no greater protection for health or environment but there are of course 'winners'.
These are the suppliers of 'trike' who pretend no alternative exists for your current 'trike' process.
This is total rubbish.
Another issue raises itself.
HSE, DEFRA and the Environment Agency give the perception that their approval removes your liabilities.
Your Lawyer would be clear it does not.
We seem to have reached a point where our enforcing agents seem to say their interpretation no longer demands the compliance with legal directives.
God help us then since power alone will rule our lives.
This cannot be allowed to go unchallenged.
There will no longer be a place for their accountability, and in no time at all we will not be able to continue in business or expect concern for our protection.
'They' say always to read the small print before giving your signature.
Never has their been a better time to heed this with regard to a voluntary scheme which safeguards your supplier.
* Consultation is important - always consult an independent process specialist with regard to your process needs before signing up as a prisoner to a scheme you may well regret.
I await an explanation from the organisations at the heart of this scheme to argue their case with transparency, never forgetting the story of the 'donkey is led to water'.
Personally, I think the 'water' they offer is badly contaminated.
I also encourage Trade Associations to stop listening to one voice alone and embrace fuller opinion on advice for their members.
Encouraging the continued use of 'trike' is not a responsible message and I doubt the people advising it would ever want any member of their family to work with this product when safer methods exist.
* Notation - for the purpose of clarity I declare the interest of Enviro Tech Europe Limited in this matter as the supplier of EnSolv within Europe, as we are currently awaiting hearing dates in the European Court of First Instance in which challenges are being made against EU decisions we consider to be illegal with regard to reclassification of n-propyl bromide, the base chemistry of EnSolv, a product approved by Boeing for aerospace vapour degreasing.
For further details see www.npb-is-safer,com and www.ensolv-europe.com * UK enforcement agencies - for many years, UK enforcement agencies have pressed industry with demands to replace trichloroethylene, a known carcinogen, for health and safety and environmental reasons, following clear EU directives.
Just as we enter the last few months of phase-out, those same enforcers decide to support a voluntary scheme, which acts entirely at odds with legislation and sends a message of contradiction.
They lend no support to other products in this way.
As ever, industry is left 'at odds' with important issues.
To date no explanation is forthcoming.
* About the author - Derek Carpenter is with Enviro Tech Europe. Request a free brochure from Enviro Tech Europe ...
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