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Perchloroethylene and Methylene Chloride (R40 Halogenated Solvents)
If you are currently unregulated and using > 1 te/yr of the R40 labelled halogenated
solvents, registration is needed by 31 October 2006 with full compliance by 31
October 2007.
If you are already regulated and using > 1 te/yr of the R40 labelled halogenated
solvents, it is possible that the regulators will expect compliance with SED
Regulations emission limit values within the shortest possible time.
For all the above-mentioned chlorinated solvents
Reduction of Consumption to below 1 te/yr can enable users to avoid the need to
comply with the SED Regulations. 9 However, the SED Regulations apply to most
solvents and their industrial applications, so other activities on the same site may
bring it back into the scope of the legislation.
The reduction scheme provided for in the SED Regulations does not apply to the risk
phrase solvents, and R40 halogenated solvents.
The “shortest possible time” is not further defined in the SED Regulations and the
DEFRA guidance on this is quoted above. It is expected that the regulators will
consider this on a case-by-case basis.
Opportunities for substitution will often be process or installation specific, and will
therefore need to be considered on a case-by-case basis. When proposing their plans,
users will need to consider:
adequate technical arguments justifying why substitution may not be feasible;
the substitution plan may include reduction of Consumption to below 1 te/yr.
References
1. Statutory Instrument 2004 No.107 The Solvent Emissions (England and Wales) Regulations 2004.
(www.legislation.hmso.gov.uk/si/si2004/20040107.htm)
2.Guidance on the Implementation of the Solvent Emissions Directive (1999/13/EC), DEFRA, March
2002.
3. Introductory Guidance on the New Solvents Emissions Regulations, DEFRA, February 2004.
(www.defra.gov.uk/environment/airquality/lapc/default.htm)
4. Secretary of State’s Guidance Note PG 6/23a Coating of Metal and Plastic.
5. Secretary of State’s Guidance Note PG 6/23b Surface Cleaning
6. Scottish Statutory Instrument 2004 No 26 The Solvent Emissions (Scotland) Regulations 2004.
(www.scotland-legislation.hmso.gov.uk/scotland/ssi2004/20040026.htm)
7. The Environmental Protection Act (Solvent Emissions Directive) (Scotland) Direction 2002
(www.scottishexecutive.gov.uk/library5/environment/sedd04.pdf)
8. Pollution Prevention and Control (Solvent Emissions Directive) (Scotland) Direction 2002
(www.scotland.gov.uk/library5/environment/prcdd04.pdf)
9. Extract from letter from Michael Harryman, DEFRA to Mike Walker, Ineos Chlor, dated 20
September 2002. (Copy available on request)
“You asked about circumstances in which the amount of risk solvent used was so reduced that
amount fell below the limits in Annex II [of the SED]. In those circumstances, there would no
longer be an obligation under the SED to replace the risk phrase solvents. Nor any obligation
to meet any other obligation under the SED. Although, of course, any other legislation
relevant to the use of these solvents would continue to apply.”