The Commission's proposal is now in its fifth draft. This broadly followed the structure of an earlier version (ENDS Report 221, pp 40-41 ). Operators of processes using more than a specified quantity of solvents would be obliged to prepare solvent management plans. Emission limits and other rules for specific sectors would be laid down in a series of annexes. Twenty sectors are now covered, the latest additions being the extraction of animal and vegetable fats, textile processing and pharmaceuticals.
The Commission has already attempted to simplify its requirements for solvent management plans. These are designed to estimate fugitive emissions by tracking the flow of solvents through a process. Larger factories are expected to produce plans to a 15% accuracy, but a simpler version for smaller sites would be accurate to only 30%.
At a recent conference on VOCs, Alison McCormick of BP Chemicals highlighted the "high cost and lack of flexibility" of the current proposals, especially for small companies. CEFIC, the European chemical industry council, has been lobbying for a move to simpler, but less accurate, solvent management plans based on an inventory approach. It is hoping that the Commission will agree to its proposals in April.
Industry's main argument is that solvent consumption thresholds should be raised to exclude smaller users. Dr McCormick estimates that the latest draft would affect some 450,000 sites in the EC. Roughly 90% of these use less than 20 tonnes of solvent per year, and account for less than 30% of the total solvent emissions (see graph ).
BP Chemicals cites industry figures from France suggesting that compliance costs are particularly high for small companies, accounting for over 6% of turnover for firms using less than 20-40 tonnes of solvents per year. "This is going to wipe out profits," she said. CEFIC claims that the current proposal would cost 2-6 billion Ecu (£1.5-4.5 billion) per year, but that this could be more than halved by excluding most smaller users in four or five key sectors.
The Commission is showing some sympathy with industry's arguments. It is sponsoring a study by a German consultant to verify its figures, and to identify sectors which are particularly hard hit by low thresholds.
However, Brussels is under pressure to produce the final draft by the summer, and it is not yet clear whether the consultant's findings will be available in time for any late changes.
The Commission faces some difficult decisions in balancing its calculations - not least in determining the potential impact of higher thresholds on the development of low- or zero-solvent products and processes. A notable feature of the fourth draft, largely driven by the UK, was the inclusion of lengthy derogations for firms which wanted to switch to alternative technologies. The aim was to encourage operators to change to cleaner technologies rather than simply fit end-of-pipe abatement.
However, there is some concern that exempting a significant portion of the solvents market from control could weaken the incentive for manufacturers to develop low-VOC products. Larger users are more likely to be able to afford expensive abatement equipment such as incinerators.