So far, the Committee's inquiry into VOCs has proved unfocused, and many of its members appear not to have come to grips with the complexities of the subject. The sense of drift was evident on 14 December, when the Health and Safety Executive (HSE) and the Chartered Institute of Environmental Health (CIEH) presented evidence.
VOCs contribute to the formation of low-level ozone and other photochemical pollutants, and the UK is committed to reduce its emissions by 30% by 1999 from a 1988 baseline. In November, the Department of the Environment presented revised emission forecasts to the Committee which suggested that existing policies should suffice to reach the target (ENDS Report 238, pp 24-25 ).
However, in written evidence to the Committee, the AMA expressed reservations over the ability of LAAPC to deliver the expected reductions. Of the 9,798 process authorisations issued by local authorities by March 1994, 2,614 are concerned directly with the control of VOC emissions. "It remains to be seen," said the AMA, "how successful the full extent [of LAAPC] will be as few process operators have yet to commit significant expenditure to the regime."
The AMA proposed several measures to achieve further VOC reductions, all of which, it said, could be implemented through existing regulatory frameworks "without undue additional burdens being placed on industry."
The first suggestion was a lowering of the solvent usage thresholds for processes coming under LAAPC. The AMA pointed to vehicle respraying processes, for which the DoE has already lowered the threshold from 2 tonnes to 1 tonne per year. Even so, said the AMA, less than half of the sector's emissions are controlled - whereas a lower threshold of 0.25 tonnes would catch 93% of its releases. However, the AMA may be on shaky ground - the respraying sector is far more "bottom heavy" than most sectors under LAAPC.
Graham Jukes, the CIEH's Director of Professional and Technical Services, was more optimistic that the 30% target will be achieved, and pointed out that the "crucial date will be the implementation of upgrading programmes in 1998 and 1999". He remained "unconvinced" of the case for lower thresholds on cost-benefit grounds. Furthermore, he doubted that local authorities' resources could cope with the added workload.
However, the CIEH agreed with another of the AMA's recommendations that LAAPC authorisations should contain mass emission limits in addition to the current reliance on concentration limits. At present, the AMA argued, local authorities have no precise control over total emissions of VOCs. Mass limits could allow reporting of VOC emissions to be incorporated into the Chemical Release Inventory (ENDS Report 236, pp 6-7 ), allowing improved monitoring of VOC emissions and the potential to set sector-specific targets towards attaining the overall 30% reduction goal.
The AMA's final area of concern was "the inadequacy of current practices for the determination of VOC emissions from industry". Many operators, it said, had adopted "cost-saving devices" which were "leading to a serious misrepresentation of the nature and extent of releases to atmosphere."
The HSE told the Committee that measures to protect the environment should not increase the risks faced by employees, and stressed the need for policy to be determined on an overall risk and cost benefit assessment. Peter Graham, Head of the HSE's Health Policy Division, singled out the need to find alternatives to chlorofluorocarbons, which are "fairly innocuous from a worker safety point of view". However, he gave no indication of concern over the health effects of water-based "compliant coatings", which many operators under LAAPC are hoping to use to avoid investment in VOC abatement.