Annualreview 2010

7/24/2019 Annualreview 2010

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Fundamentally strong

up to a point

Chlorine Industry Review2010-2011


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10Chlorine Industry Review

2010-2011

Cover picture:Chlorine is produced in electrolysis cells, where an electric currentis sent through brine, a solution of salt (sodium chloride) in water. Salt, waterand electricity the three basic raw materials of chlorine/caustic production form the central themes of our Industry Review trilogy 2008-2011.In the 2008-2009 edition, we published artists impressions of electric current.The cover of the 2009-2010 Review was illustrated with beautiful water droplets,and this new edition shows salt crystals in their cubic mineral form.

Fundamentally strongup to a point

CHLORINE INDUSTRY REVIEW2010-2011


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01 Introduction 04 Fundamentally strong - up to a point

02 Sustainability 06 Learnings from the first 10 year programme

03 Regulatory Affairs 22 Science-based legislation to support innovation

04 Science 30 Effective advocacy based on sound science

05 Communication & education 38 Relevant, reliable and timely information

06 Industry overview 42 European chlor-alkali industry shoots back up

07 Chlorine production plants 48 January 2011

08 Euro Chlor 50 In the centre of chlor-alkali regulatory and HSE issues

CH 02 03CONTENTS


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01Introduction

Ask yourself what factors need to be addressedto bring about recovery from the economic tur-

moil we have experienced over the past threeyears and competitivity will probably be highon your list. Next ask what affects yourabilityto compete and what can youdo to control itand ensure your commercial future and theanswers are a little more difficult to find.

Lets be more specific and ask what can bedone to enable the European Chlor Alkali In-dustry to compete with international competi-tors and prevent an erosion of market share.

The question is not a trivial one as the answerdictates the underlying message of EuroChlors advocacy work in the Commission andEuropean Parliament. Are we a fundamentallywell run, cost efficient industry who needs tobe nurtured or are we unable to repel the un-

deniably strong competition from other partsof the world dooming us to a slow and painfuldemise!

I am firmly convinced that it is not the latter but this is not to say that our future is guar-anteed. We have to work tirelessly in pursuit ofour competitiveness and sustainability.

Reassuringly the Commission recognises theimportance of European competitivenessand has launched an initiative to promote thecompetitiveness of European industry. CalledEurope Flagship 2020: An Industrial Policy forthe Globalization Era it saysIndustry must beplaced centre stage if Europe is to remain a globalEconomic Leader. Paraphrasing Vice Com-missioner Antonio Tajani Only a EuropeanIndustrial Policy targeting competitiveness

and sustainability can muster the criticalmass of change and coordination needed forsuccess. () There will be no sustainabilitywithout competitiveness, and there will be nolong-lasting competitiveness without sustain-ability. And there will be none of them withouta quantum leap in innovation!

Meanwhile, the major cost driver for our in-dustry is electricity which with the highest pricein the world more than double comparedto some regions is a heavy burden to bear.

Electricity efficiency of our member companiesis amongst the best in the world which unlikethe electricity cost is something which is underour own control. This is testament to our goodindustrial and management skills and is proofpositive to my earlier assertion.

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The current work to win state aid compensa-tion to offset carbon dioxide emission costsfor intensive energy consumers is crucial in thedrive for competitiveness. This is where theopening questions become relevant. We arenot a crippled industry looking for hand outsjust to prolong the agony of inevitable failure.We are a fundamentally healthy industry ableto compete with the rest of the world but onlyup to a point. The European economy needs in-dustries like ours able to provide employment,pay taxes, and to provide the chemical buildingblocks for other manufacturing industries.

Though governments may be reluctant to uselimited cash resources to support industry,recognition of deserving, legitimate cases likeours is vital if European Industrial Policy initia-tives referred to above are to be credible.

We remain optimistic of a positive outcome bythe end of 2011.

Hand in glove with competitiveness is sus-tainability, an area where we have much tobe proud of. Our first 10 year sustainabilityprogramme achieved notable successes withincreased energy efficiency, mercury emissionreduction and the increased use of hydrogen(details can be found in Section 2 followingthis foreword). Our second 10 year initiative

on the journey towards our goal of industrialimmortality is now launched. We have takenthe opportunity to broaden our approach toinclude aspects of economic and social factors.

This will take the form of success storiesshowing the progress we are making in areaslike better water usage, conservation of localwildlife habitats and the socially responsibleuse of our products.

We should not delude ourselves on the easeby which we can achieve this or even theenthusiasm required to carry it through. It is amajor challenge which we must respond to asbefits a senior sector of the chemical industryas a whole. Over the last twenty five yearswe have built an admirable reputation basedon transparency and a willingness to engagein debate with the various authorities usingsound science and common sense to substan-tiate our point of view. Our new sustainabilityprogramme will advance our reputation stillfurther by acknowledging the global issues of

availability of clean water, feeding a growingpopulation and biodiversity.

Be alert for new communications materialand be prepared to use it in communicatingwith your employees, neighbours and nationalauthorities. I wish you a successful andinteresting year!

Alistair J. SteelExecutive Director

Polyvinylchloride orPVC is widely used in

car manufacturing (e.g.dashboards) and piping T

essenderloChemie

TessenderloChemie

CH 02 INTRODUCTION 05


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02Sustainability

Learnings from the first 10 year programme

This first 10 year sustainability programme

has helped us to better understand the

trends in our industry. If some indicators

showed clear improvements, even better

than targeted, some others did not, and

the companies have been asked to analyze

their own performances and draw the

conclusions for possible actions.

At the other end, it appeared clearly that

some of the indicators could be presented

in a more positive way and that new

interesting indicators could be added: this

is the objective of a new programme.

Alistair J. Steel


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Unified strategic approach

All of the European chlorine manufacturingmembers of Euro Chlor agreed on an industry-wide strategy that focused on six voluntarycommitments. These were first developedto ensure a united industry approach and

commitment to address key sustainabilityconcerns: Include environmental, social and economic

factors in all strategic business decisions; Optimize energy efficiency in chlorine pro-

duction; Reduce water usage through recycling; Continuously reduce polluting emissions to

water, air and land; Use more hydrogen generated by the indus-

try as a raw material or fuel; Give high priority to safe transportation of

chlorine.Within this framework, 15 performance indica-tors were defined about 10 years ago, some ofthem with an improvement target for 2010, inthe following main areas: economic aspects ofproduction, environmental protection, safetyand social progress. Each year, producers havereported their progress to Euro Chlor, whichconsolidated the results for the associationsManagement Committee prior to annual publi-cation of the industrys performance.

In this section, we summarize the final resultsof this 10 year programme. Not all the indica-tors show the same degree of progress, but thelessons learned from this exercise were veryuseful for the companies and the association,and the Management Committee has decidedto propose a new programme for the future.

Economic contribution

Energy useTarget:By 2010, reduce industry-wide energyconsumption by 5% in terms of kWh/tonneof chlorine produced compared with the 2001base year.

Update: for the last year of the programme,the average energy consumption droppedsignificantly with a value of 3,358 kWh/t ofchlorine produced, about 100 kWh lower thanthe target, confirming the general trend relatedto the progressive conversion from mercury tomembrane technology.

Background:Since electricity is an indispens-able raw material of the chlorine productionprocess, the basic consumption correspond-

ing to the electrochemical reaction cannot besignificantly reduced. However, converting onetechnology into a more efficient one may savea certain amount of energy and, to a lesserdegree, reduce ancillary energy use. The energyindicator is weight-averaged across all produc-ers and based on steam and electricity. Energyis mainly used for electrolysis (transformers,rectifiers and cells) and also for illuminationand motor power (pumps, compressors, cen-trifuges, etc.). Steam is used mainly for causticsoda concentration to 50% and for minorutility purposes.

Hydrogen produced in chlorinemanufacture can be usedeffectively for power generationvia fuel cell technologyV

innolit

AkzoNobel

SUSTAINABILITYCH 02 07


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3200

3250

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2010200920082007200620052004200320022001

70

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2010200920082007200620052004200320022001

Energy consumption Hydrogen utilizationkWh/tonne of chlorine %

Goal:95% use of hydrogen by 2010Goal:5% reduction by2010

Energy consumption

RealObjective

Hydrogen utilization

RealObjective

Hydrogen utilizationTarget:Increase use of hydrogen gas from 80%(2001) to 95% by 2010.

Update:In 2010, the percentage of hydrogenuse increased again, reaching for the first timemore than 90% (90.4%). This value remainsnevertheless quite low compared to the targetof 95%. About one fourth of the companies arestill below 80%, with a few remaining around50%.

Comment: As several fuel cells projects havebeen announced, and with the developmentof oxygen depolarized cathodes (no hydrogenproduction), we are confident that this positivetrend will continue, even if slowly, in the future!

Background:High-quality hydrogen is co-pro-

duced with chlorine and caustic soda duringthe electrolysis of brine. This can be used as araw material for other processes or as fuel toproduce steam; technologies are today in finalindustrial development to allow for local elec-tricity recovery via fuel cells. See picture p.07.

Manufacturing technologyTarget:The percentage of chlorine producedby mercury cells, diaphragm cells, membranecells and other technologies will be communi-cated on a yearly basis.

Update: Membrane technology now representsmore than the half (51.2%) of the installedproduction capacity of Euro Chlor members.The mercury process accounts for 31.8% at thebeginning of 2011, continuing the progressivephase out of this technology in line with the

Chlor Alkali sectors voluntary agreement. Thediaphragm process still accounts for a bit lessthan 14% of the total capacity. See also thegraph on p.47.

Economic developmentTarget:Euro Chlor has decided to reportmonthly, quarterly and annually data onEuropean production of chlorine and causticsoda. This includes utilization rates, causticstocks, capacity and technology by plants andapplications.

Update: In 2010, Euro Chlor continued to pub-lish on its website and distribute to the mediafigures for monthly chlorine production andcaustic soda stocks. The Industry Review in-cludes every year a map of Europe showing thelocation of all plants and a table indicating the

location, ownership, technologies and capacityof each plant (see p.49 for the situation at thebeginning of 2010).

Safety & social progress

Lost-time injuriesTarget: Reduce lost-time injuries (LTI) to 1.3per million working hours for all workers - bothcompany employees and contractors workingin production units.

Update: The general trend is going slightly inthe right direction (particularly for the contrac-tors), but the values are still far from the target(7.5 for companies and 7.8 for contractorsrespectively).



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Lost Time Injuries - production units and contractorsindicators (number of incidents for 1 million working hours)

0

2

4

6

8

10

12

14

16

18

2010200920082007200620052004200320022001

CompaniesGoal:85% reduction by 2010

ContractorGoal:90% reduction by 2010

Process incidents

Companies Contractor

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10

20

30

40

50

60

70

80

2010200920082007200620052004200320022001

Number of incidents

Goal:> 75% reduction by 2010

Number of incidents Objective

Objective

Comment: All kinds of accidents are con-sidered here - not only those specific to thechlor-alkali industry. It is also important to notethat the indicators are related to the produc-tion units (and often maintenance activities)without integrating the administrative andcommercial entities, that allow lower globalfigures at company level. Nevertheless, anumber of companies still have a large marginof improvement for both indicators.

Background:A lost time injury (LTI) resultsin at least one day of absence from work. Itis reported as the number of LTI per million

working hours. The figures from companiesreporting on a three day period of absence areconverted to a one day equivalent using aCefic correlation.

Process incidents and lossesTarget:A 75% reduction in the number of pro-cess incidents from 67 (2001) to 15.

Update:After a remarkable decrease in thenumber of accidents, the indicators remainedfor 3 years at the level of the target before

increasing significantly in the last few years toreach a value of 27.

Comment:Past results show that the 2010target can be achieved, but efforts are neededin the future.

PVC sustainable development on track despitethe global recession

As reported by Vinyl 2010 in its 2011 annual progress re-port, the European PVC industry recycled nearly 261,000tonnes of this chorine-based plastic in 2010, exceeding byfar the 10-year target of 200,000 tonnes post-consumerPVC to be recycled and this despite the difficulties facedin the years of crisis.

All the information reported is independently audited andverified by external third parties. The newest Report Vinyl2010 10 years can be consulted and downloaded fromwww.vinyl2010.org.

Vinyl 2010 is a voluntary commitment from industrygroups representing the complete PVC value-chain: theEuropean Council of Vinyl Manufacturers (ECVM), theEuropean Plastics Converters (EuPC), the European Sta-biliser Producers Association (ESPA) and the EuropeanCouncil for Plasticisers and Intermediates (ECPI).

PVC constitutes one of themost sustainable materialsin construction

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2010200920082007200620052004

Environmental certifications% of production units

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200

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1000

2010200920082007200620052004200320022001

Chlorine Transported1000tonnes

Chlorine TransportedBulk railBulk road

Total withoutpipeline

Environmentalcertifications

ISO14001

EMAS

Background: Incidents are classified as eventsinvolving a fire, explosion or the release ofchlorine, hydrochloric acid, sulphuric acid,sodium hypochlorite (bleach) or caustic soda,which cause a fatality, serious injury or propertydamage exceeding 100,000. Losses includeany of the above chemical spills in air, water orland, which impact human health or the envi-ronment, property or result in evacuation.

TransportationTargets: The tonnage of chlorine transportedwill be reported annually as well as the mode oftransport involved; additionally, zero transportincidents involving the bulk movement ofchlorine by 2010 has been set as a target.

Update:Two transportation incidents werereported in 2010, while four occurred in 2009

and only one in 2008. The quantity of chlorinetransported in 2010 increased a bit after thedip caused by the economic crisis, but still is ata lower value than in 2008: chlorine produc-ers in Europe transported 522,000 tonnes ofchlorine, with almost 80% being shipped byrail and the remainder by road. The transportof chlorine (excluding pipelines) representeda little more than 5% of the 2010 production.The average distance chlorine was transportedby rail remained about 490 km and 190 km byroad.

Background:A chlorine transport incidentis one which either involves death or injury,a spill/leak of more than 5 kg, substantialproperty damage, public disruption of morethan one hour or the intervention of emergencyservices or media coverage. The amount of

chlorine transported in Europe by rail and roadhas halved during the past decade. Chlorinemovement has been decoupled from produc-tion through supplier/customer relocationsand more use of local pipelines. Rail transportdominates; road transport for bulk supply isused only in the United Kingdom and, to alimited extent, in Spain, France and Portugal.

Note:none of the incidents has led to a chlo-rine leak.

Responsible CareTarget: All chlorine-producing members ofEuro Chlor to sign up to the Responsible Careinitiatives by 2010.

Update: Three companies of the 35 werenot convinced of the desirability of a formal

commitment and had still not signed for theprogramme at the end of 2010.

Background: Responsible Care is the chemicalindustrys global voluntary initiative by whichcompanies, through national associations,work together to continuously improve theirhealth, safety and environmental performanceand to communicate with stakeholders abouttheir products and processes. ResponsibleCare was conceived in Canada and launched in1985 to address public concerns about chemi-

cal manufacture, distribution and use. Thenumber of national chemical industry associa-tions embracing the Responsible Care ethichas grown considerably from 6 to 52 countriessince 1992.

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Responsible Careis the global chemical industryinitiative to continuously improve health, safety

and environmental performance

Environmental protection - COC emissionsTarget:Emissions of 22 chlorinated organiccompounds (COCs) to be reduced in 2010 by75% to water and by 50% to air against the2001 base year.

Update:At end of the programme, COC emis-sions from manufacturing plants confirmedglobally the results from the last years for bothwater and air compartments, with even somefurther improvement for the air emissions; theconsolidated values stayed at 78% reductionfor water, and reached more than 75% for theair performance.

Background:The COCs were selected fromvarious international regulatory priority lists foremissions reductions and comprise the follow-ing substances: 1,1,1-trichloroethane; 1,1,2-tri-

chloroethane; 1,2-dichlorobenzene; 1,2-dichloroethane; 1,4-dichlorobenzene; 2-chlorophenol;3-chlorophenol; 4-chlorophenol; carbon tetra-chloride; chlorine; chlorobenzene; chloroform;dichloromethane; dioxins & furans (as TEQ);hexachlorobenzene; hexachloro butadiene;hexachlorocyclohexane; pentachlorophe-nol; tetrachloroethylene; trichlorobenzene;trichloroethylene and vinyl chloride. In 2005,pentachlorobenzene was added to the list ofthe substances to be monitored, in line withthe requirements of the EU Water Framework

Directive. To provide a longer-term perspec-tive of the sectors commitment to reducingemissions, the data shown spans the period1985-2010.

CH 02

Trained as a chemical engineer and with a long experiencechlorine production units within the Solvay Group, Jean-Debelle has been seconded to Euro Chlor for more thanyears to take charge of the technical aspects of health, sa

and environmental protection issues (HSE).

Continuous improvement in HSE fieldsThe technical activities of the association started with its cation more than 60 years ago. Several Working Groups fatated experience exchanges between member companiesthe safety, health and environmental protection areas.This experience is formalized in the publication of guidadocuments, periodically updated and shared with all mebers via the Euro Chlor website.On a global level (the World Chlorine Council), Euro Chis working with its international partner associations to

hance HSE aspects of chlor-alkali production, and especion safety via the World Chlorine Council Global Safety Te(WCC GST), whose secretariat Euro Chlor is managing two years.

In support of regulatory workThe technical activities include support to the regulatorytivities of Euro Chlor through the collection and analysistechnical data.This ranges from workers exposure to chlorine, mercury electromagnetic fields to emissions of mercury to air, waand products, handling of waste, evolution of the product

technologies and specific energy consumption.Euro Chlor is also working closely with the national authties for the preparation of the new BAT reference docum(BREF) which is of vital importance for the permittingchlor-alkali production activities in Europe.Euro Chlor has just completed a 10 year sustainability motoring programme during which the evolution of a lanumber of sustainability parameters are published annucontributing to the transparency of the sector towardsstakeholders.

Jean-Pol DebelleTechnical Director

Continuous im-provement in safehealth and enviromental protection

remains a strongbasic mission of oassociation.


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Plant emissions to water

Chlorinated organic compounds

2010

Target

1000t/year

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Plant emissions to air1000t/year

Plant emissionsto water

TotalTarget

Plant emissionsto air

TotalTarget

Mercury emissionsTarget: Although all other programmedeadlines are for 2010, the industry decidedto maintain an earlier 1998 commitment toachieve by 2007 an emission target of 1.5 gHg/t chlorine capacity for each individualplant. The industry elected to keep the earlierdate, since from October 2007 all EU chlor-alkali plants whether membrane, mercury ordiaphragms require an operating permit underthe Integrated Pollution Prevention and Con-trol (IPPC) Directive.

Update: Overall European emissions in 2010amounted to 0.88 g Hg/tonne chlorine capa-city, with a real improvement compared to theprevious years (0.93 g Hg/t in 2009 and 0.92 gHg/t in 2008). The average mercury emissionsfor Western European countries remained at

about 0.76 g/t capacity (see graph on p.13).

Comment:Plants that had quite high emis-sions in the liquid effluent last year did showsome noticeable improvement, enabling globalemissions to start going down again. Unfor-tunately, four plants are still above the 2007target of 1.5 g Hg/tonne chlorine capacity forthe total emissions, one of them being even atthe level of 2.5 g Hg/t chlorine capacity.

Product knowledge

Target:The industry agreed to provide fulleco-toxicological and environmental data on29 chlorinated substances under the Interna-tional Council of Chemical Associations/OECDinitiative on high production volume (HPV)chemicals.

Update:These data have been published -except for four HPV chemicals which wereeither no longer relevant (not commerciallyavailable anymore) or are covered underREACH with a registration deadline of Decem-ber 1st2010. Key substance property data ofsubstances registered under REACH will bemade publicly available.

Environmental accreditationTarget: All full members to gain EMAS and/orat least ISO 14001 Environmental Accreditationfor their plants by 2010.

Update: there was an increase in the numberof ISO 14001 accreditations in 2010, from 54to 57 on a total of 66 plants. There are still 14production sites with EMAS accreditation.

Background:EMAS (The Eco-Managementand Audit Scheme) is the EU voluntary instru-ment which acknowledges organizations thatimprove their environmental performance ona continuous basis. EMAS registered organiza-tions are legally compliant, run an environmen-tal management system and report on theirenvironmental performance through publica-tion of an independently verified environmentalstatement. ISO 14001 is an international qual-ity assurance standard to evaluate an organiza-tions environmental management systems

and encourage continuous improvement. Ithelps organizations minimise negative envi-ronmental impacts (on air, water or land), andcomply with applicable laws/regulations andother environmentally-oriented requirements.It is often the case that ISO 14001 is used as apart of the EMAS registration process.

2010Target



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Wolfgang Marquardt studied chemistry and sharpened profile on toxicology during his PhD thesis in Munich. joined Euro Chlor in 2007. Wolfgang Marquardt startedscience manager in the European Chlorinated Solvent Asciation (ECSA), becoming sector group manager of ECSA2009. He is responsible for the ECSA management and different working groups such as the General Technical, cupational and Environmental Health, Product, Communtion and Outreach, and Sustainability Groups.

ECSA sustainability programme in a nutshellECSA started its sustainability programme in 2007 with ambitious aim to cover the whole chlorinated solvents vachain. The programme was prepared by an independent csultancy with the mission to ensure responsible productidistribution, use and end-of-life management of chlorinasolvents. Nine objectives were set under the three vision ments: Sustainability by product and application; Value chengagement; Stakeholder engagement and communicatio

ECSA reviewed the progress in 2011. The sheer numberesults is already impressive: for example, ECSA analyzedapplications and summarized recommendations for safesustainable use of chlorinated solvents in an online toolbThis Product & Application Toolbox contains recommentions for more than 350 individual activities.

Not only the quantity but also the quality of the results in sustainability programme is worthy of mention: for examone of the six awareness programmes with the value chhas led to an Excellence Award for ECSAs contribution.

European Chlorinated Solvents Producers can be proudthe substantial progress that has been made under thECSA Sustainability Programme between 2007 and 20ECSA will continue its efforts in pro-active communicattowards stakeholders, such as the revamped website whdelivers comprehensive information about chlorinated vents and adds tools for a further dialogue with the dowstream users of chlorinated solvents.

Wolfgang MarquardtECSA Manager

We can reportsubstantial progrein our ECSA sustaability programme

CH 02

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European mercury emissions 1995-2010(g Hg per tonne of chlorine capacity)


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ECSA Sustainability Programme: Progress Report 2007-2011

Vision ElementSustainability by product

& application

Vision ElementStakeholder engagement

& communication

Vision ElementValue chainengagement

Vision

Recognized as a sustainable industry, delivering beneficial products & services,whilst meeting and anticipating societal, environmental and health needs

MissionECSA actively drives a sustainability programme ensuring responsible production, use

and end-of-life management of its products along the value chain; it works togetherwith key stakeholders and communicates progress

One of the well-researched categories of chem-icals, chlorinated solvents are used in a varietyof applications, which are mainly industrial.The properties and the health and environmen-

tal characteristics of these products have be-come better known over the years; as a result,the chlorinated solvents industry has engagedin active risk management and risk reductionprogrammes, including, for example, the de-velopment of solvents management services.

During the course of implementing measuresunder the ECSA Sustainability Programme, theREACH legislation was introduced in Europe,and ECSA integrated REACH aspects into the

existing Sustainability Programme. The ECSASustainability Programme allows ECSA toreview consistently and in depth the sustain-ability of chlorinated solvents, and to set itselfchallenging though achievable long-term objec-tives ensuring the sustainable use and end-of-life management of chlorinated solvents.


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The ECSA Vision Elements identify the threekey areas in which the chlorinated solventsindustry is taking concrete steps to ensureits sustainability. The objectives assignedunder each key Element are not only a matterfor ECSA members; they require direct andconcrete engagement with third parties suchas value chain actors and other external stake-holders.

Three Elements are the building blocks ofECSAs Vision. They set out the long-termobjectives required to achieve the Vision,and they identify Key Performance Indicators(KPIs) that will help ECSA determine where itstands relative to these goals, resulting in nineconcrete objectives.

1. Sustainability by product andapplicationA broad stakeholder consultation revealedthat emissions of chlorinated solvents are thecause of most of the pressure being broughtto bear against chlorinated solvents prod-ucts. By reducing emissions we can achievebetter efficiency of use, more value from eachmolecule of solvent and reduced potential forexposure. This Vision Element should achievethe benefits of:

Driving industry and product sustainabilityby identifying challenges or opportunities foreach emissive application

Ensuring safety for human health and envi-ronment

Demonstrating continual improvement ofsustainability in emissive applications

Resolving issues over impact of energy andraw materials.

1.1ECSA will analyze emissive applications,prioritize them, and define sustainabilityimprovement actions ECSA has so far reviewed an impressive total

of 60 applications ECSA Product&Application Toolbox:ECSA

has developed an online toolbox freelyaccessible via the ECSA website to provideusers of chlorinated solvents with informa-tion about the safe & sustainable use of theproducts. It is built as a self-explanatoryguide based on a simple decision tree of

product applications to lead the user readilyto the proper information on safe use, envi-ronmental protection as well as legislativerequirements.

The onlineECSA ProductsApplicationToolbox providesinformation onthe safe andsustainable useof chlorinated

solvents

The ECSA SustainabilityProgress Report is

available on the ECSAweb pages via

www.eurochlor.org

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ECSA SUSTAINABILITY PROGRAMME


The recommendations do take into accountREACH (1907/2006/EC on the Registration,Evaluation, Authorization and Restriction ofChemicals) as well as other European legisla-tion or voluntary industry commitments.The content of the Toolbox is based on theREACH Chemical Safety Assessment (CSA)of the substances.However, the Toolbox also includes recom-mendations based on experience of ECSAmembers that go beyond the given legalframework of the CSA under REACH.The ECSA Product&Application Toolbox isaccessible online: www.eurochlor.org/ECSA

1.2Raw material, energy & production aspectswill be coordinated with upstream organizations ECSA is in constant dialogue with Euro Chlor

and is sharing events; e.g. a joint yearly

General Assembly with reports on activitiesin the different committees

ECSA is liaizing with Euro Chlor on its newSustainability Programme 2011-2020.

2.Value chain engagement

The buy-in and active involvement of the valuechain will be essential to the overall success ofthe programme. Collaboration with distribu-tors and downstream users is the only way toensure sustainability goals are met, as thereare limits to what ECSA members can achievein their own right.

2.1All ECSA members will adhere toESAD/SQAS or a similar distributorassessment schemeESAD (European Single Assessment Docu-ment) is part of the SQAS (Safety & Quality As-sessment System) that is a system to evaluatethe quality, safety, security and environmentalperformance of Logistics Service Providers andChemical Distributors. ESAD enables chemicalproducing companies to have the quality andsafety management systems of their distribu-tors assessed in a uniform manner, thus avoid-ing multiple assessments by each individualchemical company. Currently over 280 activeassessment reports of distributors and theirsites are listed in the ESAD database. All ECSAmembers have committed themselves to theESAD/SQAS programme.2.2All distributors which are part of ESAD/SQAS or a similar programme will complypositively with a high score on the chlorinatedsolvents section of the questionnaireThe ESAD assessment questionnaire consistsof four parts: Distributor Standard Activities,Site Assessment, Chlorinated Solvents, andFood, Cosmetic and/or Pharma. The questionson chlorinated solvents emphasize the specificneeds associated with chlorinated solventsand are provided together with guidelines forconsideration by chlorinated solvent producers

and distributors as a way to implement Respon-sible Carecontinuous improvement initiatives(source: www.sqas.org). A continuous yearlyincrease in positive answers of distributors,under the chlorinated solvent part, has beenrecognized in the ESAD programme since

The integrated Safety &Quality Assignment System


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2007. This leads to consistently high scores ofdistributors in the ESAD assessment.ECSA has actively participated in a revisionof the ESAD questionnaire for chlorinatedsolvents.

2.3 ECSA will put together awareness

programmes, in partnership with tradeassociations representing end-users, to helpensure the sustainable use of chlorinatedsolventsECSA has already put six different awarenessprogrammes in place:

2.3.1Chlorinated Solvents: AwarenessQuestionnaire to the Value Chain: ECSA hasdistributed an awareness questionnaire onthe safe use of chlorinated solvents in 2009.The findings were shared with the partici-

pants in the Value Chain with one particularlysurprizing result: no participant was aware ofthe ECSA storage and handling guidance beingfreely available on the internet. This result ledECSA to take immediate action with a revisionand update of the ECSA Guidance of Storageand Handling of Chlorinated Solvents and widecommunication: see next point.

2.3.2Chlorinated Solvents: Revized Guid-ance on Storage and Handling of ChlorinatedSolvents: This guidance is intended to help

distributors and users of chlorinated solventsto handle those products safely and with care,thus protecting human health and environ-ment against possible negative impact.In this guidance, ECSA strongly recommendsthe use of modern closed equipment of BestAvailable Technology (BAT).

ECSA gives guidance onthe storage and handling ofchlorinated solvents

All ECSA membershave committedthemselves tothe ESAD/SQASprogramme forquality, safety,security andenvironmentalperformance oflogistics providersand chemicalsdistributors

The ECSA Guidance on Storage and Handlingis accessible online: www.eurochlor.org/ECSA

2.3.3 Chlorinated Solvents: Revized Safety& Quality Assessment Questionnaire forDistributors of Chlorinated Solvents (ESAD).With an updated Safety & Quality Assessmentquestionnaire in 2011, ECSA aims to enhancethe overall safety and quality level in the chlori-nated solvents distribution chain.The reviewed questionnaire is applicable to dis-tributors of the chlorinated solvents perchlo-roethylene (PER), trichloroethylene (TRI) anddichloromethane (DCM).The recently launched SQAS 2011 programmehas been titled SQAS: Driving excellence insafe and sustainable chemical logistics. Allrevized questionnaires and further details areavailable on the SQAS websitewww.sqas.org.

2.3.4Dichloromethane: OECD HPV SIDS Com-mitment:The chemical industry provides theOECD with data and initial hazard assessmentsfor approximately 1,000 HPV chemicals, rep-resenting more than 90% of global chemicalsproduction. The information gathered consistsof a Screening Information Data Set (SIDS)Dossier, which is a basic set of health andenvironmental data required for making aninitial hazard assessment of HPV chemicalsby the member countries of the OECD. ECSA

members are committed to improving themanagement and knowledge of their chemicalsthrough voluntary initiatives such as the ICCAHPV (High Production Volume) Initiative. ECSAis actively supporting the Swiss authorities inpreparing the SIDS Dossier for Dichlorometh-ane and its submission to OECD in 2011.


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2.3.5Perchloroethylene: E-DryClean sustain-able dry cleaning processing: E-DryClean is aninternational initiative to create practical andeasily accessible education material, especiallyfor the European dry-cleaning industry. Thedidactical concept is based on e-learning and/or blended learning. E-learning is a completedigital self-study form of training, presentedthrough a website. E-DryClean offers six dif-ferent training modules (best practices andworking methods) including a module onPerchloroethylene, for which ECSA was leadingpartner. The E-DryClean Project groups 15 part-ners from eight European countries.The objective of E-DryClean is to improve andadapt the educational level of entrepreneursand employees working in dry cleaning sectors

across the European Union. Read more aboutthis project on http://www.cinet-online.net/edryclean/.The professional textile care industry rec-ognized ECSA and its partners through itsExcellence Award 2010 for this awareness pro-gramme of sustainable professional textile care.E-DryClean is accessible online: http://www.cinet-online.net/edryclean/

2.3.6 Trichloroethylene: Charter for the safe useof Trichloroethylene;ECSA and the produc-

ers of Trichloroethylene (TRI) have workedproactively with the EU authorities to developa voluntary industry-wide commitment theTRI CHARTER. The charter is deemed toensure adequate control of risks identified inthe EU Risk Assessment related to the use oftrichloroethylene in surface cleaning by use

of closed systems, also for installations notcovered by the VOC directive (now IED).The charter signed by all European Trichloro-ethylene producers and an importer stipu-lates that latest by end 2010, trichloroethylenewill only be supplied for metal cleaning ordegreasing if the user has an enclosed clean-ing system and has confirmed that trichloro-ethylene will only and exclusively be used inenclosed cleaning equipment.The ECSA TRI Charter is accessible online:www.eurochlor.org/ECSA

2.4ECSA will put together, in partnership withother trade associations representing recyclers,awareness programmes to help promote thesustainable recovery of chlorinated solvents

ECSA is in contact with the European SolventRecyclers Group (ESRG), which aims to pro-mote the safe and economic management ofpost-use solvents (www.esrg-online.eu). ECSAis regularly in dialogue with ESRG on latestinformation about chlorinated solvents.

Left picture: ECSA gives guidanceon the storage and handling of

chlorinated solvents

Right picture: The professional textilecare industry recognized ECSA

for its awareness programme ofsustainable textile care

The ECSATrichloroethylenCharter


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3.Stakeholder engagement andcommunication

This Vision Element will be critical to ensurethat ECSA and its members receive worthwhileand operational feedback and proper recogni-tion from external stakeholders for the sustain-

ability initiative.Ultimately, this should also lead to a degreeof co-determination of the sustainability ofthe chlorinated solvents industry, as severalstakeholder groups will contribute to shapingits future.

3.1 ECSA will complete a detailed mappingof the activities, drivers and concerns of itspriority stakeholdersA Chlorinated Solvent Stakeholder & End-userPerceptions Survey by IAL found that 75% of

stakeholders are interested in more informa-tion on Chlorinated Solvents.Thus, ECSA hascompletely renovated the content and structureof the ECSA website in 2010 and 2011.The renewed website delivers comprehensiveinformation about chlorinated solvents. Thewebsite was re-structured, and the websitecontent filled with new information on Facts& Figures. High prominence has been givento the Sustainability section and the currentprogrammes (www.eurochlor.org/ECSA).

3.2

ECSA will translate its Sustainabilitystrategy into a set of key messages, and willdevelop tools to support their delivery andreport progressEuro Chlor, representing the European Chlor-Alkali industry, issues the Chlorine IndustryReviewon the occasion of its Annual General

Meeting. It gives an overview of the most im-portant dossiers the federation has been work-ing on, and presents the progress achieved inthe sectoral sustainability programme. ECSAextends its reporting on all nine sustainabilityobjectives and includes its progress report2007-2011 in the widely disseminated EuroChlor Annual Review as part of the ChlorineIndustry value chain.

3.3ECSA will be in active dialogue with itspriority stakeholders around its SustainabilityAction Plan, and reflect stakeholder concerns inthe ongoing implementation of the Action PlanA Chlorinated Solvent Stakeholder & End-userPerceptions Survey by IAL found that 75% ofstakeholders are interested in more informa-tion on Chlorinated Solvents. Thus, ECSA hascompletely renovated the content and structure

of the ECSA website tools for active dialogue:Additional communication toolshave been in-cluded to increase the dialogue with other stake-holders towards a pro-active communication. TheSME supportis targeting Small and

Medium Sized Enterprises. As part of its con-tinuous effort to encourage responsible andsafe handling of chlorinated solvents, ECSAhas developed several information and guid-ance documents designed to help use chlori-nated solvents not only in the most effectivebut also in the safest and most responsible

manner by following best industry practices. The News & Innovationsection highlights

some quite challenging innovations withchlorinated solvents.

The Ask an Expert toolwill help to answerquestions going beyond the information onthe website.

The ECSA Leonardo daVinci Project for sustainable

dry-cleaning is accessibleonline in six languages


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The World Chlorine Council(WCC) draws itsmembership from the chlorine producers andregional industry associations located aroundthe world. Today, the membership represents asubstantial part of global chlorine and causticsoda production and will increase to over 90%of both capacity and production by the end of2011, taking into account the anticipated mem-bership of the Chinese Chlor Alkali IndustryAssociation (CCAIA). WCChas a long affilia-tion with the International Council of ChemicalAssociations (ICCA) and is recognized by TheUnited Nations and the Stockholm, Rotterdamand Basel Conventions as an official NGO(Non-Governmental Organization).

Overall, WCCis focused on engaging produc-ers worldwide to achieve its 2011-2013 goalswhich focus on:

Engaging the global chlorine and vinylindustries;

Participating proactively in key internationalfora and coordinating advocacy on priorityissues;

Promoting continuous improvement in safety,environment and health performance;

Demonstrating progress towards sustainabil-ity for chlorine chemistry; and

Communicating the benefits of chlorinechemistry to society.

As from the beginning of 2011, Euro Chlorhas been given the task of managing for twoyears the WCC Secretariat and coordinatingits related activities such as global task forces,publications and workshops.

Outreach to the global chlor-alkali sectorIn 2009, 2010 and 2011, WCCcontinuedto strengthen relationships with the chlor-alkali associations of Russia, China, India andproducers in the Asia-Pacific region. We areoptimistic of concluding formal membershiparrangements with each of these regions by theend of 2011 and will continue to build on pastwork with the Gulf Petrochemical and ChemicalAssociation (GPCA) based in Dubai.

Energy and Climate ChangeThe UN Climate Change conferences held inCopenhagen (2009) and Cancun (2010) failedto secure global agreements on CO2emis-sions and, with doubt persisting on whetherthe Kyoto Protocol will continue beyond 2012,CO2abatement initiatives are reverting to theregional level. Currently, only WCC members

with manufacturing facilities in Europe andJapan are impacted by either Emission TradingSchemes (ETS) or energy taxation. Earlier sug-gestions that global sectoral agreements mightbe negotiated have not materialized either butnevertheless WCCcontinues to exchange in-telligence on political activity across the globein an attempt to influence decision-making ina coherent and consistent way. However, thisis now a lower priority for some regions, anda global approach is not foreseen in the shortterm.


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Advocacy for Promoting Sound Implementa-tion of International Conventions & PoliciesWCCcontinues to engage with intergovern-mental programmes on a number of crucialsubjects that could impact chlorine-basedprocesses or products. Advocacy efforts coveroutreach to governments and industry contactson issues relating to chlorine and its deriva-tives. WCCadvocacy efforts, often in partner-ship with ICCA, are focused on the followingpriority issues: Stockholm POPs Convention The World

Chlorine Councilhas continued outreachto governments regarding the process andcriteria for reviewing candidate chemicals.Industrys efforts have resulted in improve-ments in the assessment of candidate POPsand the use of such information for riskmanagement.

UNEP Global Mercury Programme WCCcontinues to be an active participant inthe UNEP Global Mercury Programme inproviding its annual report on mercury use,consumption and emissions by mercury cellfacilities. WCCis also a contributor to vari-ous Partnerships linked to the Programme(e.g. Chlor-Alkali Sector, Supply and Storage,Waste Management). The first Intergovern-mental Negotiating Committee meetingfor the preparation of a Global Conventionwas held in Stockholm in June 2010 and a

second one in January 2011 in Japan. WCCparticipated in the discussions and sharedits updated leaflet on Reduction of MercuryEmissions and Use from the Chlor-AlkaliSector Partnership. It is expected that theConvention will be ready by 2013.

Improving Chlorine Safety, Environment& Health PerformanceThe World Chlorine Councilcontinues toorganise stewardship workshops around theglobe to promote best practices in environment,health, and safety. Through the WCCsafetyprogramme, our industry sector is working to

achieve continuous improvements in safetyperformance at production facilities world-wideas well as during transportation and use of chlo-rine. Key developments in 2010-2011 include: The quarterly publication of the WCCSafety

Newsletter to share best practices and to learnfrom past incidents, which is translated intoJapanese, Portuguese, Spanish and Chinese.

The preparation of new safety tools on specifictopics that are made available to producersand packagers, including synthetic WCCSafety Posters.

Presentations made by experts from WCCcompanies and associations on chlorinesafety matters during stewardship/safetyworkshops. The next workshop is planned forOctober 2011 in Shanghai.

Demonstrating Sustainabilityof the Chlor-Alkali IndustryWork continued on the sustainability pro-gramme, as agreed the previous year. Thoughenergy became a lower priority following thefailure of Copenhagen and Cancun to reach

global agreements, other energy related issues- including the use of chlorine derivatives in thefield of insulation - continue.A new brochure on sustainability will bepublished by the end of 2011 for use in variousconferences, including Rio +20 to be convenedin Rio de Janeiro during 2012.


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03Regulatory Affairs

Science-based legislation to support

innovation

A critical role for Euro Chlor is to provide

advocacy leadership in order to positively

influence regulations in the areas of energy,

environment, health and competitiveness.

The federation works with European and

international authorities in order to achieve a

workable legislation to support the innovative

role of the chlor-alkali industry.


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Emission Trading Scheme (ETS)Directive implementation

The setting up of the rules for the financialmeasures that Member States may give tocompensate for additional costs of CO2passedthrough in the electricity prices falls under the

competences of the Commission. These StateAid rules will set the maximum compensationthat Member States could provide to indus-tries exposed to carbon leakage due to CO2costs passed on in electricity prices (so-calledindirect emitters).

The chlor-alkali industry, as part of the sectorbasic inorganic chemicals (according toNACE 2413), has been recognized as one of theexposed sectors. The exposed sectors will beeligible for free carbon allowances or for finan-

cial measures under the state aid rules.

At the beginning of this year the EuropeanCommission confirmed that the State Aid rulesshould be available by the end of the year. EuroChlor welcomed the Commissions recognitionof the importance to have the rules in placeso that industry can get their dossiers readyand talk to their national authorities prior therevized ETS Directive enters into force on1 January 2013.

Stakeholders have the opportunity to pro-vide their input and comments on the draftrules during two internet consultations. Thefirst consultation ended on 11 May 2011. Thesecretariat had set up an ad hoc working groupsome time ago to deal with ETS matters andthe team worked hard to complete the complexquestionnaire.The task was challenging because of differingelectricity market characteristics in differentparts of Europe which do not match countryboundaries. But working in a cooperativespirit the differing views were largely resolvedenabling a representative industry view to besubmitted. Some individual member compa-nies made their own submission with companyconfidential data but these did not conflict withthe unified view.

A second consultation will follow later this year.Euro Chlor will again provide a consolidatedinput on behalf of the chlor-alkali industry.

Mercury Export Ban and Storage

The EU Regulation EC 1102/2008 on the ExportBan and Safe Storage of Metallic Mercuryentered into force on March 15thof 2011. ThisEuropean Regulation aims to ban the exportof mercury and imposes a storage obligationof mercury. This requires the development ofstorage criteria for end-of-life mercury underthe Landfill Directive. According to the Regula-tion the criteria should have been developed byJanuary 1st2010. When the Regulation enteredinto force Euro Chlor sent a letter to the Com-mission to draw attention to the uncertainty

Electricity efficiencyof our member

companies is amongthe best in the world

23CH 03 REGULATORY AFFAIRS

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regarding storage of the excess mercury facedby Euro Chlor member companies using themercury technology and planning to convert.

In early April temporary storage criteria havebeen proposed by the Commission for votingby a special Comitology Committee. However,several Member States had significant com-ments and objections to the proposal andfinally the criteria were not voted. The Com-mission then proposed a Directive to amendthe Landfill Directive (1999/31/EC) with regardto specific criteria for the temporary storage ofmetallic mercury considered as waste, whichwas not decided upon when this Review wentto press.

Criteria for permanent storage of end-of-life mercury still lacking

There is little interest for our industry fortemporary storage. For Euro Chlor companiesit is much more important to have criteria forpermanent storage. An investigation into thesafety of permanent storage of liquid mercuryis ongoing in Germany, but these studies maystill take several years before being finalized.Euro Chlor member companies thereforecontinue to look into other permanent disposalsolutions, including stabilized mercury, follow-

ing closely the developments offered by varioussuppliers.

EU Mercury Strategy still recognizesEuro Chlors voluntary phase out

The Commission published a review of theCommunication on the EU Mercury Strategy inDecember 2010. This strategy covers all mer-cury uses in the EU and aims to reduce both

use and emissions. Since the very beginning ofthe mercury strategy Euro Chlor has contrib-uted by providing factual information on useand emissions of mercury in our sector.The Commission Communication was dis-cussed in the Environment Council on March14, 2011. Despite an attempt to introduce anearlier phase-out initiated by a group of threeMember States, Euro Chlors voluntary com-mitment to phase-out to end the use of mer-cury in the Chlor-alkali production by the endof 2020 is still recognized by the authorities.

On March 17, the same Communication wasalso discussed in the Environment Committeeof the European Parliament), but there wasno discussion on chlor-alkali related mercuryissues during the public session.

The overall mercury strategy of the Commis-sion therefore is still broadly supported.

Training is at theheart of safety and

the safety culturewhich is essential

in Euro Chlorcompanies

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Dolf van Wijk came to EuroChlor in 2001 and was ap-pointed Euro Chlor ScienceDirector on January 1st, 2010.

As of January 2011 he has additional responsibility forRegulatory Affairs.

Euro Chlor brandingEuro Chlor succeeded in building a credible name withmany in the regulatory and science community in the

past. High external pressure on the chlorine sectorstimulated the development of a well-organized indus-try association with a strong support from its membercompanies. The threat was directed specifically on chlo-rine, putting our industry in the forefront of many en-vironmental debates and regulations. This foregroundposition has gradually changed into broader and lessspecific challenges. But earlier topics still emerge everynow and then, sometimes still with a specific focus onchlorine.

EU increasingly risk averseTodays pressures generally focus on the broader checal industry. In addition, Europe is continuing onpath of ignoring the importance of science and techogy and becoming increasingly risk averse. Chemicadustries role to innovate society to meet future needgaining some acceptance but the regulatory framewnecessary to accommodate these new developmeand needs is not sufficiently developed. The scienknowledge and tools for effective and up-to-date re

lations are available, but there is a great reluctanceincorporate these in legislation.

These broader and more global challenges and nemerging ones like mixtures or green chemistry wilchallenging for Euro Chlor in the coming years. I looking forward to contribute to ensuring we remaineffective organization defending the sustainable futof the Chlor-Alkali industry.

Dolf van WijkScience and Regulatory Affairs Director

Teaming up science and regulatory affairs

Over and over again,PVC proves to bea hit in sustainableconstruction

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Elegance andefficiency combined

thanks to the qualitiesof polyvinylchloride

Chlor-alkali metallic mercury reportingto the CommissionThe EU Regulation on export ban and storageobligation (1102/2008) requires that quantitiesof metallic mercury on chlor-alkali sites arereported yearly to the Commission, starting

December 2009.

The Euro Chlor proposal to gather the datafrom the member companies utilizing the mer-cury cell technology has been recognized by aCommission Recommendation. All membercompanies contributed and we were successfulin providing the following data for each report-ing year: Best estimate of total amount of mercury stil

in use in the chlor-alkali cell and Total amount of metallic mercury stored in

the facility, even if shut down.

The data are publicly available on DG Environ-ments website http://ec.europa.eu/environ-ment/chemicals/mercury and can also beconsulted at the EuroChlor website. Their evo-lution shows a continuous and rapid decreasedue to the successive conversions of chlor-alkali plants using the mercury technology.

The export ban with storage obligation hasbeen in force since March 15 2011, and metallicmercury that has been sent as waste to tempo-rary or permanent storage facilities will have tobe reported (next reporting in 2012).

Caroline Andersson has a Master of Science in BusinessAdministration (MBA). She is closely monitoring legislativedevelopments and initiates advocacy activities, in close con-sultation with the Membership. She has privileged contactswith the European Commission and Parliament in order todiscuss and present the views of the European Chlor-Alkaliindustry. From January 2011, she is also working as Cefic sec-tor group manager.

For several years now, the energy issue and particularly theEuropean Emissions Trading Scheme (ETS) have been domi-nating the regulatory activities. The Euro Chlor advocacy onthis issue has entered a new crucial phase as the Commis-sion has launched its stakeholder consultation on the stateaid rules for compensating electricity intensive industries forthe CO2costs passed through in electricity prices. Euro Chloris actively contributing to the development of the rules.

Caroline makes sure that Euro Chlor does not miss importantdevelopments, and has the necessary timely contacts inter-nally and externally to stay on top of the issues that matterfor the member companies.

Caroline AnderssonSenior regulatory affairs counsellor

Stayingactively on topof regulatoryissues that matter

for the members

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Chlorine poetryin action

Blacklists still a regulatory tool:POPs/PBTs and SVHCs

In Europe, Substances of Very High Concern(SVHCs) are managed under REACH. Despitethe regular assessment of all substances underREACH, additional requirements are applied

for SVHCs under the so-called Authorization orRestriction regimes. SVHCs are PBTs (sub-stances which are Persistent, Bioaccumulate inthe food chain and are Toxic), CMRs (Carcino-genic, Mutagenic or Reprotoxic) or substancesof equivalent concern (to be determined ona case by case basis). Substances which meetthe hazardous properties criteria of SVHCsare not by definition put under Authorization.It is up to Member States to decide whetherthey will compile an Annex XV dossier for asubstance, which effectively is a proposal to

put them on the candidate list for Authoriza-tion. Alternatively, the route of Restriction maybe followed to risk-manage specific uses ofa substance more stringent than under theregular REACH regime.

Euro Chlor related substances which areSVHCs are trichloroethylene, which is consid-ered carcinogen cat. 1b - and therefore fulfilsthe CMR criteria - and SCCP which is a PBT.Trichloroethylene has been placed on the can-didate list for authorization with prioritization

and for SCCPs the EU competent authoritiesdecided to keep the substance listed underRestrictions (Annex XVII). In addition, they areplanning to include the substance in the EUDirective on POPs (EC 805/2004) based onthe decision of the UNECE LRTAP Conventionto list the substance as a POP (POP Protocol).

Chlor-alkali BREF update

The new Industrial Emissions Directive rein-forces the importance of the Best AvailableTechniques reference document (BREF) forpermitting the production units, and particu-larly of the BAT conclusions.

In the framework of the chlor-alkali BREF up-date, Euro Chlor created an ad hoc task forceto define the industry position and gather thenecessary information; this task force has pro-duced a huge number of technical documentsto submit correct and detailed information tothe technical working group in charge of theupdate work.

A first draft of the updated BREF, withoutthe specific BAT chapter is expected before

the end of 2011. Some chapters are howeveralready available on the dedicated Commissionwebsite and Euro Chlor has proposed com-ments and possible improvements.

Due to the lack of some information inthe answers to the previous questionnaireprepared by the Commission, an additionalinformation collecting round is planned for thisautumn, with the help of Euro Chlor.

CourtesytoINEOSChlorVinyls



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Some Member States suggested this routewould be a faster way to ban the substance.

At the end of 2010, Germany attempted topropose trichlorobenzene as a substance ofequivalent concern based on perceived PBTproperties. Thanks to Euro Chlor past workdone by its Marine Risk Assessment Groupand follow-up work by the EnvironmentWorking Group, we could rapidly react to thisattempt. It was possible to very quickly submita scientific paper demonstrating that TCB doesnot fulfil any of the PBT properties and, there-fore, should not be nominated as an SVHC.The nomination by Germany also met with alack of support from several Member States, sothe proposal did not proceed. This can be seenas a support for the need of a solid scientificbasis for substances to be proposed as SVHC

based on equivalent concern.

Stockholm Convention on POPs

The Stockholm Convention deals with POPs(Persistent Organic Pollutants), i.e. PBTs thatare persistent enough to travel long distancesand have adverse effects far from their point ofrelease. The fifth COP meeting (Conference of

the Parties) of the Stockholm Convention washeld end of April. The major issue was the list-ing of endosulfan as the 22ndsubstance on thelist, which started initially with the well-knowndirty dozen. However, the COP meetingfaced considerable difficulties regarding theConventions efficacy. This was exemplifiedby the many exemptions and (long) timelinesagreed for endosulfan, as well as by repeateddiscussions on financing of the Conventionsactivities and compliance checking. The lattertwo topics were postponed again to the next

COP (COP6 in 2013).In a final statement at COP5, the EU an-nounced they would nominate three new sub-stances as candidate POPs to be added to theConvention. These were HCBD (hexachlorobu-tadiene), PCN (polychlorinated naphthalenes)and PCP (pentachlorophenol). Euro Chlor andWCC will follow up the nomination of HCBD,which is an unintentional by-product relatedto our industry. Material has been preparedto contest the need for nomination of thissubstance. The evidence demonstrates thatit is unlikely, based on current environmentalconcentrations, that HCBD poses adverseenvironmental or health effects.

Top maintenance by highlyqualified personnel isessential to achieve top HSEperformance

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20102009200820072006200520042003200250

55

60

65

70

75

80

85

90

95

WCC - Chlor-alkali Industry / Number of plants andcapacity of mercury electrolysis units (in USA/Canada/Mexico, Europe, Russia, India and Brazil/Argentina/Uruguay)

Number of plants

Hg plants Capacity

Capacity (millions of tonnes)/y

0,0

0,5

1,0

1,5

2,0

2,5

3,0

201020092008200720062005200420032002

WCC - Chlor-Alkali Industry / Total mercury emissions(air + water + products)(for USA/Canada/Mexico, Europe, India and Brazil/Argentinaplus 1 Uruguayan and 3 Russian plants from 2005 onwards)

t Hg/yearg Hg/t Cl2 annual cap.

Specific emissions Total emissions

The World Chlorine Council reportedupdated figures to the United Nations

Global Mercury Programme on theprogress made in the chlor-alkali industry

in reducing the use and theemissions of mercury


UNEP Global Convention on Mercury

At the UNEP Governing Council/Ministerial Fo-rum convened on February 16-20, 2009 a decision

was reached to establish an international conven-tion to deal with mercury pollution which shouldinclude both binding and voluntary measures. Thedetails of the new convention will be negotiatedover the next years and will be completed by 2013.

The UNEP meeting also decided on the provisionsfor the future mercury convention. The require-ments that will be applicable to the chlor-alkaliindustry and VCM production are on reduction ofemissions, measures on use and trade of mercuryand addressing mercury-containing waste. TheUNEP Partnership for the chlor-alkali industry con-tinues under the US government lead. WCC is anactive partner in this programme. The followingpositive results were reported to UNEP by WCC:

The number of plants and the mercury cell-basedproduction capacity continue to show a world-wide decrease: the number of plants went downfrom 91 to 57 over the period 2002-2010 (-37%)and the mercury cell-based capacity from 9.1million tonnes to 5.5 million tonnes (-40%).

Global mercury emissions have been further

substantially reduced in the period 2002-2010.They went down from 24.6 tonnes/year to about6.7 tonnes, or 73% decrease over the eight yearsof reporting by WCC. The emissions expressedin g mercury/tonne annual chlorine capacityshow the same trend.


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04Science

Effective advocacy based on sound science

Advocating sound, science-based regulatory

decision-making has been Euro Chlors core

business for more than twenty years.

In 2010-2011, the organizational and technical

challenges posed by REACH, chlorine-based

biocides, classification and labelling and

chemicals of special concern constituted key

issues in the Federations science activities.


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assessment dossier, whole effluent testing,Water Framework Directive impact and mixtureissues.

REACH registration

The major achievement of the last 12 monthshas been the preparation and registration ofdossiers for eight high-production volumechemicals, under the European REACH Regula-tion (EC/1907/2006). The lead dossiers for allsubstances were submitted on time, as well asthe individual dossier that each legal entity wasrequired to submit. Several technical hurdlescropped up as we reached the finish line,including managing Letter of Access (LoA)sales, management of the SIEF and prepara-tion for classification and labelling (discussed

further below). The lead dossier consistedof the IUCLID file, which is itself made up ofstudy summaries for all the data identified forspecific substances. Additionally, many of theconsortia decided to prepare a chemical safetyreport (CSR) in common to reduce costs wherepossible. All consortia are managed by EuroChlor / ECSA staff working under the umbrellaof ReachCentrum, and the substances coveredare: caustic soda, chlorine, ethylene dichloride,hydrogen chloride, perchloroethylene, potas-sium carbonate, potassium hydroxide andsodium hypochlorite. The chlorinated solventsconsortium covers the five substances tetra-chloroethylene, trichloroethylene, chloroform,carbon tetrachloride and dichloromethane.But just because the registration deadlinehas been met, we must not be complacent.Further work is required with the possibility of

Revitalization of the science programme

Euro Chlor and its member companies areproud of the high quality and effective sciencework that we do. Due to the immediate priorityof REACH registration over the past two years,some of the science work had to be put on

the back burner. However, now that the 2010REACH registration deadline has passed,several meetings have been held on how toreorient the science teams towards providingthe best possible value science support to ourmembers. The science teams are structuredaround three core groups. The Science SteeringCommittee (SSC) meets twice a year to discussthe priorities for the science programme andthe required budget for various projects. Underthe SSC are two teams, the Health WorkingGroup (HWG) and the Environment Working

Group (EWG).The HWG is made up of toxicologists, occu-pational physicians and epidemiologists, whomeet twice a year to discuss medical and toxi-cological issues. This year the group has beenarranged into issue teams which work onspecific issues such as EMF, mercury exposureand disinfection by-products, and report backto the main HWG. The HWG also organizesa yearly literature review of studies published,which may be of interest to the chlor-alkalicommunity.

The EWG is made up of environmental expertswho work on several specific projects of valueto the Euro Chlor membership. These issuesinclude developing a PBT risk assessmentmethodology, the hexachlorobenzene risk

INEOSChlorVinyls

Pumping brineand caustic sodain an electrolysisunit

31SCIENCECH 04


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our dossiers being evaluated at some stage,new data going into the REACH dossier whererequired, and the preparation of summary ex-posure scenarios to append to the eSDS. Somesubstances have, moreover, been earmarkedby authorities as requiring further work onenotable example being EDC, about whichSlovakia has submitted an annex XV dossier byAugust to identify EDC as a substance of veryhigh concern.

A REACH dossier for mercury was prepared bythe Belgian-based consultant ARCHE, whichspecialises in risk assessments of metals. Thecooperation of the companies involved wasorganized by Dela (a German recycling firmdealing with the recovery of mercury). EuroChlor provided technical and scientific supportbefore the registration deadline.

The chlorinated paraffins (medium-chain, long-chain and sulpho-) were managed separatelyby a consultant, and were also successfullyregistered.

Biocides

The registration of chlorine, sodium hypochlo-rite and calcium hypochlorite as active sub-stances under the Biocidal Products Directive(98/8/EC) is continuing, albeit a little behindschedule. The registrations for product typesof Main Group 1 (disinfectants and generalbiocides) were submitted in mid-2007. The dos-siers for the three substances have been evalu-ated, and the draft competent authority reportwas provided to us for some minor correction.

The backbone of the Euro Chlor Science team, Shaun Presow,was awarded a PhD in Chemistry in Germany in 2008 beforejoining the Federation in 2009.

Data management and sharingShaun is involved in the management of health data providedby Euro Chlor member companies. These data include mercuryin workers urine, the self-assessment audit, in which com-panies assess their progress against Euro Chlor best practiceguidelines in various areas, and reporting on chlorine inhala-tion incidents. The collated data is made available to the Gen-eral Technical Committee and the Health Group for analysis,discussion, benchmarking and improving existing Guidelinesin Best Practice documents.

Euro Chlor scienceSince January 2011 Shaun has been organizing the work of theEnvironment Working Group and assisting in the managementof the Science Steering Committee. Additionally he has takenon tasks within the Chlorinated Paraffins Sector Group.

REACHShaun is managing the dossiers for chlorine, hydrogen chlo-ride, sodium hypochlorite and ethylene dichloride, as well asfollowing up generic REACH issues for Euro Chlor. He is alsoresponsible for the Biocides dossiers, namely the active sub-stance registration for chlorine, sodium hypochlorite and cal-cium hypochlorite.

Euro Chlor scientific communicationSince the beginning of 2010 Shaun has taken over the manage-ment of science communication which covers for example theScience Dossiers (in-depth reviews on various chlorinated sub-stances and topics addressing the scientific community) andthe Focus on Chlorine Science (FOCS) leaflets aiming to helpnon-scientists understand chlorine-related science issues.

Shaun PresowScience Counsellor

Quality datacollection is vitalto continuedimprovement in

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In this report, the Rapporteur Member State(RMS) agreed with our conclusions. Mem-ber states and other stakeholders were thenprovided with an opportunity to provide theirown comments, which they did before theend of January 2011. The RMS then prepareda synthesis of these comments, after whichthe substances will be discussed at TechnicalMeetings. Euro Chlor will attend these meet-ings with experts from member companiesto respond to any comments of the memberstates identified during the commentingprocess. If all goes well, we would expect alisting of the substances in Annex I of the BPDmid-2012. A second series of dossiers for MainGroup 2 (preservatives) were submitted inOctober 2008 for the three active substances.These dossiers have been assessed as com-plete by the RMS, and have entered the evalu-

ation procedure. This should be completed in2011.

Classification and labelling

January 3rd2011 was the deadline for the clas-sification and labelling of substances under theCLP regulation (EC/1272/2008). The classifica-tion of all substances, no matter what tonnageproduced, had to be notified to ECHA beforethis deadline. For most of our members, thiswas done in the REACH dossiers, but for thosewho did not submit a REACH dossier (due toa lower tonnage band) the substance had tobe notified separately. All REACH consortia,as a part of their work, provided their recom-mended classification and labelling to theREACH consortia and SIEF members, and the

documents are available on the Euro Chlorwebsite. Euro Chlor also provided a recom-mendation for calcium hypochlorite, as noREACH consortium is managed by Euro Chlorfor this substance.

Additionally, several amendments (calledadaptations to progress) have been publishedfor the CLP regulation, amending the classifica-tions. The most recent of these - published inMarch 2011 - introduced chronic toxicity criteriafor the environment, which meant that theclassification for sodium hypochlorite had tobe amended. Moreover, the sodium hypochlo-rite consortium organized further testing ofthe substance on Ceriodaphnia dubia, whichconfirmed that the substance should keepthe M-factor of 10, and thus be labelled asdangerous to the environment in concentra-

tions greater than 2.5%. Mixtures may have adifferent classification threshold due to specificmixture testing.

Occupational health issues

In 2010 an occupational health workshopwas held on mercury in Brussels. It was wellattended, and feedback received was excellent,so we are considering holding a repeat work-shop. This will be organized in early 2012 if it isdecided to push ahead.In early 2011, the Health Group also provideda questionnaire to all members regarding thehealth activities, to develop ideas around wayswe can best support our membership throughthese activities.

Protecting lifeon the move:polycarbonateenables a safevision for thebiker

BayerMaterialScienceAG

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An update has been organized for the chlorineexposure questionnaire, which we ask mem-bers to return after an incident that results inhuman exposure. This questionnaire collectsdetails on the magnitude of exposure, symp-toms shown and treatment given. By collectingthis information, we hope to build a pictureof how incidents are occurring across theindustry, and how these can best be treated tooptimise treatment outcomes.

The results of the mercury in urine question-naire for 2009 and 2010 had an excellentresponse rate, with 100% achieved in 2010.The results also showed a general decrease inexposure in 2009, followed by a levelling offin 2010. There is still room for improvement,particularly at some sites.

Disinfection by-products, chlorineand asthma

The European Union is investigatingthe health-related effects of disinfectionby-products (DBPs), by financing the researchproject HIWATE. The main findings werepresented during a 3 day meeting in 2010 andpublications are forthcoming.

Significant progress was made in our efforts to

understand suggested links, based primarily onepidemiological studies, between swimmingin chlorinated pools and respiratory symptomsincluding asthma. Euro Chlor organized anExperts Panel discussion on the subject duringthe International Conference on SwimmingPools and Spas, Porto, on 15 March.

The results of a study which Euro Chlor sup-ported with the University of Utrecht (part ofthe EU HITEA project) on more than 2000Dutch children were presented. The studyfound no link between swimming pool at-tendance and asthma or wheezing or rhinitis:it also provided valuable data on the typicallevels of trichloramine (a respiratory irritantby-product of chlorination) to which thesechildren were exposed.

The Utrecht results are paralleled by thosefrom a new longitudinal study on almost 6000children from the ALSPAC cohort in the UKwhose health and lifestyle have been followedin detail from birth. This study also found noassociation between swimming (invariably inchlorinated pools) and the risk of asthma. Onthe contrary, the authors noted that swimming

was associated with increased lung functionand lower risk of asthma symptoms, especiallyamong children with pre-existing respiratoryconditions.

Reviewing these two large studies, and relevantliterature published since a previous workshopin Leuven in 2007, the Experts Panel con-cluded that the accumulated evidence doesnot support the suggestion sometimes madethat swimming in chlorinated pools as a childhas been a major factor in the rise in asthma

in recent decades. Work will continue to clarifyany possible more limited risks for all sectionsof the population.

Having fun with PVCin a clean swimmingpool: chlorine isgiving a hand to both

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Left picture:Flexible and elasticpolyurethane shapethis comfortable Itaseat

Right picture:

Flame-retardantpolyurethane skin

is used for thesefashionable rearprojection monitors

Euro Chlor presents its science work atthe SETAC Europe Congress in Milan

The 2011 SETAC congress in Milan was at-tended by over 2,000 environmental scientists,chemists and ecotoxicologists from aroundthe globe. The congress consisted of 4 days (8

parallel sessions) of presentations and dailyposter sessions. This year mercury did notfeature prominently, but legacy PCBs remainedhigh on the agenda, and several postersdiscussing water chlorination as a method forremoval of pharmaceuticals or other chemicalsfrom drinking water were presented. There wasa lot of interest in the Euro Chlor booth, withthe new FOCS on long-term mercury exposureand the selection of science dossiers available(http://eurochlor.amaze/download-centre/science-dossiers.aspx).

Additionally, Dolf van Wijk presented the workEuro Chlor has done on hexachlorobutadiene,showing how this persistent, bioaccumulativeand toxic substance can be risk assessed, andthat the substance shows no risk to predatorsthrough secondary poisoning.

Kees van Ginkel from Akzo Nobel presentedwork done on the biodegradation of chlorinat-ed paraffins, showing how the biodegradationpotential is linked to the degree of chlorination,

and that chlorination above 50% retards thedegradation of CPs.

New Science Publications

Now that the REACH registration for the chlor-alkali substances is largely behind us, morefocus can be turned towards the Euro Chlorscience agenda, and a major part of this is thepublication of this science work.

In early 2011, Euro Chlor published two newFOCS (Focus On Chlorine Science) docu-ments, which are designed to give a quickintroduction to various topics. The first,entitled Metallic mercury: the health effectsof long-term, low to moderate exposure is adistillation of the complex discussion in ourscience dossier of the same name. In clear, un-derstandable language, this shows that the ef-fects of long-term low exposures leading to ex-posures of lower than 30g/g creatinine pose

no risk to workers. The second FOCS discussesthe issues around bioaccumulation how it isdefined, how substances bioaccumulate andhow to risk assess these substances.

It is hoped later this year to prepare a sciencedossier on the human health effects of disin-fection by-products from the use of chlorine. Arisk assessment for hexachlorobenzene is alsobeing finalized for publication by the Environ-mental Working Group.

BayerMaterialScienceAG

Tecnopols

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Marleen Pauwels joined Euro Chlor on 1 September 2011 as Sec-tor Group and Science Manager. She will manage some FluorSector groups for half of her time, while the other half she willbe managing the health related science issues for Euro Chlor.

Toxicity and health

Marleen is a doctor in pharmaceutical sciences and obtainedher PhD degree in 2008 at the Vrije Universiteit Brussel (VUB)on a thesis entitled: Critical evaluation of the current EU regu-latory framework for the safety assessment of cosmetics.

She started her career at this university giving logistical andscientific support to the experts of the Belgian High Councilof Public Health. Marleen then went to Albemarle Europe as aSenior Regulatory Affairs and Toxicology Analyst. She then re-turned to the VUB to take on responsibility for the preparationof technical information files and their acceptance by authori-ties for cosmetic companies in order to put them in compliancewith the current cosmetics legislation.

For her science activities in Euro Chlor Marleen will be deal-ing with a variety of health and toxicity related topics, includingmercury and occupational exposure and chlorine and asthma.

Marleen PauwelsSector Group and Science Manager

Glad to be partof the Euro Chlorteam

Workers exposure to electromagneticfields (EMF)

The update work on the European Directive toprotect workers against the effects of electro-magnetic fields has led to successive draftdocuments discussed with the social partners.

The final draft, integrating the latest ICNIRPguideline for low frequencies EMF and theGerman authorities study results, has led tothe editing of a formal opinion by the AdvisoryCommittee for Safety and Health. The Com-mission was asked to make several technicalimprovements and to add clarifications to thedraft Directive. In the latest version distributed,the Commission has mostly integrated thecomments made by the stakeholders, and theDirective has been submitted to the Counciland the Parliament just before the summer.

Clarifications are still required, but they willprobably be integrated in a guideline to beprepared by the Commission with the stake-holders. The target is to have this new directivevoted before April 2012, allowing the old oneto be repealed before the time limit for itsimplementation.

In parallel, Euro Chlor is restarting the workwith CENELEC to finalize a standard formeasurement methods applicable to the

electrolysis industries, based on the new draftDirectives content.

AkzoNobel

In the International Yearof chemistry (IYC) 2011,

focus is put on motivatingwomen to develop a career

in chemical science



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New pages in history of aviation are written bythe SOLARIMPULSE, the worlds first airplaneaiming to fly night and day around the worldonly propelled by solar energy.

Chlorine chemistry contributes to the manu-facturing of its 12,000 solar cells, lightweightpolyurethane foams and unbreakable polycar-bonate films and sheet for the cockpit glazing.

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05Communication & Education

Relevant, scientific and timely information

The European chlor-alkali industry has based

its reputation management on providing

relevant, scientifically sound and timely

information. Stakeholders are info

Documents

Annualreview 2010