chlorine industry review 2009-2010

7/24/2019 Chlorine Industry Review 2009-2010

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The spectre of substitution

calls for vigilance

Chlorine Industry Review2009-2010


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09

Chlorine Industry Review

2009-2010

Tackling issues

in a transparent manner

Cover:Clean, healthy water has been associated for more than a century with chlorination.However, few people are aware of the fact that chlorine and its co-product caustic soda arebuilding blocks for many high-tech product lines that are among many other applications essential for more efficient energy management on Planet Earth.

The spectre of substitution

calls for vigilance


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01 Introduction 04 The spectre of substitution calls for vigilance

02 Sustainability 06 Continuous efforts for improvement

03 Regulatory affairs 16 Balanced legislation for a sustainable future

04 Science 24 Effective advocacy based on sound science

05 Communication & education 32

Relevant, reliable and timely information

06 Industry overview 36 European chlor-alkali industry severely hit

07 Chlorine production plants 42 January 2010

08 Euro Chlor 44 In the centre of chlor-alkali regulatory and HSE issues

3CONTENTS


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CHLORINE INDUSTRY REVIEW2009-201004

01

Introduction

The spectre of substitution callsfor vigilance

Has our industry become the object of media

attention again? And if it has, in what way,what are the implications and should we beconcerned?

The answer is yes, but not directly and yes, weshould be concerned. For some time now theRegulation on Hazardous Substances (RoHS)has been under review by the European Parlia-ment with the environmental lobby calling for aban on organochlorines, organobromides andPVC for use in electric appliances.

Now this may not immediately ring any alarmbells but it is not an isolated event. Earlier thisyear a restriction on the use of dichlorometh-ane in paint strippers (except for industrialinstallations) was passed which signals thatthe full frontal attack on chlorine which oc-

curred in the nineties may have diminishedbut chlorine containing substances are stillthe subject of attention today. What we shouldbe most concerned about is the manner inwhich these decisions are taken. I refer to theextravagant and libertine use of the Precautionary Principle where the risk based decision-making process is pushed aside and replacedby the doom driven imaginations of activists.In the event, the Parliamentary EnvironmentalCommittee and the plenary vote in Parlia-ment did not result in a ban but these chlorine

containing substances are put in a candidatelist for future consideration so the threat hasnot gone away.

This may sound very benign but there are im-plications here which need to be kept in mind and this is what we should be concernedabout. It is the spectre of substitution.

Consider this the Cefic Policy Centre seessubstitution being implemented in two dis-tinctly different ways. The first is the obviousone by legislation. Under REACH, authoriza-tion will be given on condition of a legal obliga-tion to substitute by a given date. The secondone which I am addressing in this foreword ismarket driven substitution.


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5CH 01 INTRODUCTION

Market driven substitution can be more dif-ficult to tackle because it is never obvious justwho is driving it in any particular instance. TakePVC for example, the largest single consumerfor chlorine, and the recent case of dichlo-romethane. It is all very well to say its the

environmentalists who are the activists tryingto have it banned but downstream users andretailers play a role here too. This stakeholdergroup is driven by a desire to satisfy andattract consumers using a strategy based onconsumer perceptions of environmental andhealth risks. The question of how we can influ-ence such perceptions must remain rhetoricalfor the moment.

There is nothing new in this what is new isthe threat of self-destruction brought about

through the opportunity to profit from deselec-tion through the supply of substitute productsby manipulating the regulatory process. Thereare increasing instances of companies encour-aging legislators to resist defense strategies byoffering substitutes whose testing provenanceis often not complete. This is bad practice andwill result in splintering our chemical industryas a whole. We will look foolish, and worse stillour efforts to act from a position of unison andthe strength which that brings will be seriouslycompromised.

On a more positive and less controversial noteit is gratifying to report that investment in newmembrane plants to replace mercury-basedones continues even in the austere economicclimate in which we still operate. Membranetechnology now accounts for 50% of ourinstalled capacity which means we remain on

track in meeting our voluntary commitment tohave converted all mercury based chlor alkalicapacity by 2020. Considering the slow rateof recovery in our sector this is a major act offaith by our membership!

Meanwhile, within the climate change andenergy arena the ETS debate continues. At thetime of writing, a paper from DG Competi-tion detailing guidelines enabling the MemberStates to offer state aid to electro-intensiveindustries is still awaited. This is many monthsoverdue and probably reflects a change inthinking from the new Commissioner influ-enced no doubt by national governmentsand other stakeholders. In the aftermath ofCopenhagen where no global agreements wereachieved, calls to increase carbon emission

targets from 20 to 30% have so far been suc-cessfully rebutted by manufacturing industry.Optimism remains high that we will succeed inachieving some measure of state aid compen-sation for carbon inflated electricity prices butthe level is very much in question with the realeffect of carbon leakage being challenged.

For the future we will remain vigilant inidentifying the threats for our industry but areoptimistic that we can deal with these throughthe collective efforts of our membership.

Alistair J. SteelExecutive Director

It is gratifying to report that invest-ment in new membrane plantsto replace mercury based onescontinues even in the austereeconomic climate the chlor-alkali

industry operates inVinnolit


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02

Sustainability

Continuous efforts for improvement

Perhaps it is rational that progress towards

our 2010 sustainability goals has diminished.

In some areas achieving further improvementbecomes much more difficult as we approach

the targets. Still, those companies in the

upper quartile of performers have been able

to maintain their position. As a professional

organisation we must ask ourselves what

needs to be done in order to realise the

improvement we aim at. If we dont, we

waste an opportunity to create value.

Alistair J. Steel


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7SUSTAINABILITYCH 02

Unified strategic approach

All of the Western European chlorine manu-facturing members of Euro Chlor agreed in2001 on an industry-wide strategy that focusedon six voluntary commitments. These werefirst developed to ensure a united industryapproach and commitment to address keysustainability concerns: Include environmental, social and economic

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

production; 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 transportationof chlorine.

In parallel, data was collected for 2001-02and with this information, 14 performanceindicators and improvement goals were agreedamong producers and announced by EuroChlor in January 2003. Then the following year,a 15th indicator was added that required mem-bers to gain EMAS and/or ISO 14001 Environ-mental Accreditation for their plants.

These indicators come under the followingmain areas: economic aspects of produc-tion, environmental protection, safety andsocial progress and for some of them targetswere fixed for 2010. Each year, producers arerequired to report their progress to Euro Chlor,which combines feedback to report to the asso-ciations Management Committee prior to an-

nual publication of the industrys performance.In this section, we report on performanceindicators and progress in 2009. Whilst theprogramme continues to be a powerful forcefor change, not all the indicators show thesame degree of progress.

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:As for the previous year, there wasan increase in 2009, but the average energy

consumption is still slightly below the targetfixed for 2010, with a value of 3,445 kWh/t ofchlorine produced. The global trend is relatedto the progressive conversion from mercury tomembrane technology, with the last two yearsdisruptions probably due to production ratefluctuations caused by the economic crisis.Background:Since electricity is an indispens-able raw material of the chlorine productionprocess, the basic consumption correspond-ing to the electrochemical reaction cannot be

significantly 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 produ-cers and based on steam and electricity. Energyis mainly used for electrolysis (transformers,rectifiers and cells) and also for illumination

Many effectiveand safe crop pro-tection formulaerely on chlorinatedsubstances

BayerCropScience

BayerCropScience


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8 CHLORINE INDUSTRY REVIEW2009-2010

3200

3250

3300

3350

3400

3450

3500

3550

3600

3650

3700

2010200920082007200620052004200320022001

70

75

80

85

90

95

100

2010200920082007200620052004200320022001

Energy consumption Hydrogen usedkWh/tonne of chlorine %

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

Energy consumption

RealObjective

Hydrogen utilisation

RealObjective

and motor power (pumps, compressors, cen-trifuges, etc.). Steam is used mainly for causticsoda concentration to 50% and for minorutility purposes.

Hydrogen use

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

Update:In 2009, the percentage of hydrogenuse again increased slightly to 88.1%, butthe general trend has been roughly flat forseveral years, with a value quite low comparedto the target of 95%. About one third of thecompanies are below 80%, with two not evenreaching 50%.

Comment: The 2010 goal will be very difficult to

achieve, but several hydrogen fuel cell projectshave been announced!

Background:High-quality hydrogen is co-pro-duced with chlorine and caustic soda during theelectrolysis of brine. This can be used as a rawmaterial for other processes or as fuel to pro-duce steam; technologies are in development toallow for local electricity recovery via fuel cells.

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 representsalmost half (49.8%) of the installed productioncapacity at Euro Chlor members. The mercuryprocess accounts for 33.5% at the beginning of

2010, continuing the progressive phase out of thistechnology in line with the Chlor Alkali sectorsvoluntary agreement. The diaphragm process stillaccounts for about 14% of the total capacity.

Economic development

Target: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 2009, 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 the

location of all plants and a table indicating thelocation, ownership, technologies and capacityof each plant (see p.43 for the situation at theend of 2009).

Safety & social progress

Lost-time injuriesTarget:To reduce lost-time injuries (LTI) to 1.3per million working hours for all workers - bothcompany employees and contractors working

in production units.

Update: The 2009 figures for employees didnot really change (slight decrease of 0.1, givinga value of 7.2 which is the lowest level since2001), but this is still much too high comparedwith the ambitious target of 1.3. Unfortunately,the rate for contractors increased to 8.9.


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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

0

10

20

30

40

50

60

70

80

2010200920082007200620052004200320022001

Number of incidents

Goal:> 75% reduction by 2010

No. incid. Objective

Objective

Comment: All kinds of accidents are consid-

ered here, not only those specific to the chlor-alkali plant. Even if the long-term trends showa small reduction (mostly for contractors),the figures remain much too high comparedwith the target. For employees, the values havestayed roughly level for more than 5 years.There is a marked need for additional effortsby a number of companies in order to achievesignificant improvement for both indicators.

Background:A lost time injury (LTI) resultsin at least one day of absence from work. It

is reported as the number of LTI per millionworking 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 having been at the level of the2010 target for 3 years, the number of incidentsincreased in 2008 and again in 2009 to reacha value of 22.

Comment:The past results show that the 2010target can still be achieved, but efforts areneeded.

PVC sustainable development on track despitethe global recession

As reported by Vinyl 2010 in its 2010 annual progress re-port, the European PVC industry recycled 194,950 tonnesof this chorine-based plastic in 2009, continuing an ex-ponential increase in the recycling of post-consumer PVCsince 2004.

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).

Vinyl 2010 says that progress towards targets set in 2000shows that this particular approach to self-regulation isworking and that the PVC industrys sustainable develop-ment initiative is definitely on track to achieve its Voluntary

Commitment 10-year targets despite the difficulties the en-tire industry has faced as a result of the global recession.

Even old truck sheetingprotection is recycled intohandsome and sustainablePVC handbags

Freitag/PVC

Plus/BertinaKoch


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60

65

70

75

80

85

90

95

100

2010200920082007200620052004200320022001

Responsible Care% of companie

0

200

400

600

800

1000

200920082007200620052004200320022001

Chlorine Transported1000tonnes

Chlorine TransportedBulk railBulk road

Total withoutpipeline

Responsible Care

Actual

Objective

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 include

any of the above chemical spills in air, water orland, which impact human health or the envi-ronment, property or result in evacuation.

TransportationTargets:Zero transport incidents involving thebulk movement of chlorine by 2010. Addition-ally, the tonnage of chlorine transported as apercentage of the total chlorine produced willbe reported annually as well as the mode oftransport involved.

Update: Four transportation incidents werereported in 2009, while only one occurred in2008. The quantity of chlorine transported in2009 was reduced, compared to the previ-ous years, probably mainly influenced by theeconomic crisis: chlorine producers in Europetransported 475,000 tonnes of chlorine, withalmost 70% being shipped by rail and theremainder by road. The transport of chlorine(excluding pipelines) represented a bit morethan 5% of the 2009 production. The aver-age distance chlorine was transported by railremained about 450 km and 170 km by road.

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 is progressively decoupled fromproduction through supplier/customer reloca-tions, where possible, and more use of localpipe lines. Rail transport dominates; road

transport for bulk supply is used only in theUnited Kingdom and, to a limited extent, inSpain, France and Portugal.

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

Update:Some companies are not convinced ofthe desirability of a formal commitment andhave still not signed for the programme. As

last year, the same 33 (out of 37) Euro Chlor fulmembers are participating in national Respon-sible Care initiatives.

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 industry

initiative to continuously improve health, safetyand 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 2009, COC emissions frommanufacturing plants confirmed globally theprevious results for both water and air com-partments, with even some further improve-ment; the consolidated values reached a levelof 78% reduction for water, and more than70% for the air performance.

Background: The COCs were selected fromvarious international regulatory priority lists for

emissions reductions and comprise the follow-ing substances: 1,1,1-trichloroethane; 1,1,2-tri-chloroethane; 1,2-dichlorobenzene; 1,2-dichlo-roethane; 1,4-dichlorobenzene; 2-chlorophenol;3-chlorophenol; 4-chlorophe-nol; carbontetrachloride; chlorine; chlorobenzene; chloro-form; dichloromethane; dioxins & furans (asTEQ); hexachlorobenzene; hexachlorobuta-diene; hexachlorocyclohexane; pentachloro-phenol; tetrachloroethylene; trichlorobenzene;trichloroethylene and vinyl chloride. In 2005,pentachlorobenzene was added to the list of

the substances to be monitored, in line withthe requirements of the EU Water FrameworkDirective. To provide a longer-term perspect-ive of the sectors commitment to reducingemissions, the data shown spans the period1985-2009.

Wolfgang Marquardt studied chemistry at the Ludwig-Maximilians-University in Munich. Before joining Euro Chlorin 2007, he worked on his PhD thesis at the Walther-Straub-

Institute of Pharmacology and Toxicology in Munich.

Wolfgang Marquardt started as science manager in the Eu-ropean Chlorinated Solvent Association (ECSA) and becamethe sector group manager of ECSA in 2009. He is responsiblefor the ECSA Management and the different working groupssuch as the General Technical, Occupational and Environ-mental Health, Product, Communication and Outreach, andSustainability Groups.

REACH and sustainability: challenges for 2010The main focus in 2010 is compliance with REACH. The

REACH registration deadline end of 2010 is valid for five dif-ferent chlorinated solvents; the preparation of the REACHdossiers is covered in a Chlorinated Solvent Consortium un-der ReachCentrum.

Besides regulatory compliance, ECSA has invested a lot oftime in understanding how sustainability can be defined andfurther realised for chlorinated solvent products. Projects areongoing, e.g. ECSA is a partner in an EU project to implementa training module for professional dry-cleaning shops - theLeonardo Da Vinci project with the European Commission.

A pro-active communicationECSA will continue its efforts in scientific programs and onregulatory challenges and is aiming at pro-active communi-cation towards stakeholders. The revamped website deliverscomprehensive information about chlorinated solvents andadds tools for a further dialogue with the downstream usersof chlorinated solvents in the future.

Wolfgang MarquardtECSA Manager

We aim at pro-activecommunication withthe stakeholders


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01

2

3

4

5

6

7

8

9

10

2009

2007

2005

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2001

1999

1997

1995

1993

1991

1989

1987

1985

0

0,1

0,2

0,3

2009

2008

2007

2006

2005

2004

2003

2002

2001

Plant emissions to water

Chlorinated organic compounds

2010Target

1000t/year

0

10

20

30

40

50

60

2005 20102000199519901985

0

1

2

3

4

5

2009

2008

2007

2006

2005

2004

2003

2002

2001

Plant emissions to air

2010Target

1000t/year

Plant emissionsto water

TotalTarget

Plant emissionsto air

TotalTarget

Mercury emissionsTarget:Although all other programme dead-lines are set for 2010, the industry decidedto maintain an earlier 1998 commitment toachieve an emission target of 1 g Hg/t chlorinecapacity on a national basis by end 2007,

with no plant being above 1.5 g Hg/t chlorinecapacity.The industry opted for keeping the earlier date,since from October 2007 all EU chlor-alkaliplants whether membrane, mercury or dia-phragm require an operating permit under theIntegrated Pollution Prevention and Control(IPPC) Directive.

Update:Overall European emissions in 2009amounted to 0.93 g Hg/tonne chlorine capac-ity, practically identical to 2008 (0.92 g Hg/t).

Comment:The real evolution is more dramaticthan what appears on the global trend; therewas a clear reduction of the mercury emissionsto air, but unfortunately we had to integratea relatively high emission value in the liquideffluents of one plant.Three plants are still above the 2007 targetof 1.5 g Hg/tonne chlorine capacity for totalemissions, even if 2 of them are very close tothis value.

Product knowledgeTarget:The industry agreed to provide fulleco-toxicological and environmental data on 29chlorinated substances under the InternationalCouncil of Chemical Associations/ OECDinitiative on high production volume (HPV)chemicals.

Update:These data have been published exceptfor four HPV chemicals which were either nolonger relevant (not commercially availableanymore) or will be covered under REACH witha registration deadline of December 1st2010).Key substance property data of substances

registered under REACH will be made publiclyavailable.

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

Update:there were no changes during 2009and there are still 14 production sites withEMAS accreditation and 54 certified accordingto ISO 14001.

Background:EMAS (The Eco-Managementand Audit Scheme) is the EU voluntary instru-ment which acknowledges organisations thatimprove their environmental performance ona continuous basis. EMAS registered organisa-tions are legally compliant, run an environmental management system and report on theirenvironmental performance through publica-tion of an independently verified environmen-tal statement. ISO 14001 is an internationalquality assurance standard to evaluate anorganisations environmental managementsystems and encourage continuous improve-ment. It helps organisations minimise negativeenvironmental impacts (to air, water or land),comply 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.


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Jean-Pol Debelle has a chemical engineering backgroundand a long experience in chlorine production units withinthe Solvay Group. For more than five years now, he has

been seconded to Euro Chlor to take charge of the techni-cal aspects of health, safety and environmental protec-tion issues (HSE).

Continuous improvement in HSE areasJean-Pol is managing several Working Groups exchangingexperiences between member companies, leading to thepublication of Guidance documents which continuouslyhelp improve performance in the health, safety and envi-ronmental protection areas. These documents are avail-able to the whole membership via the Euro Chlor website.

On a global level (the World Chlorine Council), EuroChlor is working with its international partner associa-tions to enhance HSE aspects of chlor-alkali production.

In support of regulatory workThe technical activities include support to the regulatoryactivities of Euro Chlor through the collection and analysisof technical data. In the health area, exposure to chlorine,mercury and electromagnetic fields are monitored and theappropriate protective measures proposed. Environmen-tal protection covers the emissions of mercury to air, wa-ter and products, and the handling of waste; technological

solutions for further reduction are discussed.

Euro Chlor is also working closely with the national au-thorities for the preparation of the new BAT referencedocument (BREF), which is of vital importance for thechlor-alkali units and their operating permits.

The Euro Chlor sustainability programme continues tomonitor and publish a large number of sustainabilityparameters, thus contributing to the transparency of thesector towards all stakeholders.

Jean-Pol DebelleTechnical Director

We areworking closelywith member

companies forcontinuousimprovementin HSE fields

European mercury emissions 1995-2009(g Hg per tonne of chlorine capacity)

0,0

0,5

1,0

1,5

2,0

2,5

3,0

2009

2008

2007

2006

2005

2004

2003

2002

2001

2000

1999

1998

1997

1996

1995

Products Water Air


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The World Chlorine Council(WCC) is anICCA committee representing the chlorineand chlorinated products industries. The WCCmembership represents over 90 percent of

global chlorine and caustic soda production.Overall, WCC is focused on engaging produ-cers worldwide to achieve its 2007-2010 goalswhich focus on: Engaging the global chlorine and vinyl

industries; Participating proactively in key international

fora 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.

Outreach to the global chlor-alkali sectorIn 2009 and 2010, WCC continued to strength-en relationships with the chlor-alkali associa-tions of Russia, China, India and producersin the Asia-Pacific region. Outreach was alsoinitiated in the Middle-East with a very produc-tive meeting hosted by the Gulf Petrochemicaland Chemical Association (GPCA) attended bycompanies from Qatar and Saudi Arabia whichhave expressed a strong wish to participate infuture WCC activities.

Energy and Climate ChangeDuring 2009 the WCC Management Commit-tee followed the activities of the UN and G8 inorder to provide the views of our industry. At-

tention was naturally focussed on the outcomeof the UN organised climate change summitheld in Copenhagen during December 2009where attempts were planned to reach a globalagreement on CO2reduction targets. Thoughnot optimistic about achieving this there wassome optimism about reaching agreement atthe sectoral level. In the event no such agree-ment was reached with many regarding thesummit a failure. Since then some regions, no-tably Europe and Japan, have further developedtheir own emission trading schemes based on

emission reduction targets.

WCC continues to exchange intelligence onpolitical activity across the globe in an attemptto influence decision making in a coherent andconsistent way. However this is now a lowerpriority for some regions and a global ap-proach is not foreseen in the short term.

Advocacy for Promoting Sound Implementa-tion of International Conventions & PoliciesWCC is currently engaged in more than 10 inter-national treaties or intergovernmental programsthat could impact chlorine-based processes orproducts. Advocacy efforts cover outreach togovernments and industry contacts on issuesrelating to chlorine and its derivatives.


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WCC advocacy efforts are focused on thefollowing priority issues: Stockholm POPs Convention The World

Chlorine Council (WCC) has continued

outreach to governments regarding theprocess and criteria for reviewing candidatechemicals. Industrys efforts have resulted inimprovements in the assessment of candi-date POPs and the use of such informationfor risk management.

UNEP Global Mercury Programme WCCcontinues to be an active participant tothe UNEP Global Mercury Programme inproviding its annual report on mercury use,consumption and emissions by mercury cellfacilities. WCC is 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 Negotiation Committee meetingfor the preparation of a Global Conventionwas held in Stockholm in June 2010. WCCparticipated in the discussions and sharedits updated leaflet on Reduction of MercuryEmissions and Use from the Chlor-AlkaliSector Partnership. It is expected that theConvention would be ready by 2013.

Improving Chlorine Safety, Environment& Health PerformanceThe World Chlorine Council continues toorganise stewardship workshops around theglobe to promote best practices in environ-ment, health, and safety. Through the WCCsafety program, our industry sector is working

to achieve continuous improvements in safetyperformance at production facilities world-wide as well as during transportation and useof chlorine. Key developments in 2009-2010

include: The quarterly publication of the WCC Safety

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

The preparation of new safety tools onspecific topics that are made available toproducers and packagers, including syntheticWCC Safety Posters.

Presentations made by experts from WCCcompanies and associations on chlorinesafety matters during a stewardship/safety

workshop. Organisation of a stewardship/safety work-

shop in Brasil by end 2010.

As from the beginning of this year Euro Chloris in charge of managing for 2 years the workof the Global Safety Team, and coordinate itsrelated activities (publications, workshop ).

Demonstrating Sustainability of theChlor-Alkali IndustryWork continued on the sustainability pro-gramme as agreed the previous year. Thoughenergy became a lower priority following thefailure of Copenhagen to reach global agree-ments, other climate change issues includingthe use of chlorine derivatives in the field ofinsulation continue.

Optimal workers safetythrough a combinationof selected metals,natural and polymer

materialsHuntsman


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03

Regulatory Affairs

Balanced legislation for a sustainable future

A critical role for Euro Chlor is to provide

advocacy leadership in order to positively

influence regulations in the areas of energy,environment, climate change, health and

competitiveness. The federation works with

European and international authorities in order

to achieve the common goals of having

balanced and workable legislation.


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17REGULATORY AFFAIRSCH 03

Emission Trading Scheme (ETS)Directive implementation

Euro Chlor continues to take a great interestin the implementation of the revised EmissionTrading Scheme (ETS) Directive which was

adopted in December 2008. The main topicduring 2009 was the identification by the Eu-ropean Commission of sectors or sub-sectorsdeemed to be exposed to a significant risk ofcarbon leakage. Euro Chlor provided input tothe Commission in order to demonstrate thatthe chlor-alkali industry should be recognisedas an exposed sector. After discussions in theCouncil and European Parliament the list ofexposed sectors was adopted end of 2009. Intotal 164 industrial sectors qualify as exposed.The chlor-alkali industry, as part of the sector

basic inorganic chemicals (according to thestatistical classification of economic activi-ties in the European Community), has beenrecognized as one of the exposed sectors.These sectors will be eligible for free carbonallowances or for financial measures under thestate aid rules.

The setting up of the rules for the financialmeasures that Member States may give tocompensate for additional costs of CO2passed through in the electricity prices falls

under the competence of the Commission.These state aid rules will set the maximumcompensation that Member States couldprovide to electro-intensive industries exposedto carbon leakage (so-called indirect emitters).Euro Chlor continues to be in contact with theCommission to provide the chlor-alkali indus-try views on the rules for financial compensa-tion. A public stakeholder consultation on the

Veronique Garny is a pharmacist with a specialisationin toxicology. She joined Euro Chlor in 1996, startedworking on science issues and progressively took overthe Fluorinated Sector Groups. She became Director forRegulatory Affairs in January 2010.

Issues of great importance

The main regulatory issues Euro Chlor is working onare Energy (the ETS Directive), mercury and the Indus-trial Emissions Directive. Other topics include the WaterFramework Directive, POPs and PBTs and Electromag-netic Fields.

The regulatory work aims to cover all the regulatory issuesaffecting the European chlor-alkali industry. These areasof concern may be a bit less diverse than in the past, butare certainly of great importance for our industry and itssustainable operations in the future.

Global information exchangeFurthermore, coordination and alignment with ourglobal counterparts is important and the necessaryinformation exchange constitutes a major task of theWorld Chlorine Council (WCC). Certain subjects likethe mercury issue are indeed discussed on a globallevel (e.g. at the level of the United Nations Environ-ment Programme UNEP).

Vronique GarnyRegulatory Affairs Director

Our areas of concern areof great importance forthe sustainable future of

the European chlor-alkaliindustry


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proposal will be organised by the Commission.However, this process has been delayed and itis uncertain if the State Aid Guidelines will beadopted by the end of 2010.

International negotiationsThe EU has a firm commitment to reducethe overall greenhouse gas emissions of theCommunity by at least 20 % below 1990 levelsby 2020, and by 30 % provided that othercountries commit themselves to comparableemission reductions. The Commission ismandated to assess in the light of the outcomeof the Copenhagen Conference, by end of June2010, the impact of moving beyond this 20%reduction target and the situation of the carbon

leakage sectors.

Euro Chlor has joined the Alliance of EnergyIntensive Industries calling upon the Com-mission not to move beyond the current 20%emission reduction. The focus should insteadbe on international negotiations in order toreach a global agreement which would provideequal treatment and thus a level playing fieldfor globally traded goods. Otherwise the EUindustry risks losing out to competitors incountries with lesser or no carbon constraints.

Euro Chlor continues to monitor the interna-tional developments.

Euro Chlor is also participating to a CEN (Euro-pean Committee for Standardisation) workinggroup aiming at defining the standards to de-termine the CO2emission (direct and indirect)from different industry sectors.

Mercury: export ban and storage criteria

The EU regulation on the export ban and stor-age of decommissioned mercury is now beingimplemented. Euro Chlor has volunteered togather the data from the member companiesutilising the mercury cell technology in orderto facilitate the reporting to the Commission.All member companies contributed and EuroChlor was successful in providing the followingdata for end 2008 and end 2009:Best estimate of the total amount of mercury

still in use in the chlor-alkali cells andTotal amount of metallic mercury stored in

the facility.

The data are publicly available on DG Environ-ments website http://ec.europa.eu/environ-

ment/chemicals/mercury and http://www.eurochlor.org/regulatory.

When the storage obligation enters into forceafter 15 March 2011 metallic mercury that hasbeen sent as waste to temporary or permanentstorage facilities will also need to be reported(quantities and destinations).

The European Commission has released astudy, completed by the consultancy firmBiPRO, concerning the storage criteria for liquid

mercury. BiPRO also added an evaluation of allavailable information on the stabilisation andsolidification of mercury as well as the oppor-tunities to apply these processes in practice atEU level. Euro Chlor has contributed to the datacollected for this study and provided additionalinformation to the Commission to update theLandfill of Waste Directive, so that it can coverliquid mercury.

Sustainable heatingof our homes is

made possible bythe use of high-

performancepolyurethane foam,

produced with thehelp of chlorine

chemistry


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19

Arseen Seys, Deputy Executive Director of Euro Chlor,retired 31 December 2009, after having served the Eu-ropean chlor-alkali industry for nearly 25 years. Duringthe full 20 years of his executive role in leading EuroChlor Regulatory Affairs, he has been striving for thefull recognition of the benefits of chlorine chemistry

to society and for continuously improving the perfor-mance of the chlorine industry. He was also the Man-aging Director of the World Chlorine Council. ArseenSeys will now act as an adviser to the Euro Chlor or-ganisation.In the early years of Euro Chlors existence, interestfrom European and national policy making bodies,scientific groups, press and environmental NGOs inchlorine chemistry industry issues grew rapidly. Euro

Chlor took this as a real opportunity for effective dia-logue. Industry had to become familiar with doingadvocacy in public events which were hostile towardsrepresentatives of the chlorine industry. But graduallyour organisation became more and more recognisedand appreciated.

In the last two decades, the chlor-alkali sector has seenseveral threats. In his executive role of leading the regu-latory affairs of Euro Chlor for a period of more than 20years, Arseens expectation has been that Europe andthe rest of the world will fully recognize the benefits ofchlorine chemistry to society and that chlorine indus-try will continue to improve its performances.

Arseen SeysRetired Deputy Executive Director of Euro Chlor

REGULATORY AFFAIRSCH 03

In parallel, Euro Chlor experts have issueda report detailing the knowledge on liquidmercury behaviour in underground salt mines.The report has been submitted to the GermanMinistry of the Environment, which will use itto prepare a safety assessment for salt mineswhere mercury could be stored. The Euro Chlorposition paper and a Q&A document reflect andunderline the need of the European chlor-alkaliindustry before March 2011 for a permanentsolution for the storage of liquid mercury.

The final solution proposal for a safe under-ground storage in salt mines might not beavailable on time. That is why Euro Chlor hasalso asked to consider the storage of liquidmercury on site under well defined condi-tions as a temporary solution.

My expectation has been that Europeand the world will fully recognize the benefitsof chlorine chemistry to society

The stabilisation of mercury in the form ofmercury sulphide may not offer a short-termalternative to storage of liquid mercury: thecost impact analysis should be evaluated.Furthermore, the appropriateness of thetechnique and the storage conditions must beinvestigated.

European Mercury Strategy

under reviewThe European Strategy on Mercury whichcovers all uses of mercury is under review toanalyse where progress can be made in orderto reduce mercury use and emissions. TheCommission has asked a consultant to makeproposals to check all concerned regulationsand to report on whether sufficient measures


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Caroline Andersson has a Master of Sciencein Business Administration (MBA) and startedat Euro Chlor Regulatory Affairs in 1997. Sheis closely monitoring legislative developments

and initiates advocacy activities, in close con-sultation with the Membership. She has privi-leged contacts with the European Commissionand Parliament in order to discuss and presentthe views of the European chlor-alkali industry.

Energy dominantFor several years now, the energy issue andparticularly the European Emissions TradingScheme (ETS) have been dominating the regu-latory activities. The Euro Chlor advocacy in thisdossier is not finished yet, but has achieved pos-

itive results for the sector: member states can

compensate for the CO2costs passed throughin electricity prices and chlor-alkali is consideredas a sector exposed to carbon leakage.

Mercury is also an ongoing issue. Euro Chloris striving to have the criteria for undergroundstorage of liquid mercury approved by theEuropean authorities. Other dossiers, like Elec-tromagnetic Fields and Energy Tax are likewisein the pipeline and Euro Chlor is preparing itspositions on these matters.

Caroline makes sure that Euro Chlor does notmiss important developments, and has the ne-cessary timely contacts internally and exter-nally to stay on top of the issues that matter

for the member companies.

Caroline AnderssonSenior Counsellor Regulatory Affairs

Being on top of the issues,pro-active work and intensive contacts

with all stakeholders are crucialelements of our work

One of thewell-knownapplicationsof chlorinatedsolvents is metal

degreasing

Dow


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SUSTAINABILITYCH 02 21REGULATORY AFFAIRSCH 03

Even sportsstadiums canreceive a beautifuland long-lastingfinishing of poly-urethane coatedmaterials

are in place or new measures need to beadded. Euro Chlor has already contributedsubstantially to the process with the voluntaryphase-out of mercury technology in the chlor-alkali process by the end of 2020. We alsocommunicated with high transparency on all

aspects of the mercury use and emissions inthe chlor-alkali sector.

Industrial Emissions Directive

Euro Chlor welcomed the efforts of the Euro-pean bodies to simplify and strengthen theIndustrial Emissions Directive (IED) with theaim of sustainable environmental protection.This would also solve a major problem encoun-tered in the application of the existing IPPC

regulation (Integrated Pollution Prevention andControl): the uneven implementation in theMember States.

In a balanced approach, the IED should takeinto account the different local conditions andthe different technical characteristics of theplants and processes. This means that justifiedflexibility and local adaptation have to be bettersecured. Euro Chlor has communicated threeconcrete examples where the implementationof the BAT as described in the BREF document

is affected by the geographical location and thelocal environmental conditions, the technicalcharacteristics of the installation or an obviousdisparity between the economic costs and theenvironmental advantages. Euro Chlor sup-ported the Councils view that this could occurin specific cases (not exceptional cases).

Chlor-alkali BREF update

The chlor-alkali BREF document is more than10 years old and its update, decided last yearby the Commission, focuses more than previ-ously on measurements and monitoring.

A Euro Chlor ad hoc task force was immedi-ately created to define the industry positionand gather the necessary information. LastSeptember, the Commission held the officialkick-off meeting in Seville and Euro Chlor, withindustry delegates, participated as member ofthe technical working group. The wishes of thedifferent stakeholders were examined togetherwith new information proposed or needed. Aquestionnaire to gather this information wasdiscussed in detail. Unlike the first BREF, mer-

cury and asbestos technologies were no longerthe subject of heavy discussion. Euro Chlorwas clearly recognised as a strong organisationand a trustworthy source of information, andhas been asked to organise the collection ofdata from the industry.

Besides managing and controlling the answersto the questionnaire prepared by the Bureauin Seville, the Euro Chlor secretariat prepared,with the help of active members, a substantialnumber of technical documents that have been

uploaded on the Commissions dedicatedwebsite. This information is also available to allmembers on the CVn website.

A first draft of the updated BREF is expectedbefore the end of 2010.


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ISOPA

POPs/PBTs and substances of very highconcern (SVHC)

Substances of Very High Concern (SVHC) keepattracting special attention from authorities,both in the EU and globally. SVHCs under

REACH have to be authorised for specific useswhich is time-limited and effectively puts pres-sure on substitution if a suitable alternative isavailable. Euro Chlor, the chlorinated paraffinsand chlorinated solvents sector groups are fol-lowing SVHC related developments closely.

In the UNEPGlobal Mercury

Partnership, EuroChlor works with

World Chlorine

Council (WCC)members to up-

date the informa-tion provided each

year to UNEP onthe reduction of

mercury basedcapacity and

emissions

In modern public trans-portation pre-coated PU-encapsulated rails providehigh electrical insulation,

vibration resistance, noisereduction, anti-skid and anti-corrosion properties

Short-chain chlorinated paraffins (SCCP)will be added to the POPs Protocol of theLRTAP Convention (Long-Range Transport ofAtmospheric Pollution) of UNECE (UnitedNations Economic Commission for Europe) asdecided by the Executive Board at its meeting

in December 2009.

Once this decision is included in the EuropeanRegulation on POPs (850/2004) and in na-tional laws, the production and use of SCCPsin the UNECE region will no longer be allowedexcept for use in conveyor belts for mines andin dam sealants.

Other chlor-alkali related substances managedby various regulations are pentachlorobenzene(Stockholm Convention POPs and UNECE)

and hexachlorobutadiene (UNECE).

In addition to the UNECE, SCCPs are alsodealt with under the Stockholm Convention onPOPs, the RoHS (Regulation on HazardousSubstances) and Annex XIV (Authorisation) ofREACH.

Trichloroethylene has been put on the REACHcandidate list for Authorisation. Euro Chlor willcontinue to follow these developments closely,both at the scientific and regulatory levels.


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23REGULATORY AFFAIRSCH 03

5,5

6,0

6,5

7,0

7,5

8,0

8,5

9,0

9,5

2009200820072006200520042003200255

60

65

70

75

80

85

90

95

100

0,0

0,5

1,0

1,5

2,0

2,5

3,0

0

5

10

15

20

25

30

20092008200720062005200420032002

UNEP Global Convention on Mercury

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

In the UNEP Global Mercury Partnership, EuroChlor works with World Chlorine Council (WCC)

members to update the information provided eachyear to UNEP on the shut down of mercury cellplants and thus on the reduction of mercury-basedcapacity. The leaflet WCC has issued on this mat-ter has been updated and shows that year afteryear mercury based plants are closing down or be-ing converted to membrane technology.

The number of plants and the mercury cell-basedproduction capacity show a worldwide decrease:the number of plants went down from 89 to 58over a seven year period (- 35 %) and the mercury

cell-based capacity from 8.6 million tonnes to 5.6million tonnes (- 35 %).

The information transmitted to UNEP also in-cludes the emission trend: global mercury emis-sions were indeed further substantially reduced inthe period 2002-2009. They did in fact go downfrom 23.3 tonnes/year to about 6.4 tonnes - a 72% decrease over the seven years of reporting byWCC. The relative emissions, expressed in grammercury/tonne annual chlorine capacity show thesame trend.

The Partnership (see above) also includes sharingexperiences, documents and recommendationson best available techniques and good workplacepractices.

Also see http://www.chem.unep.ch/mercury/

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

WCC-chlor-alkali Industry / Total mercury emissions

(air + water + products)(for USA/Canada, Europe, India and Brazil/

Argentina plus 1 Uruguayan and 3 Russian plants from 2005 onwards)

Capacity (millions of tonnes)/y

t Hg/year

Number of plants

g Hg/t Cl2 annual cap.

Hg plants

Specific emissions

Capacity

Total emissions


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04

Science

Effective advocacy based on sound science

Advocating sound, science-based regulatory

decision-making has been Euro Chlor core

business for more than twenty years. In2009-2010, the organisational and technical

challenges posed by REACH, chlorine-based

biocides, classification and labelling and

chemicals of special concern constituted

key issues in the science activities of the

Federation.


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25

For all consortia external consultants havebeen contracted to support the preparation ofthe dossier.

A REACH dossier for mercury is also being pre-pared by the Belgium-based consultant ARCHE

which specialises in risk assessments of met-als. The cooperation of the companies involvedhas been organised by DELA GmbH(a Germanrecycling firm which deals with the recovery ofmercury), with the assistance of Euro Chlor.Euro Chlor supports the work on the dossierwith technical and scientific input on mercuryas applied in the chlor-alkali industry. NaClregistration will not be actively organised byEuro Chlor because for most of the membersthere is no need to register.

The chlorinated paraffins (medium-chain,long-chain and sulpho-) REACH requirementsare managed separately by a consultant. Short-chain chlorinated paraffins are listed on AnnexXIV (Authorisation) and their registrationunder REACH is left to individual companies.

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. Thedossiers for the three substances have beenevaluated, and the draft competent authorityreport was provided to us for review.

REACH consortia well on track

It has been a busy year for the REACH Con-sortia. REACH poses many organisationaland technical challenges. Many issues withpre-registered companies of the SIEF (Sub-stance Information Exchange Forum) had tobe settled, such as clarifying their intentionsfor registration, Consortium membership,finances, and organising Letters of Access.Technical issues included providing clarity onsubstance identity, recommending analyticalmethods and assessing the uses and relatedexposures. Substance specific information andproperty data are included in so-called IUCLIDfiles which were completed for all substances.Studies had to be critically evaluated and ro-bust summaries prepared. The IUCLID-hazard

data together with the use and exposure datawill form the basis of the CSR (Chemical SafetyReport) which will specify the risk managementmeasures needed to safely use the chemical invarious applications.

Most of the Euro Chlor Consortia have madegood progress and are very close to submit-ting dossiers for registration by the time thisReview went to print. Substances covered are:caustic soda, chlorine, ethylene dichloride, hy-drogen chloride, potassium carbonate, potas-

sium hydroxide and sodium hypochlorite. Thechlorinated solvents consortium covers thefive substances tetrachloroethylene, trichloro-ethylene, chloroform, carbon tetrachloride anddichloromethane. All consortia are managed byEuro Chlor staff working under the umbrella ofReachCentrum.

High-performancematerials are keyfactors in topperformance and

safety in many sportsISOPA

SCIENCECH 04


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In this report the view of the Rapporteur MemberState (RMS) is that the three substances should beapproved for use in biocidal products. The proce-dure following this is for the report to be providedto the other Member States for comments, and tobe publicly published on the Commissions CIRCA

platform. After this the report will be forwarded tothe Technical Meetings for further discussion andfinalization. If all goes well, we would expect a list-ing of the substances in Annex I of the BPD mid-2011. A second series of dossiers for Main Group 2(preservatives) were submitted in October 2008 fothe three active substances. These dossiers havebeen assessed as complete by the RMS, and haveentered the evaluation procedure. This should befinished in 2011.

Classification and labelling

At the end of this year the notification of sub-stances under the Regulation on Classification,Labelling and Packaging of Substances andMixtures Regulation (EC 1272/2008) (CLP) mustbe completed. Substances that will be registeredthis year will have the classification notified in theREACH dossier. However, companies with lowertonnage bands not registering under REACH thisyear must still notify the substance to ECHA beforethe 3rdof January 2011. Euro Chlor is organising the

notification of calcium hypochlorite, as no REACHconsortium exists for this substance. Companiesmanufacturing substances for which a REACHconsortium exists but are not planning to registerthis year should contact the relevant REACH con-sortium to find out what they recommend for thenotification process.

Dolf van Wijk came to Euro Chlor in 2001 and was ap-

pointed Euro Chlor Science Director on January 1st, 2010.Before joining Euro Chlor he was manager of AkzoNo-bels Laboratory of Environmental Chemistry in Arnhem,The Netherlands, where he focused on ecotoxicology, en-vironmental risk assessment and fate modelling.

Science delivers facts in Euro Chlors activitiesEuro Chlor has always integrated science in its advocacy.To convince regulators it is important to deliver facts andsolutions. For example, Euro Chlor carried out marine riskassessments on a voluntary basis. The results have beenused in OSPAR, the Water Framework Directive and in

the EU Existing Chemicals risk assessment programme.Other science activities are benchmarking and improvingour workers health - dealing with mercury, chlorine etc.In external debates we are active in improving swimmingpool chlorination practices to reduce by-products expo-sure. Significant progress has been achieved on assess-ment of PBTs and POPs and on communicating chlorinescience.

Dominating REACH activitiesAs expected, in the past three years REACH activities haveincreasingly dominated Euro Chlors science activities. Inclose cooperation with member companies, good pro-gress of the REACH dossiers has been achieved. They willidentify and support safe use of many applications of ourproducts which we can communicate with confidence.

Over the years, delivering sound scientific facts andtransparency on our industry and chlorine chemistry haspositioned Euro Chlor as a recognised and reliable part-ner to regulators.

Dolf van WijkScience Director

REACH will demonstratesafe use of chlorine products

The disinfectantproperties ofhypochlorite

are particularlyappreciated in

hospitals

AISE


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27

With regard to the classification of sodium hy-pochlorite, some controversy exists. Late 2008testing on Daphnia magnawas performed asit had been decided that further testing wasrequired to realistically assess the toxicityof sodium hypochlorite solutions to aquatic

species. The result of this test, combined withother data, allows the classification of sodiumhypochlorite as Dangerous to the Environmentin solutions of 2.5%.

While industry is empowered by the CLPto self- classify where a classification is notharmonised, in this case approval by MemberStates and the Commission is still awaited.

Occupational health issues priority forEuro Chlor members

The Euro Chlor Occupational Health WorkingGroup has focused during 2010 on commu-nication and sharing experiences. In previousyears the recommendations on best practicesto limit mercury and chlorine exposure in theworkplace and on electromagnetic fields wereupdated.

On 25 and 26 May 2010, 40 experts represent-ing 15 Euro Chlor member companies met on

the Solvay premises in Brussels for a one dayworkshop with the objective of sharing bestpractices on how to minimise mercury expo-sure in the workplace. Production managers,plant managers, occupational physicians andHSE experts attended.

After some introductory presentations on thedismantling of Hg cells, management of con-tractors, practical examples to reduce Hg expo-sure and Hg measurement, participants sharedexperiences in working groups. Good practices,communication with workers, atmospheric and

biological monitoring, cell room cleaning andfloor repair were some of the issues discussed.The workshop helped participants to create anetwork which is expected to facilitate futuresharing of information. The outcome of theworkshop will be reported by October 2010 andwill be made available to all members.

The results of the mercury in urine question-naire for 2008 had an excellent response rate,and showed a general decrease in exposure tomercury. However, there is still some room for

improvement.

Disinfection by-products, chlorine and asthmaThe European Union is investigating thehealth-related effects of disinfection by-prod-ucts (DBPs), by financing the research projectHIWATE of which Euro Chlor is a relevantstakeholder. The main findings were presentedduring a 3-day meeting early 2010. One of themost ambitious parts of the project is to mea-sure exposure to DBPs. Sampling took place at6 sites around Europe, with over 1000 samplestaken. 20,000 analyses were carried out toidentify various by-products. Once available,these data will be very useful for risk assess-ment of DBPs in the EU.

State-of-the-artsynthetic foamscontribute to alarge extent tomodern homecomfort

CH 04 SCIENCE

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Existing epidemiological studies suggested apositive association between total trihalometh-anes and bladder cancer, but no significantassociation was seen with colon-rectal cancerand adverse reproductive outcomes. Thebenefits of water chlorination are recognised

by the investigators, many of them saying thatdetailed studies on by-products from usingalternative disinfectants are needed beforechanging the disinfection process.

In recent years, the media have reportedon a possible link between chlorination ofindoor pools and asthma in children and poolworkers. Most of the research is focusing onepidemiological studies. A link with exposuredata is missing, because of the difficulties inmeasuring chlorination by-products (in particu-

lar chloramines) in swimming pool air. For thisreason, Euro Chlor is supporting a project withthe University of Utrecht to fill this gap. The ex-posure data obtained will be compared to theresults of questionnaires to children attendingthe swimming pools. The results of this projectwill be presented at a workshop of internation-al experts in swimming pool operational prac-tices, epidemiology, asthma and disinfectionby-products exposure, which should take placein the USA in October 2010. This workshop willidentify data gaps for future work.

Workers exposure to electromagnetic fieldsThe update of the European Directive to pro-tect workers against the effects of electromag-netic fields (EMF) has progressed with a reportprepared by a consultant to help assessing theimpact of possible legislative alternatives.

The first step of the social partners consulta-tion confirmed that a Directive was needed,but some improvements, update and practicalflexibility were requested. In the meantime, IC-NIRP (the International Commission on Non-Ionising Radiation Protection) has presented

a draft of its new guideline for low frequencyEMF. The German authorities have publisheda study performed by several specialists to pro-pose a practical solution for the new Directive.A workshop for all stakeholders includingEuro Chlor was organised in Sweden to shareideas and proposals with the Commission.

The second step of the social partners consul-tation was launched just before summer 2010with more detailed proposals for the futureDirective; Euro Chlor appreciated that they

took into account the requirements for a practical and clear implementation and commentedin line with other industrial associations. TheWorking Party assisting the Commission - inwhich Euro Chlor is actively participating - analysed these proposals and comments to helpthe Commission finalise its draft Directive bySeptember 2010.

CENELEC (The European Committee forElectrotechnical Standardization), in collabora-tion with Euro Chlor, progressed in preparinga standard for EMF measurement methodsapplicable to the electrolysis industries.

The document will be finalised when moreinformation is available on the precise contentof the future Directive.

Modern refrige-rators are so wellinsulated that theEuropean energy

ratings lower thanA will disappear

from the market.We will soon onlytalk about A, A+,

A++ etc.

ISOPA


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2929

Valentina BertatoScience manager

Valentina joined Euro Chlor in 2002. She has adegree in Environmental Sciences and is spe-cialised in environmental chemistry, comple-mented by a masters year in environmentalmanagement.

Integrating science into technical mattersIn the Science Group, Valentina covers thehuman health subjects of interest to the EuroChlor Member Companies. The issues are pre-pared by the Health Working Group, composedof physicians and experts in occupational expo-sure.

An important example of this work is the moni-toring of mercury in workers urine. The Groupalso drafts recommendations on mercury andchlorine exposure, which are included in thetechnical documents of the Technical WorkingGroups within Euro Chlor.

Chlorination and human healthThe issues of chlor-alkali industry and its prod-ucts that could impact the public at large arealso followed. The study of the public healthaspects of disinfection by-products is a typi-cal dossier in this area. Euro Chlor always re-lies upon independent laboratories analysingan issue; in this way, the study results obtainmaximal credibility. The possible relationshipbetween chlorination of swimming pool waterand the occurrence of asthma in children wasthe subject of a recent study commissioned inthe Netherlands to the University of Utrecht.

In addition to her Euro Chlor commitments,Valentina accompanies the work of the Fluoro-carbons Group. These substances are used inrefrigeration systems.

REACH consortium managementLast years key activity for REACH was the con-sortium management for hydrochloric acid with60 members and the preparation of the sub-stance registration dossier by November 2010.

We cover the human healthsubjects of interest to the Euro ChlorMember Companies

Thanks to their low energy consumption,long service life and high-quality light,organic light-emitting diodes (OLEDs),are a light source of the future.A polycarbonate based extraction layer just100 m thick increases the light yield by40 to 60 percent

SCIENCECH 04

BayerMaterialScience


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The junior of the Euro Chlor Science team, New ZealanderShaun Presow, was awarded a PhD in Chemistry in Germanyin 2008 before joining the Euro Chlor Federation in 2009.

REACH registration dossiersShaun is managing the dossiers for chlorine, sodium hypo-chlorite and ethylene dichloride. He is also responsible for thebiocides dossiers, namely the active substance registrationfor chlorine, sodium hypochlorite and calcium hypochlorite.

Euro Chlor scientific communicationSince the beginning of this year Shaun has taken over themanagement of science communication, which covers forexample the Science Dossiers (in-depth reviews on variouschlorinated substances and topics addressing the scientificcommunity) and the Focus on Chlorine Science (FOCS) leaf-lets aiming to help non-experts understand chlorine-relatedscience issues.

Data management and sharingShaun is also involved in the management of data provided

by Euro Chlor member companies. These data include mercu-ry in 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 Guidelinesand Best Practice documents.

Shaun PresowScience Counsellor

Good data management isthe basis for improving existingGuidelines and Best Practice

documents.

in modern cars,polyurethanescontribute signi-ficantly to weightreduction, safetyand comfort

ISOPA


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3131

SETAC Europe Congress in Sevillevery well attended

The 2010 SETAC Europes Congress in Sevilleexperienced a tremendous turn out of over2300 participants, an all time high. Ecotoxicolo-

gists and environmental scientists from Eu-rope, the US, South America, Asia, Russia andAfrica met during 4 days in 8 parallel sessionsof presentations and daily poster sessions. Re-markable was the revival of interest in mercurywith a special poster session and also a lot ofinterest in the two Euro Chlor Science Dossierson mercury available at Euro Chlors booth(http://www.eurochlor.org/sciencedossiers).

Also the recently published Science Dossier(SD) on halogenated by-products was well ap-

preciated by the audience.We learned from booth visitors that Euro ChlorSDs are regularly used for teaching purposesat universities. Several chlorine-related issueswere addressed in presentations given by emi-nent scientists from all over the world.

Climate change has been related to manythings, so it was no real surprise to see asession on climate change and environmentaleffects. Really new was a special session onplastic waste in the environment. Some studies

investigated the role of these marine plasticparticles as a source and means of transportfor POPs, but this seems to be of limitedsignificance.

New Science Publications

Much of the science teams resources havebeen devoted over the last eighteen monthstowards the REACH registration of the chlor-alkali substances. In addition to this, severalnew publications have been released or areunder development.

Euro Chlor was heavily involved in the SETACPellston Workshop on Science Based Guid-ance and Framework for the Evaluation andIdentification of PBTs and POPs held in 2008,the outcome of which was a series of publica-tions in Integrated Environmental Assessmentand Management which were published inOctober 2009.

In addition to editing a new Science Dossier,Euro Chlor was involved in a publication inChemosphere (Vol. 75, published in September2009) assessing sources of pentachloroben-zene and concentrations in the environment.

Two new FOCs documents (Focus on Chlo-rine Science) are also under development,one on bioaccumulation and the other devotedto the health effects of long-term low exposureto metallic mercury. A summary of the sciencepublications of last year was shared with a

broad audience including scientists, regula-tors and industry contacts through the AnnualNewsletter.

SCIENCECH 05


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05

Communication & Education

Relevant, reliable and timely information

The European Chlor-Alkali industry has

based its reputation management on

providing relevant, reliable and timelyinformation. The 20 year timeline brochure

captures this communications strategy

under the subtitle About transparency,

credibility, having a good story and getting it

accepted. This strategy remains unchanged.

All stakeholders, including academia are

systematically informed of the newest

scientific findings connected to the sectorsactivities and of Euro Chlor views on

regulatory developments.


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33COMMUNICATION & EDUCATIONCH 05

The timeline bro-chure on 20 yearsof Euro Chlordocuments howthe Federationhad to achievehigh levels ofcredibility and ac-ceptance amongstpoliticians,scientists and themedia

Euro Chlor federation celebrated 20thanniversary

Under the heading Healthy chlorine industryessential to a sustainable society, Euro Chlorcelebrated its 20thanniversary in Brussels

on the occasion of its 2009 Annual GeneralMeeting. The association was founded in 1989(although it had been existing since 1953 as theBureau International Technique du Chlore),in order to provide an adequate response torising public concern about chlorine chemistry.It would turn out to be an important actor inthe socio-political context determining thefunctioning of the chlor-alkali industry.

In the mid-1980s, the chlorine industry wasunder attack from a strong anti-chlorine move-

ment led by environmentalist groups in Europeand the USA. Their slogans Stop Chlorineand Chlorine Kills were taken seriously byauthority bodies in Europe who initiated stepsto prohibit or substitute unnecessary or-ganochlorines. The European chlorine industrytook these threats very seriously and createda strong Euro Chlor with a vision and with themeans to become the authoritative voice of thechlorine industry in Europe.

In the early years of Euro Chlors existence,

interest from European and national policymaking bodies, scientific groups, press and en-vironmental NGOs in chlorine chemistry andindustry issues grew rapidly. Euro Chlor tookthis as a real opportunity for effective dialogue.Executive Director Alistair steel says of theEuro Chlor strategy: We at the secretariat fromthe very beginning set out to provide balanced,

science-based information for use in activedialogue with key influencers. The term Critical

Success Factor was not in common usage inthose days but this was our watchword! Wehad to achieve high levels of credibility andacceptance amongst politicians, scientists andthe media.

The breakthrough can probably be attributedto the development and application of the newconcept of science-based risk assessmentswhich enabled the implementation of riskmanagement controls. This led to industry tak-ing responsibility for this process and publicly

reporting data on health, safety and environ-ment even before the requirements underResponsible Carebecame common prac-tice. Reputation issues diminished and werereplaced by rational questions on what ourposition is on chlorine-related issues of publicand political interest.


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The new ScienceDossier considers

the quantities ofhalogenated by-

products typicallyproduced duringthe various uses

of active chlorinesolutions

It can be orderedfree of cost

on CD-rom ordownloaded from

the Euro Chlorwebsite (www.eurochlor.org/

science)

From his chemical background Dirk Clotman has beenactive all his career in defending, explaining and pro-moting chemistry and the chemical industry at large.For more than two years now, he has been develop-ing and refreshing the Euro Chlor internal and externalcommunications, including the Science Communica-

tion, and adapting the visual identity of Euro Chlor.

In the electronic field a brand new website is beingprepared. Other types of electronic communication such as social networks are being studied. The daily

maintenance of the Euro Chlor and ECSA webpagesas well as the management of the ChlorVinyl networkdocument exchange site are also handled by Commu-nications. Relevant information related to Euro Chlorand to Member companies activities are shared in theelectronic newsletter.

Communication is also increasing the visibility of thechlorine industry and working closely with RegulatoryAffairs in order to enhance the readability of highlytechnical documents.

Dirk ClotmanCommunications Manager

Preparing more intensiveelectronic communication, wrappedin a modern design jacket


New Science Dossier on disinfectionby-products

This dossier addresses both the main chemicalfamilies of the by-products and the many mi-nor components including often uncharacteris-able halogenated macromolecules that makeup the balance of the effluent mixtures after theuse of chlorine as water disinfectant.

The potential environmental risks arising fromcurrent uses of active chlorine have been for-mally assessed in the EU Risk Assessment of

sodium hypochlorite under the Existing Chemi-cals Regulation. The specific risks from halo-genated organic by-products were assessed in

detail using a combination of approaches andthe conclusion reached for each use scenariois that with current risk management measuresthese by-products pose no significant risk tothe environment.

Euro Chlor website

No less than 510 e-mail requests have reachedthe secretariat in 2009 via visits to the EuroChlor website. Eighty-two per cent of those

requests concern the technical, safety andhealth areas. They concern technical recom-mendations, codes of good practice, personalprotective equipment, equipment specificationsetc. Ten per cent of the requests ask for generalEuro Chlor paper publications. Finally, 8 percent of the requests covered different areas suchas REACH, the Biocide Regulation and so on.


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35COMMUNICATION & EDUCATIONCH 05

Turning the Tideon Climate Changeby Professor Kandel(LMD, Ecole Poly-

technique Paris)

Turning the tide on climate change

The climate change phenomenon appeals tous to implement a low carbon economy. It isessential to foster innovation policies and thedissemination of more energy-friendly toolsand to facilitate related behaviour. An effectiveenergy efficiency policy must be related to asound analysis of greenhouse gas emissionsand savings mechanisms. It must also provideinnovative concrete solutions that addresseveryday life consumer needs in areas likehousing, food, mobility, use of energy, etc.

This is why Cefic, the European ChemicalIndustry Council asked Professor Kandel(LMD, Ecole Polytechnique Paris) to writea popular book, Turning the Tide on Cli-

mate Change, with a foreword by RajendraPachauri, chairman of the Intergovernmen-tal Panel on Climate Change. Euro ChlorCommunications contributed to the edito-rial preparation of this book that has beenwidely disseminated among stakeholders.

Chlorine-based construction materials likepolyurethane insulation and PVC products helpsave energy and thus reduce CO2emissions.Light-weight materials reduce the weight ofcars, like PVC and polycarbonate that replaces

glass in headlights and other components.About half of crop protection chemicals usedto boost yields and quality of food are based onchlorine chemistry. Chlorine is also indispens-able in the production of ultra pure silicon,essential to the manufacturing of solar cells.

New ECSA web pages go live!

The European Chlorinated Solvent Association (ECSA)launched its renewed website which delivers comprehen-sive information about chlorinated solvents. The websitewas completely re-structured and the website content

enriched with new information on current programmesrun in ECSA.

ECSA was formed over 35 years ago by the leading chlo-rinated solvent manufacturers in Europe. This long-standing experience in ECSA is given in condensed formin the Facts&Figures section of the new web page as wellas in the White Papers that focus on the environmentaland human health studies on chlorinated solvents. Bothsections the Facts&Figures and the White Papers aresplit into three sub-sections representing the major threechlorinated solvents, dichloromethane, perchloroethy-

lene and trichloroethylene.

High importance has been given to the Sustainability sec-tion. It includes current sustainability programmes forthe different chlorinated solvents as well as informationabout regulatory compliance, e.g. REACH, VOC, ODS.Additional tools have been included to increase the dia-logue with other stakeholders towards a pro-active com-munication: SME support, News&Innovation and Ask anExpert.

The SME support is aimed at providing expertise and

recommendations to small and medium enterprises. Aspart of its continuous effort to encourage responsibleand safe handling of chlorinated solvents, ECSA has de-veloped several information and guidance documentsdesigned to help using chlorinated solvents not only inthe most effective but also in the safest and most respon-sible manner by following best industry practices.

The News&Innovation section highlights some challeng-ing innovations with chlorinated solvents which led e.g. toa Nobel Prize Award in Physics (see picture p.41).

The Ask an Expert tool will help to answer questions go-ing beyond the information on the website. Further ques-tions about chlorinated solvents and their multiple ap-plications will be submitted to an expert in ECSA who willprovide an adequate answer and share the knowledgewith other visitors of this site.

Visit the ECSA website at the Euro Chlor pages:www.eurochlor.org/ECSA


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06European chlor-alkali industry severely hit

Reflecting the overall depression in the

European economy, production and demand

for chlorine in the whole of Europe suffereda hard blow in 2009. Demand for caustic

soda, an essential co-product in chlorine

manufacture, dropped drastically.

The chlorinated solvents market is slowly

recovering from the economic recession.

Industry overview


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37CH 06 INDUSTRY OVERVIEW

The European chlor-alkali industry has beenseverely hit by the economic crisis. Althoughthe recession was global, European producerswere most affected because of their relativecompetitiveness on world markets due tohigher energy and raw material prices. With

9.1 million tonnes in 2009, European chlorineproduction was 12.5% down on the 10.4 milliontonnes produced in 2008. Capacity utilisationrates in 2009 averaged 71.1%, compared with79.8% in 2008.

Germany remained Europes largest chlorineproducer in 2009, accounting for 43.5% ofEuropean production, followed by Belgium/TheNetherlands with 14.9%. The UK/Austria/Swit-zerland/Finland/ Norway/Sweden group with12.0% was the third highest, followed by France

at 11.3%. These top four regions representedtogether 81.6% of the total European chlorinemade in 2009.

Although chlorine is a key building block forthe chemical industry, its essential co-productcaustic soda is also important. After 3 consecu-tive years of stability and strength, demand forcaustic soda dropped drastically, resulting inhistorically high average monthly stock levelsclose to the 300,000 tonnes mark.

After a substantial decrease in the second halfof 2008, the chlorinated solvents market isslowly recovering from the morose economicclimate, although the situation differs for theindividual chlorinated solvents. European salesof dichloromethane the most widely usedof the chlorinated solvents continued to go

down in 2009 due to the marketing and userestrictions in paint stripping. European salesof perchloroethylene stabilised in 2009, as itremains the solvent of choice for dry cleaningand still gains market share as a substitute fortrichloroethylene in metal degreasing.

Chlorine is produced by electrolysis using 3main technologies: mercury, diaphragm andmembrane. Ten years ago, mercury technologyaccounted for about 60% of European chlorinecapacity (including the non Euro Chlor mem-bers). The year 2009 continued to illustratethe trend of a gradual shift away from mercurycells to the more energy-efficient membranetechnology (mercury: 31% - membrane: 52%).Three mercury cell rooms were convertedto membrane technology during 2009, and

another was definitively shut down.

Based on chlorinechemistry polyure-thane is a modernhi-tech material withnumerous uses in

everyday lifePolioles


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10

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30

40

50

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70

2010

2009

2007

2008

2006

2005

2004

2003

2002

2001

2000

1999

1998

1997

Capacities & Processes% of total capacit

MercuryMembraneDiaphragm

Other

European Chlorine production in 20099,099kilotonnes

European chlorine applications in 20099,108kilotonnes

European caustic soda applications in 20098,701kilotonnes

Pulp, paper, cellulose 1,207kt (13.9%)Adhesives, heat transfer printing, newspapers, books

Mineral oils 165kt (1.9%)Greases, fuel additives

Aluminium and metals 348kt (4.0%Greenhouses, car and airplane panels, steel hardenin

Food industries 412kt (4.7%)Fruit and vegetable peelings, ice cream, thickeners, wrappings

Miscellaneous 1,502kt (17.3%)Neutralisation of acids, gas scrubbing, pharmaceuticals, rubber recycling

Soaps 256kt (2.9%)Shampoos, cosmetics, cleaning agents

Bleach 368kt (4.2%)Textiles, disinfectants

Phosphates 133kt (1.5%Detergent

Water treatment 398kt (4.6%Flocculation of waste, acidity contro

Other inorganics 1,168kt (13.4%Paints, glass, ceramics, fuel cells, perfume

Rayon 116kt (1.3%Bedspreads, surgical dressing

Inorganics 1,274kt (14.0%)Disinfectants, water treatment, paint pigments

Isocyanates & Oxygenates 2,479kt (27.2%)Uphlostery, insulation, footwear, plastics, pesticides, car paints

Solvents 279kt (3.1%)Metal degreasing, adhesives, dry cleaning, plastics

Epichlorohydrin 510kt (5.6%)Pesticides, epoxy resins, printed circuits, sports boats, fishing rods

chlorine industry review 2009-2010

Documents