Message from the Dubois-Désiron family :

Que cherche Greenpeace au travers des attaques sur le PVC et le chlore ? Est-ce à faire passer un dogme sans nuances, à détruire plusieurs acquis de bien-être de notre société moderne. Offrons leur une ile sur laquelle ils pourraient vivre dans le plus stricte respect de leur dogmes. Nous pensons qu'on reverrait la moyenne d'âge de leur population retomber. D'autre part, ils auraient beaucoup de difficultés à utiliser le système d'Email pour faire passer à tort et à travers leurs dogmes. Nous supposons qu'ils utilisent tous des PC ou Mac sans un gramme de PVC ou de chlore et fabriquer sans un gramme d'énergie non verte., ceci dans le respect de leur dogme. Ces quelques mots précédents, pour montrer que rien n'est noir, rien n'est blanc et que la vie de tout les jours est faite en permanence de compromis. Intégrez comme tendance dans ces propres choix et décisions, un souci d'amélioration de la qualité de la vie est en soit plus constructif que de tenter d'imposer des dogmes. Famille Dubois-Désiron

Message from Mr Dubuissiez :

Je pense que nous manquons surtout d'informations concernant ce matériau qui est répandu dans tous les domaines de notre vie, que ce soit dans le bâtiment, l'aménagement de notre maison ou dans le domaine médical . Pas besoin de faire la liste de tous les domaines d'application de ce matériau léger, souple, durable, solide qui ne pourrait tout simplement pas être remplacé dans l'état actuel de nos connaissances, par aucun autre . La plupart des réactions à l'emporte-pièce que suscite ce produit (il est dangereux, nuisible à la santé, polluant …) ne reposent sur aucun fondement, simplement du subjectif . Il est important maintenant que les industriels de la branche communiquent non seulement sur le matériau par lui-même, en argumentant sur les qualités multiples du PVC mais également et surtout sur le recyclage du PVC, car je pense que c'est pour la plupart des gens une inconnue. Je suis solidaire avec ceux qui vont aller défendre le PVC dans l'optique bien sûr dur respect de l'environnement et de la sécurité de tous.

Message from Mr Eckard :

Sehr geehrter Herr Schulte-Braucks, die EU hat zum Thema PVC ein Gruenbuch erstellt. Als Betriebsingenieur in der chemischen Industrie habe ich permanent mit Werkstoff-Fragen zu tun; zu diesem Thema moechte ich deshalb folgende Anmerkungen machen: -

PVC ist ein Werkstoff, welcher wie alle anderen Werkstoffe Vorteile und Nachteile hat. Dies beginnt bei der Produktion und endet bei der Entsorgung. Sucht man nun bei einer bestimmten Anwendung den optimalen Werkstoff, so gilt es, diese Vor -und Nachteile gegeneinander abzuwaegen.Diese Abwaegung muß aber sachlich richtig auf der Grundlage technischer und physikalischer Tatsachen beruhen; was zur Zeit aber beobachtet wird, ist ein einseitiges und emotionales Agieren mit bewusstem Verleugnen realer Gesichtspunkte.

-

Der groesste Vorteil von PVC in der chemischen Industrie liegt in seiner grossen chemischen Bestaendigkeit gegenueber einer Vielzahl von aggressiven Stoffen wie Saeuren, Laugen, Salzen, Oelen und vielen mehr. Hinzu kommt eine sehr gute Widerstandfaehigkeit gegenueber Witterungseinfluessen wie Frost, UV-Strahlung, Ozon-Gehalt der Luft, etc.. Diese Eigenschaften machen PVC zu einem unentbehrlichen Werkstoff für Tanks, Rohre, Auffangwannen, u.a.. Gerade hier leistet PVC einen von vielen positiven Beitraegen zum Schutz der Umwelt, indem dieser Werkstoff durch seine Bestaendigkeit ein Austreten anderer und gefaehrlicher Stoffe in die Umwelt verhindert. Was nuetzt der Umwelt ein Alternativ-Werkstoff, welcher durch sein Versagendie Emission von Gefahrstoffen nicht verhindern kann ?

-

Die hohe Bestaendigkeit von PVC moechte ich auch im Privatbereich nicht missen. Stichwort Fensterbau: durch den Einsatz von PVC-Fensterprofilen beim Hausbau vor drei Jahren sind in den naechsten 30 Jahren keinerleiaufwendige, zeitraubende und emissionstraechtige Wartungsarbeiten zu erwarten (kein Farbentfernen und Neustreichen, kein Verkitten usw.). Diese Vorteile, gekoppelt mit der entsprechenden Wirtschaftlichkeit, erhalte ich bei keinem anderen Werkstoff.

-

Die weiteren Vorteile wie geringeres Gewicht gegenüber Metallen (Automobilbau), leichtes Verarbeiten (Halbzeug-Industrie), weites Spektrum einstellbarer Eigenschaften (weich,hart, durchsichtig, einfaerbbar, ...) moechte ich nur am Rand erwaehnen.

-

Natuerlich muß man auch etwas zu den Nachteilen sagen: die Herstellung von PVC mittels des giftigen Vinylchlorid-Monomer (VCM) bedarf sorgfaeltiger und sicherer Produktionsverfahren, um Gefahren für Mitarbeiter und Umwelt auszuschließen. Betrachtet man die Emissionsdaten der PVC-Hersteller aus den letzten Jahren, so ist eine staendige und deutliche Abnahme der VCMEmissionen erkennbar. Dieser Punkt ist jedenfalls kein Argument gegen PVC.

-

Stichwort Entsorgung: zum jetzigen Zeitpunkt ist dieser Punkt noch kritisch. Aber: warum soll es nicht moeglich sein, durch Kennzeichnung und gezieltes Sammeln von PVC-Abfaellen hier eine hoehere Wiederverwendungsrate sicherzustellen. Kein Mensch kommt z.B. auf die Idee, Schmieroele zuverbieten. Und doch muessen jedes JahrTausende von Tonnen Altoel kontrolliert eingesammelt und so aufbereitet oder entsorgt werden, dass keine Gefahr für die Umwelt entsteht. Diese System funktioniert inzwischen

reibungslos und ohne Murren. Mit etwas Aufwandund Gedankenschmalz sind auch bei PVC aehnliche Wege denkbar und machbar. Mein Resumée zu dieser vielleicht etwas langatmigen Ausführung: Ein klares "PRO" für PVC, auch wenn an bestimmten Problemen noch abschliessend gearbeitet werden muss.

A SECTOR GROUP OF

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European PVC Industry response to the Green Paper on PVC

CONTENTS Page Introduction

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Executive Summary

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8. Conclusion

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9. Contact Details

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Reference: VC057_final

Page 2 of 45

European PVC Industry response to the Green Paper on PVC

INTRODUCTION This document contains the detailed responses of European PVC producers and their industry partners to all of the questions raised within the EU Commission Green Paper on the Environmental Issues of PVC, published on 26th July 2000 in Brussels (COM (2000) 469 final).

It has been compiled by industry experts from the relevant trade associations - The European Council of Vinyl Manufacturers (ECVM), European Plastics Converters (EuPC), The European Stabilisers Producers Associations (ESPA) and The European Council for Plasticisers and Intermediates (ECPI). A number of independent experts have also been asked to assist the industry in compiling its responses.

The varying presentation within each section (e.g. use of references) reflects the different styles of contributors and the specificity of each subject.

Further copies of this document and additional background information are available from http://www.pvcinitiative.com.

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European PVC Industry response to the Green Paper on PVC

EXECUTIVE SUMMARY The European PVC resin producers and their industry partners welcome the European Commission Green Paper as a crucial step to give a truly European perspective to a debate that used to be dominated by national or partial considerations. The industry partners view the EU Commission Green Paper as an unsatisfactory review of the PVC lifecycle. They believe some options contained within the paper go against the wealth of information available to the Commission. It is based upon the outcome of five technical studies undertaken by independent consultants. The PVC industry provided a critique of these studies to the Commission immediately following their publication, and this review was not taken into account when drafting the Green Paper. Whilst the Green Paper acknowledges the socio-economic contribution of the PVC industry, it does not acknowledge the many benefits that PVC products bring to modern life. The industry believes that the focus of the Green Paper on PVC waste management issues is inappropriate. Waste management is not a PVC specific concern, but a general issue for all materials and for society as a whole. It also believes that the horizontal initiative should have compared the environmental performance of PVC with the main potential alternative materials before proposing possible limitation or restriction as an option. The approach of studying a single material in isolation, with no relative comparative studies, is fundamentally biased. Whilst the paper incorporates various elements of the PVC industry’s Voluntary Commitment, it does not truly underline the benefits of such a voluntary approach nor give proper credit to the progress made by the industry to date. European PVC producers and their industry partners are confident that implementation of their Voluntary Commitment, already underway, will address all the questions contained within the Green Paper. It will deliver improved product stewardship more quickly and effectively than any other approach because it has been agreed by all of the partners. It is a dynamic and measurable approach, governed by review dates, commitments on consultation and external verification. The industry’s response to the Green Paper is particularly relevant given that the outcome of the consultation process may have an effect upon its competitiveness and could impact upon the 20 000 SME and the 530,000 jobs directly supported by the production and conversion of PVC throughout Europe. The response of European PVC producers and their industry partners to the 8 main questions contained within the PVC Green Paper can be summarised as follows:  6WDELOLVHUV Heavy metals stabilisers have been used for more than 40 years without any measurable impact on the environment or human health. Nevertheless, heavy metals in general are being considered for possible phase-out. The Voluntary Commitment of the PVC Industry is the quickest and most effective route for phasing out the use of Cadmium stabilisers in 2001 and developing appropriately the use of alternatives to lead stabilisers.

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European PVC Industry response to the Green Paper on PVC

 3ODVWLFLVHUV No measures should even be considered until the results of the EU risk assessments are available (expected early 2001).  0HFKDQLFDOUHF\FOLQJ The Voluntary Commitment of the PVC Industry offers additional PVC recycling with specific targets for waste streams not regulated by current or future EU legislation (Packaging, ELV,WEEE, …)  +HDY\PHWDOVLQPHFKDQLFDOUHF\FOLQJ Closed-loop recycling prevents loss of heavy metals to the environment and recovers the inherent polymer resources for re-use rather than disposal. A restriction of the recycling of PVC containing heavy metals is not appropriate and would affect the mechanical recycling of building waste, a waste stream with the highest potential for high-quality recycling.  &KHPLFDOUHF\FOLQJ The PVC industry is currently actively involved in developing the most effective technologies for chemical recycling with potential for expansion to a commercial scale. It is already investing 3 million euro in a pilot plant and additional projects are being considered.  ,QFLQHUDWLRQ All materials have their specific benefits and burden in Municipal Solid Waste Incineration. On balance when considering operational and external costs, diversion of PVC waste from incineration is not warranted. The situation with relation to Incineration will change dramatically following the adoption of the EU Incineration Directive (PE-CONS 3641/00) and with the introduction of new technologies such as pyrolysis and gasification coupled with higher energy recovery rates.  /DQGILOO Comprehensive research into degradation and leachate effects from PVC waste products does not suggest that specific practices for controlled landfill should be employed. 2WKHUKRUL]RQWDODVSHFWVRQ39& Any regulatory action on a single material is inappropriate without having equally analysed its alternatives (i.e. total lifecycle rather than only end-of-life aspects).

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European PVC Industry response to the Green Paper on PVC

1. STABILISERS 1.1 Comments on the Green Paper assessment of stabiliser use in PVC •

The 1998 stabiliser use figures are taken from those already issued by ESPA as part of its voluntary commitment.



+HDY\0HWDOV

•

In reviewing the hazard classification of lead and cadmium compounds used as PVC stabilisers, the Green Paper states that lead and cadmium are persistent. This statement is misleading because, by definition, all elements are persistent and can only be destroyed by radioactive decay or nuclear fission or fusion.

•

The lead and cadmium compounds that are used in PVC are covered by specific entries in Annex I to 67/548/EEC and the cadmium entry (048-001-00-5) only classifies this group of compounds as harmful and dangerous to the environment.

•

In discussing lead and cadmium stabilisers, the Green Paper moves from hazard to risk. It correctly states that there is a distinction between hazard and risk. EU Chemical policy requires hazard labelling in normal handling so that any user can determine the risks they may face. The EU has formal risk assessment procedures through its Existing Substances Regulation and detailed technical guidance associated with this Regulation (in four volumes and subject to technical development).

•

If studies undertaken according to the Existing Substances Regulation determine that there is a possible risk, the first step is to refine the assessment. If a real unacceptable risk does exist, then risk management actions must be taken according to another guidance document (Technical Guidance document on Development of Risk Reduction Strategies). The last action according to this guidance document is a restriction on the use of a substance. The conclusion of this work is then reviewed by the Commission’s Scientific Committee for Toxicity and Ecotoxicity (CSTEE).

•

The figures on levels of metals due to PVC in the waste stream presented within the Green Paper are questionable. Firstly, both the Dobris Assessment and the Second Assessment acknowledge that there are serious inadequacies in the EU waste statistics and different definitions used within each country.

 •

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The Green Paper states that risk assessments for cadmium and cadmium oxide are being completed under the Existing Substances Regulation, but fails to mention that under Article 12(2) of the same regulation, targeted risk assessment is also being carried out on cadmium laurate and stearate for their use in rigid PVC stabiliser systems. This report has been completed and reviewed by the 15 Member States in a “Market and Use Directive Meeting”, as well as by the CSTEE. This report identified no risks in the production of PVC products using these materials. It also states that the disposal of PVC construction products containing these substances in demolition waste sites presented no risk to the environment. The report had some minor queries directed at its methodology by the CSTEE and it is being revised to take these into account. When the final report and methodological difficulties of handling metals in the risk

Page 6 of 45

European PVC Industry response to the Green Paper on PVC

assessment process are agreed, the industry will carry out an identical study on PVC lead stabilisers using an independent consultant, as part of its voluntary commitments. •

The figures for cadmium in the municipal waste stream presented within the Green Paper are not based on any real measured data. Considering the technical uses of cadmium, it is difficult to see how consumer products could give rise to any of the material present within the municipal waste stream. The only exception could be PVC flooring made more than 10 years ago.

•

In the case of cadmium stabilisers, a review of the literature by Donnelly (reference 20 and 21 – the same paper) showed very little evidence of migration from PVC. Argus also reviewed the literature in their study for the Commission as part of the PVC horizontal initiative and found the same references. However, they appear to have misread the results from Brederick and stated a 4.8% migration level was observed, whereas the research actually states that a loss of only 10kg of lead occurs from the total amount of window profiles disposed of in Germany. It is interesting to note that the paper by Wilson presented at the OECD Risk Reduction exercise on cadmium stated that the leaching of cadmium from all plastics, including pigment use, is unlikely to exceed that from natural trace levels in food and paper.

•

A number of comments on the action by stabiliser producers to phase out cadmium based products according to the Council Resolution of 1988 are worthy of note. In particular it should be noted that this Council Resolution is based on substitution, if technically feasible, and not on any risk assessment since it pre-dates the risk assessment regulations. The 16,400 tonnes of liquid stabilisers used in flexible PVC quoted within the Green Paper were mostly based on cadmium some 15 years ago. Since that time, these have all been changed to non-cadmium systems due to the innovations of the stabiliser industry. Figures produced by ESPA in 1999 show that only 31 tonnes of cadmium compounds, expressed as cadmium metal, are now used for both rigid and flexible PVC. This use will cease by the middle of 2001 as agreed in the Voluntary Commitment of the PVC Industry. th

The 10 adaptation of the Market and Use Directive is frequently reviewed. On the basis of actions contained within the Voluntary Commitment of the PVC Industry, this will undoubtedly be extended to a total ban so that no PVC products containing cadmium can be legally imported into the EU. It should be noted that the stabilisers industry offered to phase out cadmium within three years at the last review of the Market and Use Directive. However, this offer was not accepted because Member States were unable to provide evidence of any risk in their use. As a result, an extension of the current restrictions was not considered justified by a majority vote. Austria and Sweden were allowed to keep their existing tighter laws for a further two years. /HDG •

Because of the proposed Danish law on lead, the CSTEE has examined the justification provided by the Danish Government but no details are given within the Green Paper as to what was in the CSTEE review. The OECD also carried out a full risk reduction review based on the known toxicology of

Page 7 of 45

European PVC Industry response to the Green Paper on PVC

lead and this resulted in an OECD Ministerial Declaration banning certain uses. However, no action was considered necessary on the use of lead compounds in PVC stabilisers. It is unfortunate that no mention is made of the conclusions by these two expert bodies within the Green Paper. •

To illustrate the difference between hazard and risk, the industry has pointed out that lead stabilised PVC is approved by regulators across Europe for use in drinking water pipes. These pipes have also been tested according to the Ceramics Directive for lead migration and been shown to be safe. Hence it is equally safe to eat food off a normal ceramic plate or off lead stabilised PVC pipe.

•

The CSTEE answers the two questions that were asked on lead and also suggest further work in a number of areas. The CSTEE notes that in Member States, including Denmark, there has been a constant decrease in blood lead levels of children since the late 1970s and a new steady state level has not yet been reached. The decrease has mainly been due to the progressive elimination of lead from gasoline (which is not necessarily good because exposure to benzene has increased). It also states that very limited data has been provided by the Danish Authorities to support the case that the burden of lead on the general environment is increasing. Data provided on levels in sewage sludge do not support the case.

•

Within the construction sector, PVC is primarily used in long-term applications that find their way into demolition waste rather than municipal waste at the end of their life. More than 98% of all the lead stabilisers used within PVC products will be found within these construction applications. Hence, the maximum 1% level of lead due to PVC in the municipal waste stream suggested in the recent landfill study commissioned by the PVC industry is likely to be the most reliable figure. At the recent OECD risk reduction meeting on lead, there was disagreement on the levels of lead finding their way into the municipal waste stream. One of the studies presented had sorted and analysed a large number of typical waste samples from an incinerator, whilst another merely estimated the level that might be present based on personal experience. The first study showed that little of the PVC waste present was stabilised with lead and supported a maximum level of 1%. This report also contains useful information on lead distributions between different fractions of the waste stream (Chandler et al, Mass Burn MSW Incineration Study).

•

The landfill study quoted as Reference 28 within the Green Paper did find some lead migration for one particular low temperature cable. However, the Green Paper fails to note that the authors concluded that the difference in concentrations in the leachate were minor. The authors also stated that normal cables containing just the DIDP plasticiser are expected to show little or no migration. Lead stabilisers from PVC pipe gave rise to no noticeable contribution.

•

Reference 29 quoted within the Green Paper is claimed to state the use of lead stabilisers would give rise to an increase in lead concentrations in the environment through the waste management phase. There is no direct evidence given for this statement in the original Swedish KEMI report. Interestingly, the Swedish Environment Agency published their contribution to the debate on PVC at the same time and stated in their press release: ³:HFRQVLGHUWKDWERWKWKHPDQXIDFWXUHDQGUHXVHRI39&SURGXFWV DUHDFFHSWDEOHHYHQLIWKH\FRQWDLQHQYLURQPHQWDOO\KDUPIXODGGLWLYHVVXFKDVWLQDQG OHDGFRPSRXQGV7KHOHDGDQG WLQFRPSRXQGVDUHILUPO\ERQGHGLQWRWKH39&PDWHULDO DQGGRQRWOHDFKRXW´

Page 8 of 45

European PVC Industry response to the Green Paper on PVC

7LQ •

The comment that dioctyltin is toxic to the immune system is misleading. The relevant research data was reviewed by the EU Scientific Committee for Food when they assigned specific migration limits for this stabiliser when used in food-contact applications. The stabilisers industry has convened an expert panel to review this issue, including three recognised experts from the USA and Europe. It should be noted that the tin stabiliser industry has compiled all the literature data, along with its own internal studies. These have been reviewed by an academic expert group in Germany, with Professor Greim as one of the three experts. This detailed report has been made available to Regulatory Authorities.

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,QGXVWU\5HVSRQVHWR4XHVWLRQLQWKH*UHHQ3DSHU The Voluntary Commitment of the PVC Industry is the best way forward to minimise the use of lead and cadmium. In the spirit of the Voluntary Commitment, the PVC industry will work towards using the alternative stabiliser systems within a specified timeframe. ESPA members are constantly developing new and improved stabiliser systems. Nevertheless, cadmium and lead stabilisers are safe for use within PVC applications. The trend to use other types of stabiliser is mainly due to political pressure and the fact that heavy metals are under scrutiny without any reference to proper risk assessment.

Page 9 of 45

European PVC Industry response to the Green Paper on PVC

3/$67,&,6(56 2.1 Comments on the Green Paper assessment of plasticiser use in PVC •

Industry and the authorities have invested major financial and human resources into comprehensive risk assessments over several years – some of the statements made in the Green Paper call into question the benefit of such risk assessments.

•

It should be noted that when phthalates were ranked for risk assessment prioritisation by the EU Joint Research Centre using their Informal Priority Setting system (IPS) they came out at between number 162 and 1126 (from a total of 1400) so in principle they should not have appeared on the first three priority lists for Risk Assessment in accordance with regulation 793/93 on existing substances.

•

The Green Paper says that DEHP, DINP and DIDP have a potential for bioaccumulation. Extensive testing has demonstrated that all three phthalates pose minimal risks to the environment. Bioaccumulation in fish is very low and in lower organisms only moderate. These data are included in the EU Risk Assessments, the most recent drafts of which conclude that there is little if any cause for concern with regard to risk to the environment and no justification for any labelling with regard to environmental hazard.

•

Reference is made to long-chain length phthalates having a low biodegradability under normal conditions of sewage treatment and are only partly degraded in usual leachate and sewage treatment plants, where they accumulate on suspended solids.This is not the conclusion of the Risk Assessments. These phthalates have been shown to be readily biodegradable based on OECD standard test methods and using the accepted OECD criteria. In sewage treatment plants DEHP/DINP/DIDP will bind to sewage sludge but extensive testing has shown minimal environmental effects from this and that biodegradation that will occur over time

•

The Green Paper says that certain phthalates can cause adverse effects on human health (in particular on liver and kidney for DINP and on testicles for DEHP). There is no evidence of adverse effects in humans during the 40 years that these phthalates have been extensively used. The only adverse effects which have been seen have been in studies on particular animal species - effects are seen in rodents but not in monkeys. It is now accepted that the effects produced by phthalates in rodent livers are due to peroxisome proliferation, a mechanism recently concluded by the International Agency for Research on Cancer (IARC) not to be relevant to human beings.

•

DEHP/DINP/DIDP are QRW ubiquitous in the environment. They do QRW partition to any significant degree to air or water and therefore these are QRW major routes by which phthalates enter the environment. They can be present in soil and sediment but they degrade with time and have minimal impact on soil/sediment organisms.

•

The Green paper says that in Denmark it has been reported that the concentrations of certain phthalates can exceed the national limit values fixed for the use of sewage sludge in agriculture. These Danish limit values are not science-based.

•

The “concern” expressed by the CSTEE about DINP and DEHP being used in toys was because the margin of safety (MOS) did not reach the desired level of 100-fold – not because exposure was at a level where such effects had been seen in rodents. If the latest toxicological information is used then the “concern” for the principle phthalate used

Page 10 of 45

European PVC Industry response to the Green Paper on PVC

in toys (DINP) would no longer apply since the MOS would increase to a level greater than 400. •

The Chairman of the CSTEE has stated that a ban is not an appropriate risk control measure. The CSTEE has recommended the use of specific migration limits and both DG Enterprise and DG Health & Consumer Protection are actively pursuing the development and validation of necessary test methods which would enable such limits to be used. Commissioner Liikanen recently – July 5 – referred to these test methods in Parliament and said that the Commission would support the Parliamentary amendment (subsequently adopted) which stated that the availability of a suitable test method would provide strong grounds for the Commission to review the proposed legislation for a ban on the use of phthalates in toys designed to be put in the mouth by children under three years old.

•

The paper says that without waiting for the final stage of the risk assessment process, three Member States have already started to draw up risk management strategies to reduce the use of phthalates. Neither the Swedish or Danish initiatives are based on comprehensive reviews. They are not based on sound scientific data. It should also be noted that the Swedish plan explicitly excludes medical products and drugs. In the case of Germany the Green paper refers to an assessment carried out by the German Federal Environment Agency. There is a comprehensive review and critique of this Study on the ECPI web site (KWWSZZZHFSLRUJWHFKQLFDOSDSHUVLQGH[KWPO). This includes a letter from the agency clarifying some of the points in its study.

•

In outdoor applications such as roofing sheet and in soil buried applications such as cables it has been shown that plasticisers are consumed at the surface of the flexible PVC by micro-organisms. Thus the level of plasticiser in the material will fall but there is no corresponding build up in the environment.

•

Levels of phthalates that have been reported in leachates are generally low , 1-30 µg/l. Even in the Argus & Rostock University study no emissions of plasticisers were found in the leachate.

•

Domestic and industrial sewage treatment plants currently deal adequately with effluent containing phthalates and the levels passing to surface waters are extremely low, giving concentrations that do not pose a risk to aquatic or sediment dwelling organisms. Phthalates will bind to sewage sludge and if this is spread on the land the phthalates will have little if any effect on plants or soil organisms and will biodegrade.

•

It is unlikely that losses of phthalates could contribute to gaseous emissions from landfills since environmental fate modelling data and environmental measurements show that DEHP/DINP/DIDP do not partition to air. This is supported by the lack of any study showing the presence of phthalates in gaseous emissions from landfills.

•

It has been shown that phthalates are strongly retained in landfills and in soils and are biodegraded.

Page 11 of 45

European PVC Industry response to the Green Paper on PVC

4XHVWLRQLQWKH*UHHQ3DSHU ,VVXHVRQSODVWLFLVHUVSUHVHQWHGIRUFRQVLGHUDWLRQZLWKLQWKH*UHHQ3DSHU 7KHXVHRISKWKDODWHVLQ39&DSSOLFDWLRQVUDLVHVLVVXHVGHVFULEHGDERYHZKLFKFRXOGEH DGGUHVVHGWKURXJKDQXPEHURIPHDVXUHVLQFOXGLQJOHJLVODWLYHRUYROXQWDU\ULVNUHGXFWLRQ PHDVXUHV7KHVHSRWHQWLDOPHDVXUHVVKRXOGEHDVVHVVHGLQWKHOLJKWRIWKHLUHQYLURQPHQWDO DQGHFRQRPLFLPSOLFDWLRQV 4XHVWLRQ 6KRXOGVSHFLILFPHDVXUHVEHWDNHQIRUWKHXVHRISKWKDODWHVDVSODVWLFLVHUVLQ39&",IVR ZKHQDQGWKURXJKZKLFKLQVWUXPHQWV"

,QGXVWU\UHVSRQVHWR4XHVWLRQZLWKLQWKH*UHHQ3DSHU The EU risk assessment process involving experts from all 15 Member States will provide the right answer to this question. The industry is committed to accepting the conclusions of the risk assessment process and to working with regulators to establish appropriate risk reduction measures if necessary. The future PVC strategy should not include risk reduction measures on phthalates unless they are mandated by the EU’s own risk assessment process. If this is not the case, then the EU risk assessment process could be undermined in the eyes of all stakeholders. The following points also have to be considered. •

(8ULVNDVVHVVPHQWVDUHFRPSUHKHQVLYH The EU risk assessment process was established in 1993 with the objective of carrying out a comprehensive analysis of the environmental, health and safety aspects of existing chemicals. Moreover, once the risk assessment is finalised, measures are proposed if necessary to minimise any identified risks. This process is the cornerstone of EU chemicals policy and a well respected science based approach to risk assessment and risk management.

•

7KHULVNDVVHVVPHQWVRISKWKDODWHVZLOOEHILQDOLVHGE\HDUO\ i.e. within a similar timeframe to the outcome of the Horizontal Initiative on PVC. Member State governments and industry have invested considerable time and effort in this process.

•

7KHULVNDVVHVVPHQWVVKRXOGIRUPWKHEDVLVRIDQ\IXWXUHSROLF\ The industry welcomes an open debate on phthalates. However, the Commission must ensure that all statements in the Green Paper and any subsequent follow-up strategy take full account of, and do not conflict with, the EU’s own risk assessment process. The industry does have concerns about some of the statements in the Green Paper which it do not accurately reflect the current situation or state of knowledge about phthalates. The industry is particularly concerned that the Green Paper suggests that phthalates can cause adverse effects to human health. Such effects have never been observed. Furthermore, there is no evidence that the use of phthalates in flexible PVC have caused any adverse health effects in more than 40 years of use.

•

(8ULVNDVVHVVPHQWVKRXOGIRUPWKHEDVLVRIQDWLRQDOPHDVXUHV The Green Paper presents unilateral measures to control phthalates by Member States as an important

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European PVC Industry response to the Green Paper on PVC

consideration in the debate. ECPI and the 15 EU Member States have committed themselves to the risk assessment process. National measures, if needed, should follow the EU risk assessment and not prejudge the conclusions. ECPI expects the Commission to support their own risk assessment process and protect the integrity of the single market.

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European PVC Industry response to the Green Paper on PVC

0(&+$1,&$/5(&90%

100,000

Denmark

1.7

32

420,000

90%

60,000

Sweden

1.6

21

400,000

0

60,000

UK

1.5

7

450,000

60,000

)LJXUH (VWLPDWHG\HDUO\PDVVIORZVIRU0XQLFLSDO6ROLG:DVWH,QFLQHUDWLRQLQ (XURSH(8 .LUUPDQQD &OHDQHG RII JDV

Hot water, electricity 40,000 kt MSW (300 kt PVC-waste)

,QFLQHUDWRU

10,000 kt bottom ash (Negligible PVC-related)

1,300 kt APC-residue (130 kt PVC-related)

Disposal

5RDG

IO\DVK

0LQH9DORULVDWLRQ

4XDUU\

6DOWPLQHVWRUDJH

/DQGILOO&ODVV,,, P/FLW/UIM/030400/JS

•

The presence of PVC in MSW has some positive effects, as it contributes to reducing the heavy metal content and total organic carbon in the bottom ash. The reduction of heavy metals is due to the chlorine content of PVC, while the energy content of PVC contributes to a better burnout of the waste thereby decreasing the content of total organic carbon in bottom ash.

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European PVC Industry response to the Green Paper on PVC

•

Incineration experiments in the pilot plant TAMARA at Karlsruhe in Germany have shown that the chlorine associated with PVC waste mainly enters the gas phase and consequently fly ash, contributing only a marginal increase to chlorine in bottom ash. The presence of volatile heavy metals zinc, cadmium and selenium, the trace element Antimony (Sb), and the more lithophilic metal Copper all show a significant correlation in their transfer to the fly ash with the chlorine load in the feed stream. The findings from experiments at TAMARA indicate that the more distinctive transfer of volatile metals from bottom ash into filter ash has to be taken into account in grate systems handling waste streams of increasing PVC content.

•

The transfer of heavy metals from the fuel bed into fly ash increases the toxicity of the fly ash. This residue stream is, however, classified as a special waste in many European countries. A higher or lower load of heavy metals will not alter its disposal requirements. On the other hand, some people view the enhanced volatilisation of ecotoxic elements from the bottom ash as a desirable outcome in view of its increased compatibility with regulations for the beneficial use of this residue (Jacquinot, 2000). Combustion trials at TAMARA have also shown that increasing heat values of the feed stream and the resulting higher bed temperatures improve the burnout of bottom ash (Vehlow, 1998).

•

Disposal of APC residues in mines is a safe practice within Europe. Salt mines are well suited for safe long-term disposal of these wastes.

•

Nearly half of the APC residues generated in Europe are being deposited in German salt mines, with the other half being disposed of in landfills (Kirrmann, 2000b). Salt mines are well suited for long-term disposal of such wastes, particularly where they have high leachability. They offer a unique closed storage environment which is well isolated and dry, with a stable atmosphere and naturally gas-impermeable salt layers that allows long term conservation. Natural water barriers (impermeable layers such as clay bands) protect the salt layers against the risk of water infiltration or flooding. This combination ensures secure isolation of wastes and could be considered as preferable to conventional landfill. Salt mines also assure both security and avoidance of ground occupation (except in the case of existing wells used for salt production) (Kirrmann, 2000b).

•

Salt mine valorisation sitesuse residues as materials for filling, construction and secure completion. This is considered a recovery or recycling activity under German law rather than landfill (Kirrmann, 2000a).

•

A new salt mine for waste disposal is to be opened at Middlewitch in the UK. This will further extend the capacity of this disposal route for APC residues in Europe.

•

AEA’s scenarios evaluate the economics of treating tomorrow’s PVC waste with today’s technology. AEA’s choice of scenario format is unfortunate, as several promising technologies for thermal conversion of solid waste and treatment of salt residues are now being implemented. The industry believes that the APC mix and amounts of PVCrelated residues to be landfilled estimated by AEA are not representative of the likely situation in 2010. The calculations by AEA of the so-called “incinerator subsidy” in their “Economic

Page 26 of 45

European PVC Industry response to the Green Paper on PVC

Evaluation of PVC waste” is based on the following APC plant mix (Brown, 2000): 0% dry lime, 0% dry bicarbonate, 25% semi-dry lime, 25% wet and 50% semi-wet-wet. •

AEA developed scenarios for 2010 and 2020 that incorporated estimates for the amounts of PVC waste types, split between recycling, incineration and landfill. Estimates for the “incinerator subsidy” were also included. None of these scenarios allow for the development of thermal waste conversion or salt residue treatment technology. AEA’s scenarios therefore evaluate the economics of treating the PVC wasteof tomorrow with the technology of today or even yesterday.

•

Juniper (Anon., 1997) reviewed the status of all leading thermal conversion processes that are being promoted as future waste management solutions.The most important of these processes are gasification and pyrolytic methods, as well as combined gasification and pyrolysis. Developments in thermal treatment options will contribute to reducing the amount of neutralisation residues associated with PVC in 2010.

•

A table summarising the survey of promising technologies for treatment of salt residues from Municipal Solid Waste Incinerators undertaken by TNO (Rijpkema, 2000) is included in Table 2. TNO considers the five most promising technologies against the following aspects: • • • • • •

Commercial products Status of development Solid residue to be landfilled Percentage reduction of residue to be landfilled Economical feasibility Technological feasibility

•

The majority of promising technologies focus on the neutralisation of residues from absorption of HCl by wet scrubbers, which evaporate cleansed waste water. The HClrelated residues can either be upgraded to a commercial grade concentrated hydrochloric acid or calcium chloride (solution). SO2-related neutralisation residues (consist mainly of gypsum, not related to PVC) are not yet realistically considered for upgrading or recycling efforts because of their low solubility in water and poor market potential.

•

In Germany, a growing number of plants (5 at the moment, with 3 currently under construction) are operating wet scrubbers in a radically different way. These plants absorb HCl from the flue gases separately and upgrade this solution to a commercial grade. Widespread adoption of this technology has the potential to fully eliminate HCl related residues. Whilst the TNO-study suggests that the market potential for HCl is limited, this situation may change. A recent article in European Chemical News (Anon., 2000b) predicted that competition for hydrochloric acid likely to intensify in the coming years. The Neutrec process will reduce the volume of waste going to landfill by 95% (with reference to dry and semi-dry scrubbers) because the commercial product is a feedstock for soda plants. One pilot industrial plant at Rosignano in Italy, with a capacity of 2,800 tonnes per year, is currently in operation. Studies are currently being undertaken into the potential capacity extension of this plant to 8,000 tonnes per year. Another with a capacity of 50,000 tonnes/year, is under construction in France. The French plant will treat half of the neutralisation residues produced nationally, which accounts for 13% of the total generated in Europe (EU-17, referred to figures given in (Kirrmann, 2000b)).

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European PVC Industry response to the Green Paper on PVC

7DEOH - &KDUDFWHULVWLFVRIWHFKQRORJLHVIRUUHGXFWLRQRIWKHDPRXQWRIQHXWUDOLVDWLRQ UHVLGXHVWREHODQGILOOHG Technology

Commercial products

Status of development

Solid residue to be landfilled [kg/tonne MSW combusted]

% reduction of residue to be landfilled 1,2

Production of hydrochloric acid (chapter 3.1)

Concentrated hydrochloric acid (15 – 30 wt%)

5 plants in operation, 3 under construction (all in Germany)

10

33% (B)

Neutrec process (chapter 3.2)

Feedstock for soda plant

- Scrubbers (approx. 20) in operation since 1991 - Recycling of residue: 1 industrial pilot plant in operation; more capacity planned

3

Recycling of salt residue (chapter 3.4)

Calcium chloride

Pilot plant experiments executed

7.4 to 10.4

Recycling of salt residue: special case (chapter 3.4.1)

Calcium chloride

Industrial pilot plant just started operation

Adjustment of flue gas cleaning system (chapter 3.5)

Calcium chloride

Concept, composed of existing technology

Economic feasibility

Comments 2

Technical feasibility

Yes, proven

Yes, proven

Applicable to wet scrubber systems only; sensible for B. Market potential for HCl acid limited. Filtercake (SO2 related) not touched.

Yes, indicated

Yes, proven

Applicable as a retrofit to C and D. Recycling capacity yet to be extended, but not seen as a limiting factor.

31 to 51% (B)

Yes, possibly

Yes, probably

No market for calcium chloride expected: discharge in surface water ? Applicable to B. Filtercake (SO2 related) not touched.

7.0

~ 50% (B) ~ 65% (C) ~ 72% (D)

Yes, in this special case

To be demonstrat ed by pilot plant

Special case: revenue from CaCl2 not necessary: discharge in surface water ? Applicable to B. Maybe also applicable to C and D. Filtercake (SO2 related) not touched.

7.2 to 7.4

51 to 52% (B)

Yes, probably

Yes, probably

Applicable to B only. Market for CaCl2 not needed: discharge in surface water ? Filtercake (SO2 related) not touched.

-294% (A)

1.2 (dry matter)

3

94% (C) 95% (D)

1

The percentage reduction is indicative and is specified relative to flue gas cleaning configurations as given in Figure 1 with the amounts of solid residues produced as specified in Table 1. A negative value indicates an increase of the amount to be landfilled

2

The configurations are indicated by letters: A = wet scrubber with effluent discharge, B = wet scrubber with effluent evaporation, C = semi-dry scrubber and D = dry scrubber

3

The amount given includes the recycling of the flue gas cleaning residue. Without that (just application of a dry scrubber operated with sodium bicarbonate) the amount of residue to be landfilled is 15.7 kg per tonne MSW combusted and the percentages in reduction of landfill volume drop to 23% (C) and 38% (D)

•

Three processes generating calcium chloride are included within the TNO study. These will reduce the amount of waste residue to be landfilled by 50% (with reference to wet scrubbers with effluent evaporation). As for HCl, recent changes in the market indicates that calcium chloride is becoming a more attractive commercial product (McCoy, 2000).

•

Other promising technologies for dry scrubber residues are the TREFID process and the process offered by Taiheiyo. All of these developments reflect the fact that there is no

Page 28 of 45

European PVC Industry response to the Green Paper on PVC

stand-still in the advance of flue gas treatment technologies. By contrast, there is considerable innovation at present that will have positive economic and environmental effects in the future. •

Options for thermal conversion of waste residues are illustrated in Figure 4. )LJXUH (QHUJ\FRQYHUVLRQRSWLRQVIRU6ROLG:DVWH

CONCEPT

PROCESS

E NERGY CARRIER

Hea t

Biological Conversion

Anaerobic Digestion

B iogas

Bugs

S tarved Air

Solid W aste

T hermal Conversion

Ai r

No air

High pressure

Liquefaction

•

Gas ification

Low quality syngas 4-11 MJ/m 3

Combus tion

Flue gas

Pyrolysis/ Thermolysis

Medium quality syngas 11-22 MJ/m3 + char

Indirect Liquefaction/ Methanation

Liquid hydrocarbon fuel

Juniper’s report 7KH0DUNHWIRU3\URO\VLV *DVLILFDWLRQRI:DVWHLQ(XURSH(Anon., 1997) reviews the currents status of all leading thermal conversion processes that are being promoted as future waste management solutions. The key market driver is a search for better treatment technology than conventional moving grate incineration. The emphasis is put on: 1. Creation of less secondary wastes (ash, emissions to air etc.); 2. Production of gaseous fuels ("syngases", CO, H2 etc.); 3. Production of stable solid residues which can be recycled into useful products. Based on these aspects, the new technologies are being marketed as WKHUPDOUHF\FOLQJ. Juniper’s report covers 22 different processes for treating mixed waste streams, such as MSW, that have been developed in Europe, North America and Japan. These comprise gasification (10), pyrolytic methods (8) and both gasification and pyrolysis (4).

•

Many of the processes convert residues into a slag-like material that is much more stable than fly ash (which accounts for more than 60% of APC residues) and can be

Page 29 of 45

European PVC Industry response to the Green Paper on PVC

readily recycled into construction aggregates or other useful products. Two of the processes generate solid fuels suitable for combustion off-site. Acids produced by these processes are neutralised by conventional cleaning devices. Pyrolysis and gasification processes produce more concentrated syngas and HCl streams that require significantly smaller volume cleaning equipment (and corresponding smaller investment costs) compared with those streams from incineration. •

Pyrolysis and gasification technologies presently have 5-10% of the market share. Juniper forecasts that this will rise to 21% by 2006 at the expense of conventional moving grate incinerators. They also predict that two thirds of the new orders for new thermal processes will be for treatment of MSW, thereby increasing the capacity by a factor of ten from 0.5 million tonnes per year to nearly 5 million tonnes per year.

'LR[LQV •

Dioxin formation in MSWI is not related to PVC. Variations in combustion conditions are most important for the formation rates of dioxins in Municipal Solid Waste Incinerators. Removing PVC from Municipal Solid Waste will not reduce dioxin formation. This is also recognised by the EU Commission in the Green Paper on PVC, the main incinerator parameters, such as temperature and oxygen, have a major influence upon the formation of dioxins.

+HDY\PHWDOV Œ

Comments on the use of heavy metal stabilisers in PVC products and their safety, health and environmental aspects are contained within Section 1 of this document.

&RUURVLRQ •

There are several parameters that determine whether there is a risk of corrosion in MSWI. Even complete elimination of PVC is unlikely to substantially reduce the risk of corrosion.

•

According to one investigation (Rijpkema, 1999), it is important to distinguish between high and low temperature corrosion at MSWI facilities. Low temperature corrosion occurs at temperatures below the dewpoint of acidic o substances (e.g. HCl, H2SO4). At temperatures above 150 C, this type of corrosion is o unlikely. As the temperature of flue gas remains between 200 and 230 C at the boiler exit, this type of corrosion is only likely to occur beyond the boiler, i.e. in the quench and the acidic step of a wet scrubber, where the flue gas temperature cools below the o dewpoint (around 70 C). High temperature corrosion can only occur in the boiler. In principle, high temperature corrosion may occur at a high rate when local conditions around steam pipes are alternating between reducing and oxidising states. Corrosion can also be caused by (alkali) sulphates or chlorides. The main cause of high temperature corrosion for MSWI facilities is the presence of chlorides.

•

Although both types of corrosion occur in MSWI facilities, low temperature corrosion is considered less important than high temperature corrosion. This is partly due to the fact that low temperature corrosion can be controlled more easily through the use of

Page 30 of 45

European PVC Industry response to the Green Paper on PVC

protective materials that are cheaper and more effective in this temperature area than in the high temperature area. Another reason for increased attention to high temperature corrosion is its role within discussions on understanding the causes of reduced energy efficiency in MSWI facilities. •

The high temperature corrosion process is still not completely understood. One plausible explanation focuses on protective layer of metal oxides that forms on the boiler steam pipes due to oxidation. Under normal oxidative conditions, this layer is maintained. However, if there is a lack of oxygen, this layer can be (partly) destroyed by reduction.

&RVWV •

All waste materials in MSW have their own specific incineration costs, related to operation of the incinerator and external environmental costs. Assessing the cost contribution of a single material in isolation, as has been the case in AEA paper referenced in the EU Green Paper on PVC, is unrealistic, discriminatory and unrepresentative.

•

A recent study (Kirrmann, 2000c) has attempted to estimate the specific incineration (variable + fixed) and external costs for various constituents of MSW. The external costs are associated with the environmental impactof municipal solid waste incineration (MSWI) caused by emissions to air, the use of air pollution control (APC) reagents and residues. This is the only study that has attempted to estimate the overall costs of single materials in addition to PVC in MSWI (i.e. processing and external costs). The results are based on an average European situation with respect to incinerator gas treatment systems. They also assume that 90% of MSW incinerators are thermally limited, whilst the remaining 10% are mass limited (see point 1 below for explanation). This study has used data and methods from:

1. A TNO study (Rijpkema, 1999) that was the first to assess incineration costs (fixed and variable) for various wastes types, including PVC. The costs for two configurations of gas treatment in the Netherlands were applied and three types of operation limitations were considered (thermal, mass, no limitation). The cost was shown to be highly dependent on whether or not an incinerator is thermally limited. A thermally limited plant cannot run at maximum throughput capacity for waste with higher calorific value than average MSW. Modern MSWI facilities are generally thermally limited. 2. The EU horizontal study on incineration (Jacquinot, 2000). However, this focused only on the YDULDEOH costs for average MSW and PVC, failing to take into account different operation limitations as TNO study mentioned above had done. 3. The study made by AEA (Brown, 2000). Costs,called external costs for MSW and PVC, were included in this study in addition to the incineration costs based on (Jacquinot, 2000). However, there was no break-down of MSW into single materials for direct comparison with PVC. The study concludes that all waste types contribute to the overall costs of MSWI. PVC total costs are shown to be in the range of the other plastic materials. By using these costs and taking into account the percentage of each waste type in

Page 31 of 45

European PVC Industry response to the Green Paper on PVC

MSW, it is possible to assess the share of costs for each waste material in MSW. PVC waste contributes only 2.3% to the total costs of incinerating MSW. •

In any cost assessment of incineration when there is recovery of heat and/or energy, the environmental benefits from avoiding the use of fossil fuels should also be taken into account. A study by Ecobalance (Anon, 1997) demonstrated that the generation of electricity from MSW incineration, as well as saving resources, gives rise to significantly lower greenhouse gas emissions than those produced by traditional power generation for the same quantity of electricity using coal or fuel oil (and even slightly lower than from natural gas). PVC, as part of the plastics fraction, contributes to the useful calorific energy in MSW.

5HIHUHQFHV Anon., 1997.7KHPDUNHWIRU3\URO\VLV *DVLILFDWLRQRI:DVWHLQ(XURSH. Juniper Consultancy Services Ltd. Anon., 2000a.$VVHVVLQJWKHHFRHIILFLHQF\RISODVWLFVSDFNDJLQJZDVWHUHFRYHU\ APME Association of Plastics Manufacturers in Europe. Anon., 2000b. 0DQ\FKDQJHVLQ+&OSURGXFWLRQ European Chemical News. Brown, K.A., Holland, M.R, Boyd, R.A., Thresh, S., Jones, H., Ogilvie, S.M, 2000.(FRQRPLF (YDOXDWLRQRI39&:DVWH0DQDJHPHQW$UHSRUWSURGXFHGIRU(XURSHDQ&RPPLVVLRQ (QYLURQPHQW'LUHFWRUDWH. AEA Technology. Chandler, J.A., Eighmy, Taylor T., Hartlén, Jan, Hjelmar, Ole, Kosson, David S., Sawell, Steven E., Van der Sloot, Hans A. and Vehlow, Jürgen, 1994.$Q,QWHUQDWLRQDO3HUVSHFWLYH RQ&KDUDFWHUL]DWLRQDQG0DQDJHPHQWRI5HVLGXHVIURP0XQLFLSDO6ROLG:DVWH,QFLQHUDWLRQ. International Ash Working Group. Jacquinot, B., Hjelmar, Ole, Vehlow, Jürgen, 2000.7KHLQIOXHQFHRI39&RQWKHTXDQWLW\DQG KD]DUGRXVQHVVRIIOXHJDVUHVLGXHVIURPLQFLQHUDWLRQ. EU Commission B43040/98/000101/MAR/E3. Kirrmann, C., 2000a.)HDVLELOLW\6WXG\RIWKH6DOW0LQHV6WRUDJH5RXWH6WHSUHSRUW $SSUDLVDORIWKHVDOWPLQHVVWRUDJHURXWHIRUUHVLGXHVIURPLQFLQHUDWLRQ. Bertin Technologies DT B 99 101. Kirrmann, C., 2000b.)HDVLELOLW\6WXG\RIWKH6DOW0LQHV6WRUDJH5RXWH6WHSUHSRUW &RPSDULVRQRIWKHVDOWPLQHVVWRUDJHZLWKFRPSHWLQJURXWHVIRU06:,UHVLGXHV PDQDJHPHQW. Bertin Technologies DT00B 017. Kirrmann, C., 2000c.,QFLQHUDWLRQRI39&DQGRWKHUSURGXFWVLQ06:$VVHVVPHQWRI DGGLWLRQDOFRVWVIRUYDULRXVZDVWHVZLWKFRPSDULVRQWR39&LQGRPHVWLF:DVWHLQFLQHUDWLRQ. Bertin Technologies. Lighty, J.S., Veranth, J.M., 1998. 7KHUROHRIUHVHDUFKLQSUDFWLFDOLQFLQHUDWLRQV\VWHPVD ORRNDWWKHSDVWDQGWKHIXWXUH Twenty-seventh Symposium (International) on Combustion. The Combustion Institute. pp. 1255-1273. McCoy, M., 2000. 5RDG&OHDUV)RU&DOFLXP&KORULGH'ZLQGOLQJVXSSOLHVDUHJRRGQHZVIRU EHOHDJXHUHGEXVLQHVV C&EN. pp. 3.

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European PVC Industry response to the Green Paper on PVC

Rigo, H.G., Chandler, A.J. and Lanier, W.S., 1995.7KHUHODWLRQVKLSEHWZHHQFKORULQHLQ ZDVWHVWUHDPDQGGLR[LQHPLVVLRQVIURPZDVWHFRPEXVWLRQVWDFNV. ASME Research Committee on Industrial and Municipal Wastes CRTD-Vol. 36. Rijpkema, L.P.M., 1999.39&DQG0XQLFLSDO6ROLG:DVWH,QFLQHUDWLRQ%XUGHQRUEHQHILW" TNO TNO_MEP-R99/462. Rijpkema, L.P.M., 2000.06:&VDOWUHVLGXHV6XUYH\RIWHFKQRORJLHVIRUWUHDWPHQW. TNO R2000/317. Vehlow, V., 1998. ,PSURYLQJWKHTXDOLW\RI0XQLFLSDO6ROLG:DVWH,QFLQHUDWLRQ%RWWRP$VK DQG2WKHU5HVLGXHV 6th annual Conference on Incineration: Update On Policy, Regulation and Technology, Amsterdam. pp. 26. Whiting, K.J., 1997. 0DQDJHPHQWRI$VK5HVLGXHVIURP:DVWHWR(QHUJ\3URFHVVHV$Q RYHUYLHZRI&XUUHQW3UDFWLFHVLQ(XURSHDQG7HFKQLFDO$OWHUQDWLYHV Waste-to-Energy, Copenhagen. pp. 23. Wikstrøm, E., Løfvenius, G., Rappe, C. Marklund, S., 1996. ,QIOXHQFHRI/HYHODQG)RUPRI &KORULQHRQWKH)RUPDWLRQRI&KORULQDWHG'LR[LQV'LEHQ]RIXUDQVDQG%HQ]HQHVGXULQJ &RPEXVWLRQRIDQ$UWLILFLDO)XHOLQD/DERUDWRU\5HDFWRU. Environmental Science & Technology.  1637-1644. Wikstrøm, E., 1999. 7KHUROHRI&KORULQHGXULQJ:DVWH&RPEXVWLRQ. phD-Umeå. Wikstrøm, E., 2000. )LQDO5HSRUW8PHnVWXG\. . Anon, 1997. /LIH&\FOH&RPSDULVRQRI(QHUJ\3URGXFWLRQRID:DVWHWR(QHUJ\)DFLOLW\WR 2WKHU0DMRU)XHO6RXUFHVECOBALANCE INC

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European PVC Industry response to the Green Paper on PVC

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,QGXVWU\UHVSRQVHWR4XHVWLRQFRQWDLQHGZLWKLQWKH*UHHQ3DSHU There is no scientific or financial reason need to single out PVC as a material of particular concern in incineration plants. Regardless of the presence of PVC, incinerators have to be built in the same way, including flue gas cleaning installations. When considering total incineration costs (i.e. sum of treatment and external costs), PVC is in the range of the other plastic materials. As a single material, it accounts for only 2.3% of the total incineration costs. If measures were to be introduced for MSWI, these should cover all contributing waste types, not just PVC in isolation. Introducing specific PVC measures would be a discriminatory action. As part of its Voluntary Commitment, European PVC producers and their industry partners have committed to supporting technological developments that will minimise the quantity of salt residues produced as a result of MSWI and develop purification technologies with the objective to recover the salt for reused in chemical processes.

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European PVC Industry response to the Green Paper on PVC

The situation with relation to Incineration will change dramatically following the adoption of the EU Incineration Directive (PE-CONS 3641/00) and the introduction of new technologies such as pyrolysis and gasification coupled with higher energy recovery rates.

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European PVC Industry response to the Green Paper on PVC

/$1'),// 6.1 Comments on the Green Paper assessment of PVC in landfill •

PVC products under landfill conditions are mainly subject to the processes of leaching and biodegradation. Various investigations have indicated that the PVC polymer matrix itself is not subject to degradation. Vinyl chloride concentrations at landfill sites originate from other sources (Mersiowsky et al., 1999; Mersiowsky et al., 2000b).

•

The behaviour of various flexible PVC products under landfill conditions was investigated in laboratory-scale experiments designed to represent conditions in average sanitary landfills. The behaviour of the plastic compounds was found to differ considerably depending upon the selection of plasticisers. Two of the most relevant plasticisers, DEHP and DIDP, showed practically no detectable losses. Losses of BBP were also small or close to analytical detection limits. The adipate DINA, solely a secondary plasticiser, showed more losses. These were attributed to the lesser compatibility of DINA with PVC resin. DINA is used in cable formulations for cold climates (e.g. Scandinavia) because it improves the lowtemperature flexibility of the PVC compound. It has a market share of only about 5% (Mersiowsky et al., 1999; Mersiowsky et al., 2000b).

•

Temperature affects the malleability of PVC compounds and related diffusion processes. Average landfill temperatures range from 20 to 55°C, with a mean value of around 35°C (Dohmann, 1997). Experiments at different temperatures between 20°C and 85°C (Ejlertsson et al. 2000) concluded that a definite increase in the loss of plasticisers DEHP and BBP occurred only at temperatures of 70°C and above. It would be extremely rare to find such temperatures in landfills.

•

Plasticiser losses are predominantly attributed to microbial consumption, either at the PVC product surface or in surrounding waste. In contrast to biodegradation, leaching processes are much less relevant (Ejlertsson, 1997; Mersiowsky et al., 1999; Mersiowsky et al., 2000b; Ejlertsson et al. 2000).

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Since biodegradation is the primary factor, plasticiser losses from PVC compounds do not translate into equivalent concentrations in leachate. Instead, findings of phthalic compounds (i.e. phthalates and their degradation products) were comparatively low and transient. Concentrations of phthalic compounds in leachate were orders of magnitude lower than expected following release and dissolution, often remaining below blank controls or undetectable (Ejlertsson, 1997; Mersiowsky et al., 1999; Ejlertsson et al. 2000).

•

Any potential loss of plasticisers will not continue indefinitely, since PVC compounds undergo glass transition after the residual plasticiser content falls below a critical value (or if temperatures decrease). This transition practically prevents further losses and renders the PVC product brittle. This process was confirmed in landfill simulation assays with the plasticiser DINA, where substantial losses subsided during the experimental period and before all plasticiser was had been released (Mersiowsky et al., 2000b).

•

Any release of stabilisers is generally attributable to superficial leaching. A noticeable loss of lead from the investigated PVC cable compound was reasonably explained by migration properties of the secondary plasticiser DINA. Otherwise, stabilisers are expected to be fixed within the PVC matrix. The contribution of PVC products to the

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European PVC Industry response to the Green Paper on PVC

heavy metal inventory in landfills is negligible. The impact of organotin stabilisers on leachate quality was found to be minor or non discernible (Mersiowsky et al., 1999). •

There are currently no conclusive indications, neither substance properties nor experimental findings, that gaseous emissions constitute a relevant pathway for PVC additives (Ejlertsson et al. 2000).

•

The landfill body and solid waste matrix itself function as an anaerobic fixed-bed filter. Thus the retention and biodegradation of pollutants in leachate is possible. Attenuation must be considered in risk assessments (Mersiowsky et al., 1999). Predicted environmental concentrations (PEC) based upon findings in raw and undiluted leachate from a number of European landfill sites have been found not exceed the predicted no effect concentrations (PNEC) for aquatic toxicity (Mersiowsky et al., 1999; Mersiowsky et al., 2000b).

•

Fires in landfill should be considered in a similar way to any other accidental fire where the presence of chlorinated materials leads to the production of dioxins, regardless of whether PVC is present. The potential hazard from polyaromatic hydrocarbons (PAH) is much greater as analysis of accidental fires has demonstrated.

•

PVC is suggested to be the largest source of Bisphenol A in landfill. This conclusion was based upon Japanese landfill research which is unrepresentative of the European situation. Furthermore, Bisphenol A is alleged to have endocrine modulation effects which are not consistent with recent scientific data on this subject.

5HIHUHQFHV Argus Arneitsgruppe Umweltstatistik An Der Tu Berlin (2000) — The Behaviour of PVC in Landfill; Report for European Commission, in association with University of Rostock and Carl Bro a/s (Dänemark), General Directorate Environment (DG XI), Brussels/Belgium, 2000 Bauer M. J., Herrmann R. (1998) — Dissolved Organic Carbon as the Main Carrier of Phthalic Acid Esters in Municipal Landfill Leachates, Waste Management Res. 16 (1998), No. 5, pp. 446–454 Dohmann (1997) – BMBF-Verbundvorhaben Deponiekörper Teilvorhaben 3: Emissionsverhalten umweltrelevanter Schadstoffe in Abhängigkeit von der Zusammensetzung des Abfalls und der Standzeit der Deponien (German); Report for German Ministry of Research (BMBF) by Institut für Siedlungswasserwirtschaft, RheinischWestfälische Technische Hochschule Aachen, 1997 Ejlertsson J. (1997) – Fate of Phthalic Acid Esters during Digestion of Municipal Solid Waste under Landfill Conditions, Linköping Studies in Arts and Science No. 158, Linköping/Sweden, 1997 Ejlertsson J., Hörsing M., Mersiowsky I. (2000) — Behaviour of PVC Products in Landfilled Municipal Solid Waste at Different Temperatures – Modular Environmental Test System (METS) Study in Support of the Research Project »Long-term behaviour of PVC products under soil-buried and landfill conditions«; Final Report for ECVM, Norsk Hydro ASA, ECPI, ESPA and ORTEP, Linköping/Hamburg, 2000

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Ejlertsson J., Mersiowsky I., Fredriksson A. (2000a) — Long-Term Behaviour of Organotinstabilised PVC Products under Landfill Conditions; Executive Summary for ORTEP and Vinyl Institute, Linköping/Hamburg, 2000 Furtmann K. (1993) – Phthalate in der aquatischen Umwelt (Phthalates in the Aquatic Environment), in: Schriftenreihe des Landesamtes für Wasser und Abfall in NRW, 1993 (English version available) Kuballa J., Jantzen E., Steffen D. (1998) — Endokrin wirkende Stoffe in kommunalen Klärschlämmen – Beispiel zinnorganischer Verbindungen, Wasser und Boden 50 (1998), S. 30–32 Mersiowsky I., Ejlertsson J., Stegmann R., SvensssonB. H. (1999) — Long-term behaviour of PVC products under soil-buried and landfill conditions, Final Report for Norsk Hydro ASA, ECVM, ECPI, ESPA and ORTEP, Hamburg, 1999 Mersiowsky I. (2000) — Strategies and Instruments of Substance Flow Management in Integrated Product Policy – Example of PVC Products and Additives (dissertation manuscript for submission at Technical University of Hamburg-Harburg/Germany, autumn 2000) Mersiowsky I., Brandsch R., Ejlertsson J. (2000a) — Screening for Organotin Compounds in European Landfill Leachates (submitted to J. Environ. Quality) Mersiowsky I., Weller M., Ejlertsson J. (2000b) — Fate of Plasticised PVC Products under Landfill Conditions: A Laboratory-Scale

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European PVC Industry response to the Green Paper on PVC

,QGXVWU\UHVSRQVHWR4XHVWLRQFRQWDLQHGZLWKLQWKH*UHHQ3DSHU There is no immediate need for action concerning phthalic and organotin compounds in landfill leachate, as a conservative PEC/PNEC comparison between the raw and undiluted leachate indicates that detected concentrations do not constitute environmentally relevant emissions. Furthermore, PVC products do not require any specific landfill management practices that would incur additional costs compared with municipal solid waste in general. PVC products do not significantly contribute to the heavy metal inventory in landfills. Since PVC products cannot conclusively be identified as the sole and most relevant source of phthalic and organotin compounds in landfills, other waste components must be taken into consideration. Waste management measures directed specifically at PVC products would be inappropriate. Sanitary landfills operated in accordance with the appropriate EU Directive and respective national technical guidelines will ensure effective leachate containment, abstraction and treatment. Since the removal of phthalic and organotin compounds appears sufficient, either by adsorption to sludge or activated carbon, or by aerobic biodegradation and other treatment technologies, there is no conclusive necessity for additional technical measures. A workshop with the scientists of the two landfill studies was held in October 2000. The research groups reached common conclusions as the two projects were found to agree on a number of findings, or produced complementary results. The discussion corroborated the findings of the three-year project, but also pointed out that different processes can take place at temperatures above 80 °C, which may be reached in rather rare and localised spots in a landfill. This workshop supports the conclusion that PVC products do not require any specific landfill management practices.

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European PVC Industry response to the Green Paper on PVC

27+(5+25,=217$/$63(&762139& &RPPHQWVRQWKH*UHHQ3DSHUDVVHVVPHQWRIRWKHUKRUL]RQWDODVSHFWVRQ 39& •

Substitution of materials on environmental, health, safety and cost-performance grounds has always been and should remain a common practice in a competitive market. Every substitution in both directions is a reality and a challenge to any material for utilising its optimisation potential to remain the material of preferred choice.

•

PVC has been used for more than 40 years in many different important applications. As with any activity (industry, transport, life itself), the use of PVC contributes towards environmental pollution through production, conversion, consumption and waste management but no differently to any other material.

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PVC is certainly one of the most thoroughly investigated of all modern materials. Nevertheless, despite a phenomenal number of studies, no significant measurable impact on the environment or human health outside of production plants has been demonstrated.

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Findings from the five studies undertaken as part of the EU Commission’s horizontal initiative, along with the conclusions of the Green Paper, do not raise any issues of concern specific to PVC. Waste management and the use of additives are issues common to all materials. Similar conclusions would undoubtedly have been reached if the horizontal initiative had focussed on any alternative material.

•

The PVC industry provides widespread economic prosperity and employment. Accident numbers in the industry are below average, which itself compares favourably with other industry sectors. Published life-cycle studies, conducted in accordance with ISO standards, clearly demonstrate that PVC holds a favourable ecological position compared to competing products in its main application markets.

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The discovery of a hazard for PVC production plant workers through exposure to the carcinogenic properties of vinyl chloride monomer in 1974 was followed by the immediate implementation of stringent technical measures by PVC producers to minimise the risk to their staff. The success of these measures is reflected in the leading standards of health and safety in PVC production plants today.

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Dioxins have been demonstrated not to be a PVC issue. PVC production is only a very minor contributor to dioxin levels throughout the world (much less than 1%). It has also been demonstrated that there is no connection between the presence of PVC in municipal solid waste and the generation of dioxin emissions at waste incinerators.

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PVC has a low dependency on non-renewable resources, and a correspondingly low contribution to carbon dioxide levels in the environment. Durability, lightweight and energy-saving attributes of PVC products in service are important sustainability considerations, too.

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Recycling rates for all types of waste should be increased to bring benefits in terms of resource recovery and environmental protection. This is part of the change required to meet the needs of sustainable development and therefore an issue for society as a

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European PVC Industry response to the Green Paper on PVC

whole. Within the debate on how to raise recycling rates, the general long life of PVC applications (compared to many alternative materials) needs to be taken into account. •

In practice, there is no direct connection between the current level of PVC production and quantity of PVC waste generated today. This means that comparisons of PVC against alternatives need to be made not only on a material by material basis, but also application by application. For example, it is misleading to compare the recycling rate of a material used in construction applications with the recycling rate of a potential alternative material currently used primarily in packaging.

•

As part of the recycling challenge, the PVC industry has clearly acknowledged its responsibility and committed to achieve targets on the basis of a voluntary approach for some key applications in addition to its obligations under existing or forthcoming regulations (packaging, WEEE, ELV etc.).

•

As for any material, any substitution policy on PVC should only be developed with proper reference to the benefits that its performance brings to the society, and in the light of a total life-cycle comparison with potential alternatives. Legislative controls specific to PVC and in the absence of such comparative perspective will seriously undermine the European PVC industry’s competitiveness. The consequences will be a heavy reduction in jobs, investment and a questionable benefit to society.

•

In the words of Jonathan Porritt, chairman of “The Natural Step” and official advisor to the UK Government: “ ... sustainability is a tough challenge for PVC. But not that dissimilar from the challenge that confronts DOOmaterials. It serves little purpose arguing the elimination of PVC without first assessing the degree to which any substitutes would have a lower ‘sustainability footprint’. PVC may or may not have a place in a genuinely sustainable future, but exactly the same question must be asked to DOOmaterials, be they man-made or natural, before leaping to what are often ill-judged and unscientific conclusions.”

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European PVC Industry response to the Green Paper on PVC

,QGXVWU\UHVSRQVHWR4XHVWLRQFRQWDLQHGZLWKLQWKH*UHHQ3DSHU Any legislation regarding one single material is inappropriate without having equally analysed its alternatives. Such a comparison has to consider the whole life cycle of each specific application and not just end-of–life aspects. Existing regulations focus on applications rather than specific materials. European PVC producers and their industry partners believe this is the right approach. Regulation focusing on a single material is unjustified, uneconomic and discriminatory. It would also be inappropriate to consider such regulation without first having analysed all of the alternative materials, application by application, on the basis of a full lifecycle analysis. Consequently, the appropriate instrument for developing a horizontal strategy on PVC is the voluntary approach put forward by the industry, supported by a recommendation encouraging member states to support the industry in achieving the challenging targets it has set. The Voluntary Commitment of the PVC Industry is an opportunity to make steps forward towards sustainability and good product stewardship by: Œ Œ Œ Œ

Continuous optimisation of the manufacturing processes Addressing additives issues Increasing recycling Setting up a financial scheme to achieve the targets

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European PVC Industry response to the Green Paper on PVC

&RQFOXVLRQ Amongst issues for consideration, the Green Paper lists voluntary and/or mandatory measures. The PVC industry believes voluntary action is the only workable approach when a single material is concerned. Mandatory measures are only viable when they cover all relevant materials within an application sector. Targeting one single material across applications has an anti-competitive effect on specific industries, without any scientific (environmental, health, safety, financial and social) grounds. European PVC producers and their industry partners are looking forward to working with the European Parliament, Member State representatives, the EU Commission and other stakeholders during the consultation process. They hope that decision-makers will support the PVC industry’s voluntary approach and help it to achieve the targets included in its Voluntary Commitment. The industry partners are working to achieve an outcome based upon sound-science that allows the EU Commission to meet its target of defining the most appropriate policy on PVC in order for it to take steps towards sustainable development as soon as possible.

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European PVC Industry response to the Green Paper on PVC

&RQWDFW'HWDLOV A copy of this document, along with other background information such as The PVC Industry Voluntary Commitment and industry response to the 5 EU horizontal initiative studies, can be obtained by visiting www.pvcinitiative.com If you would like more information on any of the issues raised within this document, please contact the relevant PVC industry association listed below: 7KH(XURSHDQ&RXQFLORI9LQ\O0DQXIDFWXUHUV(&90 ECVM Represents the European PVC producing companies and is a division of the Association of Plastic Manufacturers in Europe (APME). Its membership includes the 10 leading European PVC producers which together account for over 98 per cent of Europe’s production of PVC resin. Avenue E van Nieuwenhuyse 4 B-1160 Brussels Tel: + 32 2 676 74 43 Fax: + 32 2 676 74 47 www.pvc.org (XURSHDQ3ODVWLFV&RQYHUWHUV(X3& EuPC represents approximately 30,000 predominantly medium-size, plastic processing operations in Europe. These companies have over one million people on their payrolls, 85% of whom work for companies that employ less than 100 people. The individual members combine to produce a processing capacity of more than 30 million tonnes of plastic every year. Avenue de Cortenbergh 66 Bte 4 B-1040 Bruxelles Tel: + 32 2 732 41 24 Fax: + 32 2 732 42 18 www.eupc.org 7KH(XURSHDQ6WDELOLVHUV3URGXFHUV$VVRFLDWLRQV(63$ ESPA represents the whole of the European stabilisers industry through its five branches: ‡ European Cadmium Stabilisers Association (ECADSA) ‡ European Lead Stabilisers Association (ELSA) ‡ European Tin Stabilisers Association (ETINSA) ‡ European Mixed Metal Solid Stabilisers Association (EMMSSA) ‡ European Liquid Stabilisers Association (ELISA) Avenue E van Nieuwenhuyse 4 B-1160 Brussels Tel: + 32 2 676 72 86 Fax: + 31 2 676 73 01 7KH(XURSHDQ&RXQFLOIRU3ODVWLFLVHUVDQG,QWHUPHGLDWHV(&3,

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European PVC Industry response to the Green Paper on PVC

ECPI represents 21 member companies that are involved in the production of plasticisers. Plasticisers are esters (mainly phthalates) which are used generally in the production of flexible plastic products, predominantly PVC. Avenue E van Nieuwenhuyse 4 B-1160 Brussels Tel: + 32 2 676 72 60 Fax: + 32 2 676 72 16 www.ecpi.org

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