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How to organise waste management and emission control?

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How to organise waste management and emission control?

Input chemicals can be integrated into a company’s products, may react in the process (e.g. 2-component glues or cross-linkers) or may be emitted via waste gas, wastewater, or as waste.

What are the advantages of managing environmental emissions?

Managing environmental emissions is not only relevant to protect the environment from hazardous substances, but may also lead to efficiency gains or cost reductions, e.g. if fees for water discharges or waste disposal can be saved. 

Working on environmental emissions starts with an analysis of the company’s flow of chemicals. This analysis can identify inefficient resource uses and unnecessary losses of chemicals; if remedies are implemented, savings are possible due to:

  • more efficient resource use (smaller amounts can be purchased),
  • reduction of (hazardous) wastes resulting in lower disposal costs or
  • the reduction of fees for wastewater discharges.

Reducing the emission of hazardous substances contributes to an improved regional environment and supports the wellbeing of the neighbourhood. It increases trust in the company and contributes to a good reputation.

If emissions are reduced (significantly) below legal limits, accidental non-compliance is less likely, and inspectors tend to be more inclined to be cooperative in solving issues with the company.

Knowing company processes well is a value as such, because, for example, chemical flow analyses can also be used for other purposes, such as technical process organisation, emergency planning, OSH risk assessment and risk management, etc.

How to define priorities in emission control?

The current approaches to control emissions into air and water focus on “traditional” pollutants, such as nitrogen oxides (NOx), sulphur oxides (Sox) or certain heavy metals (air) as well as the biological oxygen demand (BOD), and sum parameters, such as the total amount of halogenated compounds (AOX). Individual hazardous substances are only regulated if there are specific requirements in installation permits or local requirements, or if discharge fees have been imposed. 

From the perspective of a non-toxic environment, persistent chemicals are of highest concern, e.g. PBT/vPvB and PMT/vPvM1, such as the group of per- and polyfluorinated chemicals (PFAS). This is because they are neither degraded nor destroyed in the environment and as a result exist for a long time. They may accumulate in the environment and concentrations build up over time and eventually reach levels that cause damage to the environment. Another group of priority chemicals is environmental endocrine disrupters (EDCs env)2. Reducing emissions of these chemicals should be a top priority. 

The content of hazardous chemicals may contribute to waste being classified as hazardous waste. This triggers additional legal requirements (and costs) for waste disposal. According to the EU waste hierarchy, hazardous wastes should be prevented and reduced. 

  1. Substances with these properties have to be identified in the safety data sheet. They may also have a classification with the H-statements EUH440, EUH441, EUH450 or EUH451. ↩︎
  2. These should be indicated via an EUH 430 or EUH 431. ↩︎

What are the legal requirements?

Requirements on the emission of hazardous substances to water and air are defined in environmental permits. There are certain criteria and conditions defining which types and sizes of installations need to have a permit. Permit requirements may include: 

  • Emission limit values (ELVs) for waste air, with an obligation to demonstrate compliance either by continuous measurements or with representative measurements of air emissions;

  • ELVs for the wastewater, with obligations to demonstrate compliance either by continuous or representative measurements;

  • Reporting obligations about annual amounts of emissions into water and air for specific substances.

Depending on the type of your production and where it is located (e.g. in ecologically sensitive areas), specific requirements may be defined in the environmental permit. Even if you do not have a permit, out of responsibility for the environment and good practice considerations, you should consider reducing or eliminating emissions of hazardous substances to the environment. 

All companies that generate (hazardous) waste must classify and label it and ensure that it is disposed of safely and appropriately. If waste is classified as hazardous, only specific installations may process it and the disposal process must be documented according to EU legislation. The requirements are transposed to national legislation, i.e. specific requirements may exist.

Assessment of the company’s flow of chemicals – mass balancing

The basis of managing chemical emissions is in-depth knowledge of the flow of chemicals through the company and its processes. The starting point for this is the chemicals inventory with information on the input amounts of chemicals and their uses in products or processes. As (the emissions) of all (relevant) substances cannot be measured to identify emissions, material flow analyses may involve estimates and assumptions based on knowledge of the intended use of chemicals, the design of the processes in which they are used and the properties of the substances. 

The analysis of the flow of chemicals is a core tool to identify potentials for resource savings and/or emission reduction.

Identification of usage amounts

  • Use the chemicals inventory to identify the amount of the chemical that has been purchased and the purpose for which the company uses it. 
  • Use the SDS or chemical databases to identify the water solubility and the boiling point of the chemical.

Identification of the workplaces where the chemical is used

  • Find out at which workplaces and in which processes the chemical is used. 
  • Look at the process design and discuss the use of the chemical with technical staff and workers to understand how the chemical is used in practice. 
  • Based on this information, develop a flow chart that illustrates the chemical’s flow through the company. 
  • Record if there are sources for emissions into air, water or waste at each of the workplaces and/or if the substance is incorporated into the product. 

Quantify flows

  • Consider how the substance may behave during processing and estimate the proportions of the used chemical which is integrated into the product, reacts or is emitted to the air, the water and the waste for each of the process steps. 
  • You may use measurements of workplace air, waste gas or wastewater as well as knowledge of the composition of wastes to complement and check your estimates. 
  • Involve technical experts and ask them for their estimates to further consolidate your mass balance. 

Examples of considerations: 

  • In the workplace, solid substances may emit air as dust, but this dust may settle rather than being transferred to ambient air. Dust settling on the floor is disposed of as waste. 
  • Solvents with a low boiling point will be emitted into the workplace air. The amounts eventually emitted into ambient air depend on any waste gas treatment and how efficient it is. 
  • If a process is water based, substances may be emitted with the wastewater, especially when they are water soluble and are washed off. Another consideration to be kept in mind here is the existence of wastewater treatment and its efficacy to remove/degrade the substance determine the emitted amounts.

Make a simple mass balance

Make a simple mass balance for each relevant processing step and include quantities of the chemical in the process flowchart:

  • Set the input amount at the first processing step to 100% and define the amounts ending up in product, air, water and waste, ensuring that their sum equals 100%. 
  • The input amount to the next processing step would be lower than the first, as the emissions must be subtracted. 
  • At the end, you should have a flow chart with quantified (estimated/measured) amounts of all inputs and emissions, including products and wastes, of the chemicals. 

Analyse the mass balance

  • When you have finished the mass balance, discuss it with colleagues and check what it means in terms of resource efficiency and potentials to reduce emissions. 
  • Options to increase resource efficiency and potential measures to implement them, e.g. automatic dosage systems, process redesign to eliminate the use of certain chemicals or lowering operating temperature would benefit both the environment and the company’s finances. Accordingly, their implementation could be a priority and one that is the easiest to convince the company management of. 
  • If there are processes giving rise to large environmental emissions without abatement technologies, you should start identifying options for emission reduction, starting with substitution, and ending with technical options that may allow the internal reuse or recycling of the chemicals used. 

Which measures reduce emissions?

Substitution

Substitution is the risk management option that addresses risks at source and therefore may solve several problems at the same time, such as workplace risks, environmental risks and the generation of hazardous wastes. Furthermore, in the context of environmental risk reduction, substitution should start with the question of what function a product or chemical fulfils in order to identify all options for risk reduction, including those based on different materials or technologies.

Technical measures

Technical controls to reduce environmental emissions normally consist of two steps: 

  1. technologies to capture emissions from a process and 
  2. technologies to prevent emissions into the environment either by enabling recycling and reuse of the chemical or by destroying the chemical and/or disposing of it as waste. 

Capturing water emissions is “naturally” implemented for water, because in operational processes it is used in a targeted way, led through piping and kept in containers, not least to keep workplaces and the installation dry. 

Capturing air emissions may be implemented in order to protect workers and/or to avoid losses of chemicals into the air. Devices and equipment range from closed processes with directly attached exhaust extraction via local exhaust ventilation to the general ventilation system in a production hall. 

Emissions into water and air captured thus can either be processed to recover a potential chemical substance or subjected to treatment technologies that destroy the unwanted chemicals. An example of the former are absorbers, which accumulate solvents from waste air, which are then recovered when the absorber is regenerated. An example of the latter are wastewater treatment plants, which degrade organic substances or remove pollutants via sewage sludge, which is eventually disposed of as waste. 

Technical measures may have different efficacies for different chemicals and their adequacy for a specific substance should be checked with the equipment supplier.

Organisational measures

Organisational measures that are relevant to environmental emissions mainly include changes in process designs that lead to changes in the use of chemicals, i.e. either a reduction of amounts or, in the context of a substitution, result in the use of different chemicals with less harmful properties. Examples include: changing the sequence of processing steps, reducing the cleaning frequencies of paint pistols by better planning of colour changes or improving logistics to avoid long storage of (wet) materials to avoid the need to use biocides. 

Step-by-step

  • Identify priority chemicals for the mass balance; priorities could be derived based on the company policy, identified problems with emissions (e.g. permits, fees, wastes, etc.) or specific hazards.

  • Identify usage amounts and substance properties.

  • Develop a mass flow scheme with all (processing steps) and products the chemical is used in.

  • Identify emission pathways for all steps performed by the company.

  • Quantify emissions: the entire input amount should be allocated either to the product, wastes, waste air or wastewater.

  • Identify problem areas, e.g. large amounts of chemicals ending up in waste, risks of exceeding limit values, etc.

  • Discuss action needs with colleagues and management.

  • Identify risk reduction / emission reduction options and evaluate which one is the most appropriate regarding risk reduction and costs.

  • Implement the measure and monitor success.

  • Start with the next priority substance.

How to define responsibilities

Reducing environmental emissions is a core goal of environmental management systems. Accordingly, if an environmental management system exists, the steps of analysing chemical flows and identifying risk / emission reduction measures should be integrated into the routines and procedures of this system. The environmental manager should either be tasked with the specific assessment of chemicals emissions or at least closely involved in this work.

If no environmental management system and similar procedures exist, the person working on emission reduction should closely cooperate with the technical staff to derive the mass balances (estimates) and discuss emission reduction options.

In any case, there should be a designated person responsible for waste management in the company. This person should be involved in any discussions and analyses of emissions into waste. This may lead to reconsidering established waste classifications, e.g. in the event that the content of certain hazardous chemicals was not previously known. You may consider providing additional information on the composition of wastes to ensure safe waste processing.

More resources

Identification of environmental emissions / challenges

  • Guidance on mass balancing (will be provided later)
  • STAN  (subSTance flow ANalysis)

Free software tool used to model, calculate and visualize material and substance flows in systems such as industrial processes, waste management or environmental systems.

Technical controls

This page provides access to reference documents (especially BREFs) developed by the EU Joint Research Centre’s Bureau for Industrial Transformation, which describe industrial processes, emissions, and best available techniques used to prevent and reduce pollution.