ENVIRONMENTAL CODE OF PRACTICE

Air Pollution

Overview

The main provisions for the control of air pollution are set out in:

It is an offence to operate a prescribed process, such as the polymerisation of styrene in certain quantities, without a relevant authorisation or without regard to the conditions attached to that authorisation.

Part I of the Environment Protection Act 1990 introduced prior authorisation powers for local authorities over a list of prescribed processes. Until full implementation of the IPPC Regulations in 2007, prescribed processes are subject to integrated pollution control (IPC). This places a duty on operators to use Best Available Techniques (BAT) to prevent and minimise releases of prescribed substances. Process Guidance Notes explaining BAT for specific industries are available from OPSI.

The Industrial Pollution Control (Northern Ireland) Order 1997 makes provision for a system to control pollution from industrial processes that is broadly similar to that operating in the rest of the UK. This provides the statutory basis for compliance in Northern Ireland with the European Air Pollution and Integrated Pollution Prevention & Control Directives.

Solvents Emissions Directive

This EU Directive (99/13/EC) aims to reduce emissions of volatile organic compounds (VOCs) to the environment from specified industrial processes. It also aims to phase out the use of more harmful solvents such as carcinogens, and those toxic to reproduction to reduce the potential effects on health. It establishes solvent consumption thresholds, above which various controlling measures and procedures must be implemented.

This legislation was passed into UK law in April 2001 and all installations affected must comply by 31 October 2007. The Directive is mainly aimed at the larger users of VOCs, such as the printing, vehicle coating and paint manufacturing industries, but it may have an impact on sectors within the boatbuilding industry as well. ‘Surface cleaning’ – defined as “any activity using organic solvents to remove contamination from the surface of material, including degreasing” is specifically listed as being within its scope.

Currently the most significant consideration in terms of air pollution arising from the marine industries is the use of composite materials that release atmospheric emissions from solvents in which resin is dissolved and from solvents used to clean tools and equipment. Styrene, acetone, methanol and methyl ethyl ketone are commonly used organic solvents that release VOCs into the air.

The SED requires the yard to keep a solvent management plan which is an inventory of all paint and solvent used at the yard in any one year. It also allows the yard to carry out the 'Solvent Reduction Scheme' which is a compliance option available for yards to follow to meet the emission limits set out in the SED.  Click here to download BMF's SED guidance document.

The use of styrene is regulated as a Part B process under the Local Authority Air Pollution Control System and environmental limits apply. Process Guidance Notes on the polymerisation or co-polymerisation of pre-formulated resins or gel coats containing unsaturated hydrocarbons contains guidance on acceptable limits for processes and advice on management. These limits should not be confused with the Health and Safety limits for which maximum exposure limits are defined. Health and Safety considerations however require boat builders to ventilate emissions out of their working area, a process which introduces these emissions to the atmosphere.

Further guidance on styrene can be obtained from the BMF Technical department.

Recreational Craft Directive (RCD)

Since 1998 most new recreational craft and second hand craft brought into Europe have had to comply with a number of essential safety requirements set out in the Recreational Craft Directive (94/25/EC). Most requirements of the RCD relate to safety, construction, stability, on board systems and pollution control, but after January 2005 the Directive will be amended (2003/44/EC) to also regulate exhaust and sound emissions.

The emission limits have led to marine engine manufacturers investing significantly in the development of cleaner and quieter engines to meet the new requirements for emission limits by the agreed deadlines:
• January 2005 for 4-stroke and marine diesel engines (with 12 month transition period)
• January 2006 for 2-stroke engines (with 12 month transition period)

For more detailed information please click here.

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