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Important information for users of paint...
What is the Solvent Emissions Directive (SED)?
This is an initiative by the EC which has been produced with the intention of reducing
the amount of solvents released into the atmosphere. It follows on from previous legislation
known as PG6/23.
What are the main changes?
The onus has been transferred to the user instead of the manufacturer, and it is the user
who must now ‘manage’ their solvent usage and emissions.
What do users need to do?
All users need to know how much solvent they are likely to use in a given 12 month period
which will put them into one of 3 categories:-
- less than 5 tonnes
- 5 - 15 tonnes
- over 15 tonnes
Armed with this information, they must then inform their Local Authority which of 2 methods
they will use to manage and reduce their solvent emissions either by abatement and monitoring
or by way of a Solvent Management Plan (SMP).
Generally, the requirements are more onerous as you move from category 1 to category 3.
Abatement will usually favour those processes that are contained within a specified area such
as a dedicated spraying booth(s) which enable all emissions to be contained and then removed
by way of a ventilation stack. It does not suit open shop applications where the solvent is
removed by a combination of forced ventilation and passive ventilation such as open doors,
windows and general release through the fabric of the building.
From this it can be seen that steel fabricators and general blasting and painting contractors
will go down the SMP route while production line companies may be able to use abatement and
monitoring although they may also have to consider some means of treatment such as
incineration of solvents within this process.
What should be included in the solvent management plan?
Key data will include an inventory of the volumes of each product purchased, together with
product weight and a split down of the weight of paint solids to weight of solvent.
A well presented and thought out plan should help to mitigate any effects that might
otherwise be imposed.
What is the period in which the solvents emissions are measured?
We would suggest that solvent ratios are monitored as an ongoing process over a rolling 12
month period, in order to demonstrate a continued commitment to the process.
This legislation will be targeted at existing facilities, what about new ones?
Essentially, any new or substantially changed process will have to meet the requirements that
came into effect on the 1st of October 2007.
What would happen if I bought the paint and used it on site?
Site painting does not generally come under the scope of SED, therefore ought not need to be
included in the calculation. It is vital that accurate inventories of paint used in this manner
are kept, in order to satisfy the inspector.
What if I purchase the paint and send it to a sub contractor? Whose responsibility would it be?
The paint supplied to a sub-contractor becomes the responsibility of the sub-contractor and
should be included in his SED calculation. Again, accurate record keeping is needed to account
for this paint use.
What about site application?
Site application in a maintenance or building site application does not come under the scope of
SED, as it is a non-permanent painting process.
Are ship building yards included?
Yes
What is the basis used for the definition and calculation of solvents?
Previously solvent levels in paint were expressed as a Volatile Organic Content (VOC) which
was the percentage of solvent in the paint measured on a volume basis. The major difference
now is that the solvent content is measured as a percentage by weight.
Importantly, this is based on actual usage rather than a theoretical data sheet derived figure.
This will be important where low solids/high solvent materials are used such as blast primers,
because over application will have a significant effect on the overall calculation.
What happens to Compliant Coatings?
The SED does not set levels for solvent in specific materials any more, it is purely concerned
with the overall usage figures.
It does still mean that higher solids materials will enable the user to ‘manage’ their solvent
usage though, unless the user only uses a high solvent containing blast primer which will
inevitably mean a shift to a water based product.
How do I know what the solvent by weight figures are for the products I use?
Leighs Paints provide both the old VOC figures and the new Solvent By Weight (SBW)
figures on data sheets.
How are you going to help customers to see the specific gravity (sg) and solvent content of the paint we use?
Solids by weight data is included on technical data sheets, which will enable calculation of
information.
What are Leighs Paints doing to help customers?
We will be able to give you summaries of usage on an agreed frequency basis i.e. monthly,
for your records and to enable you to ‘manage’ the usage of materials either to initially stay
within one of the lower categories and/or to achieve the specified reduction in solvent usage
set out in the legislation.
The product range has also been reviewed. The majority of products that were ‘compliant’ under the existing regulations will not cause any problems under SED. Work is underway on some of the borderline products to make them more SED
favourable. The only real challenges come with solvent based blast primers and low solids quick
drying alkyds. Users who predominantly rely on these products alone will have to consider
their product inventory and switch to higher solid products or waterbased. (Or consider the
abatement route).
We have also taken steps to ensure that specifications are written with the SED in mind,
without compromising performance.
What are the implications of switching to water based products?
Performance-wise, water based paints can be as good as solvent based; however their use is
limited to shop or production line applications where good drying conditions can be guaranteed,
and to relatively low film thickness.
However, water based coatings have been significantly more expensive than an equivalent thickness of a
solvent based product based on similar chemistry. The cost gap will continue to narrow as
economies of scale kick in with increased use of water based technology. Although it may
never be the same cost base as solvent based, more stringent future legislation may make
waterbased the only viable option in certain industry sectors.
Water based materials and contaminations - are there any products on the market
to help the operator with the paint?
Surface cleanliness is crucial with water based paints. Leighs can supply a proprietary
degreasing agent to assist in obtaining a suitable substrate for painting.
Recycling solvents - how does that work and what impact will this have on the solvents for our business?
Solvent can be reclaimed by using an in-house distillation unit, or by sending it away for
distillation and taking back the reclaimed solvent for re-use. Any re-used solvent will not need
to be included in the SED calculation.
How will the new regulations be enforced?
Your LA will be responsible for this which allows an element of ‘post code lottery’ to come into
effect as it did with the monitoring of solvent usage previously.
Can you give me specific advice on my methods and product selection so that I
can manage our obligations contained in the SED?
Yes. Either contact your Area Manager, or Leighs Paints Customer Services at our
Head Office on Tel +44 (0)1204 521771 to arrange an appointment.
Further Information
Defra have complied a general guidance manual for the Environmental Permitting Regulations, which includes the SED regulations.
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