In the current regulatory restriction process for Cr(VI), absolute emission limit values in kilograms per site per year are under discussion. VECCO is criticizing this approach from day one: if the emissions from all chimneys at a site are added together, larger plants in particular, with multiple galvanic lines and high exhaust air flow rates – are disadvantaged, even where emission concentrations are very low.

In addition, there is a flaw and a conflict of objectives in the draft restriction: high-performance extraction systems reduce workers’ exposure but, due to the greater volume of exhaust air, increase the calculated annual emission load.

This leads to the absurd situation where well-established plating companies that have been complying with national emissions standards for years suddenly face regulatory problems.

The alternative: Maximum Release Factor

With Alternative Option 5 (AO5) of the draft restriction, the RAC and SEAC have therefore introduced the Maximum Release Factor (MRF). This involves setting the annual Cr(VI) emissions in proportion to the amount of Cr(VI) used. The decisive factor is thus the actual efficiency of emission reduction rather than the size of a company.

A look at the Vecco database for our members’ risk data shows a clear picture: around 94 per cent of sites achieve a Maximum Release Factor (MRF) of 0.1 per cent.

VECCO therefore expressly supports a Maximum Release Factor of 0.1 per cent as part of the future Cr(VI) restriction. It combines ambitious emission reduction targets with an approach that remains practicable even for larger industrial sites and helps businesses to remain in the EEA.