Absolute kilogram values per year: A flaw by design

Why the Maximum Release Factor (MRF) may be a sound approach in the context of the upcoming restriction of Cr(VI)

In the current restruction of Cr(VI), the proposed absolute emission limit values in kilograms per site and per year play a key role. VECCO and other trade associations have criticized this approach since the start of the procedure.

The reason: unlike, for example, the German TA-Luft, the concentration at a single emission source is not considered in isolation. Instead, the annual emissions from all sources at a site are added together. This puts particular pressure on larger companies with multiple galvanic lines and high exhaust air flow rates – even if their emission concentrations at single chimneys is very low and national requirements are met since years.

The conflict of objectives: occupational health and safety versus emissions at the chimney

A particular problem is an existing conflict of objectives in ECHA’s draft restriction: an efficient extraction system improves air quality in the workplace and reduces workers’ exposure. At the same time, a high exhaust air flow rate, even with the same low Cr(VI) concentration, can mathematically result in a higher annual emission load.

In our view, companies must not be penalized for using efficient extraction systems to protect their workers. Success and growth must not be punished in the EEA.

With Alternative Option 5 (AO5), the RAC and SEAC committees therefore proposed a different approach in the restriction procedure: the Maximum Release Factor (MRF).

Under this approach, a site’s annual Cr(VI) emissions are set in relation to the quantity of Cr(VI) used. The decisive factor is therefore no longer solely the absolute size of a site, but how efficiently its emission reduction measures actually work.

VECCO considers this approach to be fundamentally more appropriate than an absolute kilogram value per site per year. However, an MRF must also be technically achievable, verifiable by measurement and socio-economically proportionate.

What does our database show ?

In terms of emissions, the annual Cr(VI) load for VECCO sites averages 0.22 kg Cr(VI) per year and stands at 2.62 kg Cr(VI) per year at the 90th percentile. According to this, only 38.5 per cent of the sites considered meet the R02 scenario; only around 13.4 per cent achieve an even stricter R03 value.

At the same time, the VECCO database paints a different picture when it comes to the maximum release factor: the average release factor for our companies is 0.001 per cent. Over 90 per cent of VECCO sites meet the new target of 0.1 per cent.

When applied to the scenarios in the draft restriction on Cr(VI), the following picture emerges: