Tuesday 22nd November 2016

Other updates from Standards and Legislation Director, Nov. 2016

ESA BAT on IPPC 1996/61/EC and IED 2010/75/EU

Mark Neal and I have been charged with co-ordinating divisional responses to updating the ESA BAT on Sealing Technology, as well as rewriting the introduction section of the BAT.

So far we have received a brief report from Mechanical Seals saying nothing needs changing, and a proposal from Gaskets division, which needs some modification, to bring it more in line with the FSA/SA gasket handbook rewrite. Elastomeric and Packings divisions are to get on with their sections. I have written a proposal for the introduction section and am in discussion with Mark on the relevance and content.

The governing EU directive is now IED 2010/75/EU and the  key point is that IED 2010/75 combines and merges 7 existing directives. (IPPC (1996/61/EC and 2008/1/EC); Large Combustion Plants (2001/76/EC); Waste Incineration (2000/76/EC); Solvent Emissions (1999/13/EC); and 3 existing TiO2 directives).

The types of installations covered are much the same (Energy Industries; Metal Industries; Mineral Industries; Chemical Industries; Waste Management; and the ubiquitous Others – like intensive livestock farming), and all these documents focus on the process BREFs and general BATs.

The scope of the IED is focused on the environment (emissions to air; emissions to water; emissions to land; prevention and control of accidents; waste prevention and recovery; energy and water use; noise; vibration; heat; and odour). So there is plenty of scope for promoting Sealing Devices Best Available Techniques in all of these areas. The Divisions need to respond!

The MAJOR change is that the IED now includes the issuing of Permits and the Permit conditions which include emission limit values for ALL POULTANTS. IPPCs did not include permit and permit conditions, so IED 2010/75 is MUCH tougher, and I believe gives the ESA a great promotional platform to encourage the use of Best Available Techniques for Sealing Devices. We need to seize this opportunity, and not just accept what is already in place, too much is going to change.

IED industrial emissions Article 13 forum

This effectively is the working group, chaired by DG Environment, which decides, via the expert working group, on the technical issues for all the new BREFs that are to be issued as part of IED BATs.

The current interest is clarification of the scope of BREF’s, especially the recent draft on Large Volume Organic Chemicals (LVOC) and the Large Combustion Plant (LCP), where there are concerns on monitoring issues, and the decision making process. There has been a call for participation in the Waste Gas in Chemical Sector BREF, and ESA has volunteered its services here.

Mark Neal is a member of Article 13 forum on behalf of ESA.

Food contact materials

Mechanical Seal division has concerns about materials in contact with food. In particular Regulation 1935/2004 and Carbon/Graphite faces used in Mechanical Seals. Led by Derek Blumfield of John Crane, and Philip Charlton of Morgan Advanced Materials. The ESA has been trying to arrange a meeting with Jonathan Briggs of DG Sante to raise concerns.

EN 1591/4 and ASME PCC-1/2/3

ESA has been asked by Gaskets Division to engage with the FSA to try to find a route to combine these two standards into one global standard. Henri Azibert has agreed that the FSA will attempt to raise the issue at the next ASME meeting.

Pressure Equipment Directive (PED 2014/68/EU)

Derek Davidson attended an I.Mech.E meeting in London on 14th June, where there was a seminar on the latest PED stakeholder report (March 2015). He published his report with copies of presentations and enough reading material to last a lifetime!

The main point appears that there is a new version of PED Article 13 that has come into force on 1st June. There is a Joint Research Centre effort to review possible amendments to ATEX, PED and Machinery.

Flange gaskets division has asked that ESA attempt to have flanged connections regraded as “critical joints” as was attempted by John Hoyes previously, in the planned 2020 revision of PED.

ESA Code of Conduct

I believe that ESA would benefit from a Members Code of Conduct, which could be used to allow end users gain confidence in using ESA members to purchase their Sealing Devices. This draft is now in circulation with the Executive Committee and will be published on the web site shortly.

David Mitchell, Standard and Legislation Director

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