Standards—a note by M B Recycling
Ltd 11 September 2001
At the recent round table meeting held at the
Conference Centre at the DTI on 21 August 2001 to discuss the
implications of the New Regulation 2037/2000 with regard to the
disposal of domestic refrigeration waste after 31 December 2001,
it was confirmed that in order to comply with Section 16/2 a new
method of disposing of this waste stream will have to be developed,
after it was recognised by DEFRA, the DTI and the EA that this
country had at the present time no technologies established for
the removal of all ozone depleting substances from either the
refrigerants or the foam blowing agents trapped within the insulation
of domestic refrigeration waste.
Being aware that new technologies would need
to be developed, much consideration was given to the standards
which would need to be set to achieve Best Practice before industry
would have sufficient information to be able to make decisions
on which technology to deploy.
The discussions then gave rise to a representation
from the RAL Quality Assurance Body (a German organisation that
had set a minimum standard for recovery of ODS, in the absence
of legislative standards within Germany). Close examination shows
that the RAL Standard set a very low minimum recovery rate of
283 grams of ODS per unit, and by RAL's own concession, as given
to the Stena Gorhard Workshop on CFC Recovery from Refrigerators
held in Oslo on 23-24 September 1999, they themselves admitted
it was artificially compiled. Nonetheless, examination shows that
there are a variety of standards, all measuring different aspects,
which are mentioned in regard to ODS. In reality there are a wide
variety of standards of which RAL and TA Luft are but two. Collectively
these chart a pattern of measurement and behaviour which is always
dominated by the two words "where practicable" in compliance
with the Environmental Protection Act.
If this was compared with the UK's interpretation
of "where practicable" under the Environmental Protection
Act which stated it was not practicable to reclaim any ODS blowing
agents, the RAL standards or any of the other standards were much
better than the UK position of a 0 per cent of reclamation.
The new Regulation 2037/2000, Section 16(2)
did not include this "where practicable" clause and
has made mandatory the requirement to reclaim ODS trapped within
the foam insulation as from 31 December 2001. As such, neither
the RAL Standard nor any of the other simple standards any longer
carry any bearing to the requirements of the Regulation.
The alternatives, one strongly advanced by Mr
Gary Taylor of Clwyd Refrigeration and another advanced by Mr
Peter Jones of Biffa, relate to details of the overall problem
and all of them carry great input, but at the end we have to recognise
that the full standard which it covers will have to measure the
losses and reclamation of all ODS substances from the moment the
refrigerator enters the gate to the time when it is fully destroyed
and therefore the measurements must cover wastage to atmosphere,
the amount residual in the foam, the amount that is in the processing
unit itself and the amount that is vented to atmosphere in other
ways. Additionally, the measurement must also measure any quantity
of risk involved in the operation through the process.
With this in mind, the benchmark would very
much resemble that contained in the German document E DIN 8975-12
. . . 2000/11. This document, which I am sure had been read by
many of the attendees at the meeting contains the draft proposed
by the Germans. The categorisations in it are all capable of being
met and it would seem probable that the Germans have given very
mature thought in arriving at these standards. It may well be
that within the framework of the DIN it is possible to improve,
for example on the amount of residual ODS left in the foam or
in the means by which measurements are taken with regard to discharge
to atmosphere via the chimneys, but these are details against
a mature backdrop prepared by people who have had considerable
experience in operating the standards that have been laid before
us, such as TA Luft Regulations and RAL Standards . It is perhaps
a pointer to the future that in preparing the DIN document which
is by far the highest standard, they have effectively moved away
from the piecemeal approach to a fully integrated approach and
it would appear realistic that we should also pursue the same
realistic approach. There is surely no loss of face in adopting
a standard prepared by people with far more practical experience
of the use and destruction of ODS than ourselves.
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