Correspondence from the Department of
the Environment, Transport and the Regions to the European Commission
11 September 2000
NEW EC REGULATIONS:
ARTICLE 16—RECOVERY
OF ODS FROM
FOAMS
You may recall that, following discussion in
Geneva with other Member States on the clarification of Articles
16.1 and 16.2 as they apply to foams, I wrote to Paul Ashford
co-chair of the Foams Technical Options Committee seeking advice
on whether it would be technically possible to meet these requirements
in respect of foams.
Please see annexed a copy of reply, stating
that it would not be possible to remove ODS from foam either during
maintenance or before dismantling of the equipment. Although it
would be possible to recover the ODS before disposal of the equipment,
it is not currently practicable to achieve this because of the
status of the relevant technology, and probably a greater proportion
of the blowing agent would be lost to atmosphere on removal of
the foam.
I would therefore still support the views expressed
by France and most other Member States, except Denmark, that all
foams should fall under Article 16.3.
I hope that this provides some help to enable
the position of foams to be clarified.
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