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Environmental legislation

Air emissions

• Introduction
• Local Air Pollution Prevention and Control
• Environmental Protection Act
• Clean Air Act 1993
• Climate Change Levy

Environmental Management Systems

Local Air Pollution Prevention and Control

The most significant air pollution controls for the furniture industry are those which were initially imposed at the start of the 1990's by the Environmental Protection Act 1990 (EPA). Part I of the EPA made it an offence to operate a prescribed process or use a prescribed substance without an authorisation. The EPA has since been superseded by the Pollution Prevention and Control Act 1999 and its associated regulations, though this change has had little practical impact on the sector.

Companies operating prescribed processes, above specified thresholds, must hold a permit under the Local Air Pollution Prevention and Control regime (LAPPC). Processes of particular relevance to furniture manufacturers are:

• PG1/12(04): Combustion of fuel manufactured from or comprised of solid waste in appliances between 0.4 and 3MW
• PG6/2(04): Manufacture of timber and wood based products
• PG6/33(04): Wood coating processes

Each prescribed process has a process guidance note (PG) which is updated on a periodic basis, with 2004 being the latest revision hence the (04) notation. The guidance notes are available from www.defra.gov.uk/environment/airquality/lapc/pgnotes

The process guidance notes contain useful background information as well as the details of the Best Available Techniques (BAT) for the control of pollutants from the process. Companies which hold a permit are expected to apply BAT, which is effectively a balance between state-of-the-art technology and management techniques and what an industrial sector can generally afford.

Typical controls specified in the process guidance notes include emissions limits, monitoring, maintenance and recording. These will be incorporated into a site specific permit, unless the local regulator can be persuaded to use their discretionary powers to waive some of the requirements.

The aim of the notes is to provide a consistent level of control to specific processes across the UK , whilst allowing a degree of flexibility to local regulators with regards to the interpretation of requirements at individual sites. Requirements may vary depending upon the presence of sensitive residential areas close-by, the cost and benefit of conducting upgrades and the general degree of diligence shown previously by the company. However, the guidance notes constitute BAT in the eyes of the DEFRA (Department for Environment, Food and Rural Affairs) and local regulators must have good reasons to deviate from them. The APC system is regulated by the local authorities (in England and Wales ) and by the Scottish Environmental Protection Agency (SEPA) north of the border.

PG1/12(04) Combustion of fuel manufactured from or comprised of solid waste in appliances between 0.4 and 3MW

The wood combustion guidance note was republished in September 2004, following a lengthy revision process which resulted in very little practical change. The note sets emission limits for wood burning boilers between 0.4 and 3 MW which is roughly equivalent to a feed rate of 90 to 675 kg/hour:

The limits for formaldehyde, hydrogen chloride and hydrogen cyanide are only relevant to sites burning board material, e.g.:

• Formaldehyde from chipboard, plywood, fibreboard and similar material
• Hydrogen chloride where painted or PVC coated wood is burned
• Hydrogen cyanide from melamine faced wood

Raw timber (e.g. uncoated, untreated hardwood and softwood):

• Particulate matter: continuous quantitative monitoring with a visible and audible alarm
• Carbon monoxide and organic compounds: annual test

Other wood based products (e.g. MDF, MFC and chipboard)

• Particulate matter: continuous quantitative monitoring with a visible and audible alarm
• Carbon monoxide: continuous quantitative monitoring with a visible and audible alarm. Results may be discarded when taken within 30 minutes of start-up or during periods of idling
• Oxygen or carbon dioxide: continuous indicative monitoring
• Annual testing for particulate matter, carbon monoxide, organic compounds and where appropriate for formaldehyde, hydrogen chloride and hydrogen cyanide
• Daily visual and olfactory assessments

Monitoring imposes a significant cost on wood combustion plant. Continuous monitoring equipment will generally cost £20,000 to £30,000. Furthermore, the equipment tends to be unreliable especially with regard to carbon monoxide. Re-calibration after repair will typically cost between £500 and £1,000. Annual testing incurs another £1,000 to £2,000 p.a.

EU Waste Incineration Directive
EU Waste Incineration Directive (2000/76/EC) requirements have been integrated into PG1/12(04). The Directive excludes “wood waste” except that containing “halogenated organic compounds or heavy metals as a result of treatment with wood preservatives or coating”. Current understanding suggests that this excludes all wood and timber based products e.g. except where they contain halogenated organic compounds - basically substances which contain chlorine, bromine or fluorine, e.g. polyvinyl chloride (PVC) - or they contain heavy metals.

Therefore, the Directive will not apply to the majority of furniture manufacturers. Plant falling within the scope of the Directive would effectively have to close down as the emission limits could not be met by plant which has not been specifically designed for this purpose.

PG6/2(04) Manufacture of timber and wood based products

Sites likely to use more than 1,000m³ of timber in any 12 month period are required to hold a local authority authorisation for processes involving the manufacture of timber and wood based products as defined in PG6/2. The threshold figure increases to 10,000m³ if the wood is sawn only, i.e. not sanded or drilled etc. Sites unsure of the need for authorisation should take particular note of the italicised words.

The main aim of this legislation is to ensure the correct extraction and collection of wood dust to prevent environmental harm and the creation of neighbourhood nuisance. As with much environmental legislation, there are close links with health and safety requirements, with wood dust controls also serving to protect human health and minimise fire hazards.

The main requirement of the note is the switch from cyclones to bag filters for furniture manufacturers, though this may not be necessary for timber companies generating larger chips of material with moisture content above 20%. Operations requirements also apply such as:

• Requirement to conduct and record 3 visual observations each day to ensure that there are no emissions of particulates
• Staff training must be undertaken for those with responsibility for the extraction system
• A written maintenance programme must be provided to the regulator with respect to pollution control equipment.

PG6/33(04) Wood coating processes

This process guidance note applies to sites likely to use more than 5 tonnes of organic solvent in any 12 month period in their coating process. The wood coating sector emits around 10,500 tonnes p.a. which is around half of one percent of the UK total (BFM, 2001).

There are a variety of options that can be used by sites above the threshold limit to ensure compliance with the requirements of the guidance note. There are two bands of solvent users: 5-15 tonnes and 15 tonnes upwards. The former have an extended deadline for compliance with their final compliance option (2007) whilst the latter had a compliance deadline of April 1999.

N.B. When talking of such dates it should be remembered that the extension applies only to small users in respect of their final compliance routes (i.e. mass balance, compliant coatings or emission limits). All other aspects of the note should have been complied with by all sites by 1 st April 1999 .

The compliance options available are:

• Compliant coatings: where all coatings have less than a specified level of solvent. This level has been increased from 435 g/l to 475 g/l in the 2004 note. This options ceases to be available to larger solvent users (>15 tonnes) from October 2005.
  
• Emission limits: typically involving abatement technology to reduce VOC emission levels below 50 mg/m 3 (where solvent use is above 15 tonnes) or to below 150 mg/m³ (where solvent use is between 5 and 15 tonnes). It is thought that some small sites might be able to achieve 150 mg/m³ without abatement, but they would still need to install expensive monitoring equipment
  
• Mass balance approach: compliance is achieved by reaching a “target emission” which is related to the solids content of coatings to allow flexibility in accordance with varying levels of production. The target is calculated as follows:
  
  • 5 to 15 tonne users can apply up to 1.6 times as much solvent as solids, i.e. 1.6:1 (and they have until 2007 to do so)
  • 15 tonne and upwards users can apply the same amount of solvent as solids, i.e. 1:1 (and they had until 1999 to do so)

Companies are required to draw up a solvent inventory which is submitted annually to the local authority. This should include a calculation of solvent usage during the year (opening stock + purchases - closing stock) from which should be subtracted the discountable solvent (solvent sent for re-use and recovery).

The starting point for any such upgrade should be the reduction of unnecessary VOC usage:

• Use of a solvent management system to understand exactly what solvent is consumed in each process and the levels of variation that occurs
  
• Elimination of non essential solvent use, e.g. the use of unnecessary thinners for thinning
  
• Better house-keeping such as ensuring lids are placed on all tins
  
• Staff training and education - how will lower solvent usage benefit the individual and how can it be achieved
  
• Careful collection and storage of special waste (waste solvent & thinners) which is then sent for reuse - and hence can be claimed as “discountable solvent”.
  
• Efficient spray technology with an efficiency of at least 65% is used - and all sites must have this in place by April 1999.

Once steps such as those outlined above have been taken, it will be a case of working with your coating suppliers to develop the best solution. Unfortunately, the large number of timber / process / finish variables mean that there are no generic solutions.

Further information is provided in a variety of benchmarking and best practice guides produced by BFM Ltd and Envirowise, as outlined in the final section on further reading.

EU Solvent Emission Directive
The 2004 revision of PG6/33 incorporates the requirements of the EU Solvent Emissions Directive. The latter only applies to sites using >15 tonnes of solvent p.a. As a result, PG6/33 differentiates between 5-15 tonnes users (to which the directive does not apply) and >15 tonnes users to which it does.