Chlorine Industry Review 2009-2010
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Chlorine Industry Review 2009-2010 The spectre of substitution calls for vigilance TheTackling spectre issues of substitution callsin a fortransparent vigilance manner Chlorine Industry Review 09 2009-2010 Cover: Clean, healthy water has been associated for more than a century with chlorination. However, few people are aware of the fact that chlorine and its co-product caustic soda are building blocks for many high-tech product lines that are – among many other applications – essential for more efficient energy management on Planet Earth. 01 Introduction 04 The spectre of substitution calls for vigilance 02 Sustainability 06 Continuous efforts for improvement 03 Regulatory affairs 16 Balanced legislation for a sustainable future 04 Science 24 Effective advocacy based on sound science 05 Communication & education 32 Relevant, reliable and timely information 06 Industry overview 36 European chlor-alkali industry severely hit 07 Chlorine production plants 42 January 2010 08 Euro Chlor 44 In the centre of chlor-alkali regulatory and HSE issues CONTENTS 3 01Introduction Now this may not immediately ring any alarm bells but it is not an isolated event. Earlier this year a restriction on the use of dichlorometh- ane in paint strippers (except for industrial installations) was passed which signals that the full frontal attack on chlorine which oc- curred in the nineties may have diminished but chlorine containing substances are still the subject of attention today. What we should be most concerned about is the manner in which these decisions are taken. I refer to the extravagant and libertine use of the Precaution- ary Principle where the risk based decision- making process is pushed aside and replaced The spectre of substitution calls by the doom driven imaginations of activists. for vigilance In the event, the Parliamentary Environmental Committee and the plenary vote in Parlia- Has our industry become the object of media ment did not result in a ban but these chlorine attention again? And if it has, in what way, containing substances are put in a ‘candidate what are the implications and should we be list’ for future consideration so the threat has concerned? not gone away. The answer is yes, but not directly and yes, we This may sound very benign but there are im- should be concerned. For some time now the plications here which need to be kept in mind Regulation on Hazardous Substances (RoHS) – and this is what we should be concerned has been under review by the European Parlia- about. It is the spectre of substitution. ment with the environmental lobby calling for a ban on organochlorines, organobromides and Consider this – the Cefic Policy Centre sees PVC for use in electric appliances. substitution being implemented in two dis- tinctly different ways. The first is the obvious one – by legislation. Under REACH, authoriza- tion will be given on condition of a legal obliga- tion to substitute by a given date. The second one which I am addressing in this foreword is market driven substitution. 04 CHLORINE INDUSTRY REVIEW 2009-2010 It is gratifying to report that invest- ment in new membrane plants to replace mercury based ones continues even in the austere economic climate the chlor-alkali Vinnolit industry operates in Market driven substitution can be more dif- track in meeting our voluntary commitment to ficult to tackle because it is never obvious just have converted all mercury based chlor alkali who is driving it in any particular instance. Take capacity by 2020. Considering the slow rate PVC for example, the largest single consumer of recovery in our sector this is a major act of for chlorine, and the recent case of dichlo- faith by our membership! romethane. It is all very well to say it’s the environmentalists who are the activists trying Meanwhile, within the climate change and to have it banned but downstream users and energy arena the ETS debate continues. At the retailers play a role here too. This stakeholder time of writing, a paper from DG Competi- group is driven by a desire to satisfy and tion detailing guidelines enabling the Member attract consumers using a strategy based on States to offer state aid to electro-intensive consumer perceptions of environmental and industries is still awaited. This is many months health risks. The question of how we can influ- overdue and probably reflects a change in ence such perceptions must remain rhetorical thinking from the new Commissioner influ- for the moment. enced no doubt by national governments and other stakeholders. In the aftermath of There is nothing new in this – what is new is Copenhagen where no global agreements were the threat of self-destruction brought about achieved, calls to increase carbon emission through the opportunity to profit from deselec- targets from 20 to 30% have so far been suc- tion through the supply of substitute products cessfully rebutted by manufacturing industry. by manipulating the regulatory process. There Optimism remains high that we will succeed in are increasing instances of companies encour- achieving some measure of state aid compen- aging legislators to resist defense strategies by sation for carbon inflated electricity prices but offering substitutes whose testing provenance the level is very much in question with the real is often not complete. This is bad practice and effect of carbon leakage being challenged. will result in splintering our chemical industry as a whole. We will look foolish, and worse still For the future we will remain vigilant in our efforts to act from a position of unison and identifying the threats for our industry but are the strength which that brings will be seriously optimistic that we can deal with these through compromised. the collective efforts of our membership. On a more positive and less controversial note it is gratifying to report that investment in new membrane plants to replace mercury-based ones continues even in the austere economic climate in which we still operate. Membrane Alistair J. Steel technology now accounts for 50% of our Executive Director installed capacity which means we remain on CH 01 INTRODUCTION 5 02 Sustainability Continuous efforts for improvement ”Perhaps it is rational that progress towards our 2010 sustainability goals has diminished. In some areas achieving further improvement becomes much more difficult as we approach the targets. Still, those companies in the upper quartile of performers have been able to maintain their position. As a professional organisation we must ask ourselves what needs to be done in order to realise the improvement we aim at. If we don’t, we waste an opportunity to create value.” Alistair J. Steel 06 CHLORINE INDUSTRY REVIEW 2009-2010 Bayer CropScience Bayer CropScience Bayer CropScience Unified strategic approach nual publication of the industry’s performance. Many effective and safe crop pro- All of the Western European chlorine manu- In this section, we report on performance tection formulae indicators and progress in 2009. Whilst the rely on chlorinated facturing members of Euro Chlor agreed in substances 2001 on an industry-wide strategy that focused programme continues to be a powerful force on six voluntary commitments. These were for change, not all the indicators show the first developed to ensure a united industry same degree of progress. approach and commitment to address key sustainability concerns: • I nclude environmental, social and economic Economic contribution factors in all strategic business decisions; Energy use • Optimize energy efficiency in chlorine Target: By 2010, reduce industry-wide energy production; consumption by 5% in terms of kWh/tonne • Reduce water usage through recycling; of chlorine produced compared with the 2001 • Continuously reduce polluting emissions base year. to water, air and land; • Use more hydrogen generated by the indus- Update: As for the previous year, there was try as a raw material or fuel; an increase in 2009, but the average energy • Give high priority to safe transportation consumption is still slightly below the target of chlorine. fixed for 2010, with a value of 3,445 kWh/t of chlorine produced. The global trend is related In parallel, data was collected for 2001-02 to the progressive conversion from mercury to and with this information, 14 performance membrane technology, with the last two years indicators and improvement goals were agreed disruptions probably due to production rate among producers and announced by Euro fluctuations caused by the economic crisis. Chlor in January 2003. Then the following year, a 15th indicator was added that required mem- Background: Since electricity is an indispens- bers to gain EMAS and/or ISO 14001 Environ- able raw material of the chlorine production mental Accreditation for their plants. process, the basic consumption – correspond- ing to the electrochemical reaction – cannot be These indicators come under the following significantly reduced. However, converting one main areas: economic aspects of produc- technology into a more efficient one may save tion, environmental protection, safety and a certain amount of energy and, to a lesser social progress and for some of them targets degree, reduce ancillary energy use. The energy were fixed for 2010. Each year, producers are indicator is weight-averaged across all produ- required to report their progress to Euro Chlor, cers and based on steam and electricity. Energy which combines feedback to report to the asso- is mainly used for electrolysis (transformers, ciation’s Management Committee prior to an- rectifiers and cells) and also for illumination CH 02 SUSTAINABILITY 7 Energy consumption Hydrogen used 3700 kWh/tonne of chlorine 100 % 3650 95 3600 Goal: 5% reduction by 2010 Goal: 95% use of hydrogen by 2010 3550 90 3500 3450 85 3400 80 3350 3300 75 3250 3200 70 2010200920082007200620052004200320022001 2010200920082007200620052004200320022001 Energy consumption and motor power (pumps, compressors, cen- 2010, continuing the progressive phase out of this Real trifuges, etc.).