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R&D
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Sourcing
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Production
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Packaging
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Transport
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Storage
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Marketing
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Farming
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Re-cycle
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PRODUCT MANUFACTURE |
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EFMA PRODUCT STEWARDSHIP FOR FERTILIZERS
Version 1.5: 01-08-2009
INTRODUCTION |
Product manufacturing is often well regulated by law and is already subject to regular checks (audits). Hazard analyses have been carried out and many procedures are in place. These hazard analyses should contain assessment of impacts on manufacturing from all product components and chemicals used. Impact assessment, evaluation and documentation should be done regarding Process Safety, Occupational Health and Safety and the Environment. Procedures should be in place to control significant SHE aspects during manufacturing.
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LEGAL REQUIREMENTS |
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IPPC Directive 2003/87/EC Establishing a scheme for Green House Gas allowance trading within the Community and amending Council Directive 96/61/EC. OJ 25-10-2003. L275/32 Best Available Techniques Reference Document Ammonia, Acids and Fertilizers. EU Best Avaialable Technique Reference Document Ammonia, Acids and Fertilizers Final August,2007 Emission values in ambient air GHG Emission and Emission trading Commission Decission 2004/156/EC. Directive 2003/87/EC Establishing a scheme for Green House Gas allowance trading within the Community and amending Council Directive 96/61/EC. OJ 25-10-2003. L275/32 Decision 280/2004/EC of the European Parliament and of the Council of 11 February, 2004 concerning a mechanism for monitoring Community greenhouse gas emissions and for implementing the Kyoto Protocol. OJ L 49 of 19.2.2004 p1, lays down the procedures for monitoring. COMAH Directive
Workplace Safety (Occupational Exposure Limits Levels) COMMISSION DIRECTIVE 2006/15/EC of 7 February 2006 establishing a second list of indicative occupational exposure limit values in implementation of
Companies should have a procedure in place to comply with these directives. The Directive covering the safe work with machinery in the Member States was established in 1989: Council Directive 89/392/EEC1 of 14 June 1989 on the approximation of the laws of the Member States relating to machinery, more generally known as The Machinery Directive 98/37/EC provides the regulatory basis for the harmonisation of the essential health and safety requirements for machinery at European Union level. Essentially performing a dual function, the Directive not only promotes the free movement of machinery within the Single Market, but also guarantees a high level of protection to EU workers and citizens. Being a "New Approach" Directive, it promotes harmonisation through a combination of mandatory health and safety requirements and voluntary harmonised standards. Such directives apply only to products which are intended to be placed (or put into service) on the EU market for the first time. 1) Guide to the Directive 98/37/EC 2) Useful facts re. Directive 98/37/EC It has been amended several times eversince: Directive 98/79/EC [1998-12-07 OJ No L 331/1] , Directive 89/392/EEC [1989-06-29 OJ No L 183/9] , Directive 91/368/EEC [1991-07-22 OJ No L 198/16] , Directive 93/44/EEC [1993-07-19 OJ No L 175/12] , Directive 93/68/EEC [1993-08-30 OJ No L 220] , Commission proposal for a Directive of the European Parliament and of the Council on machinery and amending Directive 95/16/EC, Fore a full overview of machinery related directives see Table listing the publications of the references of harmonised standards under the "New Approach" in the Official Journal of the European Union from 1998-01-01 to 2003-12-31 On 15 December 2005, an agreement has been reached in the European Parliament to streamline the Machinery Directive.
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EFMA REQUIREMENTS |
EFMA IMPLEMENTATION |
3.1.3.1. ESTABLISH PRODUCT SPECIFICATION, RAW MATERIALS SPECIFICATION AND SPECIFICATION FOR ADDITIVES
In order to secure a problem free and safe processing and handling of materials used (raw materials, additives, coatings, chemicals, catalysts, etc), their specifications must be established based on:
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3.1.3.2. ESTABLISH BEST PRACTICE PRODUCTION STANDARDS (BAT)
IPPC The EU has a set of common rules on permitting for industrial installations. These rules are set out in the so-called IPPC Directive of 1996. IPPC stands for Integrated Pollution Prevention and Control. In essence, the IPPC Directive is about minimizing pollution from various point sources throughout the European Union. All installations covered by Annex I of the Directive are required to obtain an authorization (permit) from the authorities in the EU countries. Unless they have a permit, they are not allowed to operate. The permits must be based on the concept of Best Available Techniques (or BAT), which is defined in Article 2 of the Directive. In many cases BAT means quite radical environmental improvements and sometimes it will be very costly for companies to adapt their plants to BAT. To impose new and considerably tougher BAT rules on all existing installations in the European Union could jeopardize many European jobs, and therefore the Directive grants these installations an eleven year long transition period (October 2007) counting from the day that the Directive entered into force. Council Directive 96/61/EC of 24 September 9 concerning integrated pollution prevention and control Official Journal of the European Communities L 257, 10.10.96 pages 26-40 as amended by EC Directive 2003/35EC, EC Directive 2003/87/EC and Regulation EC 1882/2003 and Commission Decision 2006/194/EC (see also CONSLEG 96/61 for conherence between these legislations). Council Directive 96/61/EC has been repealed by Directive 2008/1/EC of the European Parliament and of the Council of 15 January 2008 concerning integrated pollution prevention and control. OJ L24/8 of 29.1.2008. This new Directive differs in the following points: 1) Makes reference to Directive 2003/87/EC from installations specifeid in annex 1 of named Directive establishing a scheme for Green House Gas emission allowances trading. 2) Has in addition much more emphases on the public participation(annex V) in decission making: such as in the case of issuing a permit for new installations,substantial changes or update of permits. |
ENVIRONMENTAL LIABILITY All IPPC installations as refered to in the annexes of the IPPC Directive (this includes farming as an activity see 3.1.8.)are subject to the Directive 2004/35EC of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage. OJ L 143/56 of 30-04-2004 . This Directive regulates, based on the polluter pays principle, prevention of pollution of the environment and remediation of environmental damage in case pollution has happened. Directive 2004/35/EC has been amended by Directive 2006/21/EC on the topic of the management of waste from the extractive industries (see chapter 3.1.9.2.) |
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All installations covered by Annex I of the IPPC Directive are required to obtain an authorization (permit) from the authorities in the EU countries. Unless they have a permit, they are not allowed to operate. The permits must be based on the concept of Best Available Techniques (or BAT), which is defined in Article 2 of the IPPC Directive. In addition ESA has prepared an addition on the EFMA/ESA jointly produced BAT booklet: Production of Sulphuric Acid. In addition to processes explained in the BAT Booklet nr. 3 it also includes information on the spent acid regeneration. The task to prepare BAT Reference (BATREF) Documents for the Industry was given to the European IPPC Bureau in Seville. Before October 2007, when the IPPC comes fully into force, 35 BATREF will be available. These documents will be up-dated regularly. The two most relevant BATREF Documents for the Fertilizer Industry are the BATREF AAF and the BATREF on storage. In 1999 the European IPPC Bureau in Seville started to draft the EU BAT Reference document Ammonia, Acids and Fertilizers (BATREF AAF). A first draft was issued in May, 2003 and the second draft became available in May, 2004. In August the final draft BATREF AAF was issued.
2) EU Best Avaialable Technique Reference Document Ammonia, Acids and Fertilizers Final August,2007.
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EFMA's EMISSION SURVEY Ever since 1996, EFMA yearly benchmarks the environmental performance of the EFMA members. Data on the emission into air and into water, for a great number of components, are gathered (e.g. NOX, NH3, CO2, dust) and graphically displayed. It enables EFMA to see whether our performances as an industry proceed in a proper direction. In addition it enables our individual members to benchmark themselves against what EFMA considers as Best Available Technique Levels and to see where they stand as regard to the other members of EFMA |
EPER EPER (European Pollutant Emission Register) is the European emission reporting system as established by the IPPC (Integrated Pollution Prevention and Control) Directive 96/61/EC. The first year of reporting is 2003 on releases of 2001. Information is made public, as provided by the Directive, on a web site which has been launched on 23 February 2004. The next is due in 2006 based on reporting year 2004. http://www.eper.cec.eu.int/eper/ EPER can be considered as the first step towards the application of the European Pollutant Release and Transfer Register (PRTR), which is a protocol signed in May 2003 under the Aarhus Convention. |
PRTR
To learn more about PRTR's, visit one of the following sites: The UNEP website has an extensive listing of PRTR documents from international organizations, national governments, and non-government organizations. Many can be also be downloaded. There is also a listing of PRTR contacts in various international organizations and governmental ministries. An example of a national environmental ministry's work on PRTR's can be seen through Mexico's Instituto Nacional de Ecologia's (INE) website - http://www. ine.gob.mx/dggia/net The EU commisison has issued a draft Proposal for a Regulation concerning the establishment of a European Pollutant Release and Transfer Register (E-PRTR)for further discussion . Following this proposal, the European Commission has issued a regulation concerning the establishment of a European Pollutant Release and Transfer Register amending Council Directives 91/689/EC and 96/61/EC. The purpose of the regulation is transparency to the public, greater awareness of environmental matters, a free exchange of views, and more effective participation by the public in environmental decision-making and, eventually, to a better environment. The operators of facilities (as specified in the annex 1 of the regulation) have to report their yearly emissions of a number of pollutants (as specified in annex 2 of the regulation) to their National Authorities if the emissions exceed a specified level. Member states in their turn have to report to the Commission. The regulation comes into force 12 days after publication (04-02-2006) in the Official Journal. The results of the reporting can be viewed by the public on the Commissions¡¯ EPER website http://www.eper.cec.eu.int/ The fertilizer Industry is subject to this regulation as specified under point 4 of annex 1: activity ¡°chemical industry¡± and more precisely under 4c: ¡°Chemical installations for the production on an industrial scale of phosphorous-, nitrogen- or potassium-based fertilizers (simple or compound fertilisers)¡±. The relevant emissions are NOx, CO, CO2, N2O, NH3, sulphur oxides, total nitrogen, total phosphorus, PM 10,heavy metals into water, and air and to land. In addition this Directive covers wastes, The Commission shall draw up a guidance document supporting the implementation of the European PRTR as soon as possible but no later than four months before the beginning of the first reporting year (2007).
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ENERGY EFFICIENCY By nature most off the chemical processes consume energy. Especially in the production of ammonia as starting material for many nitrogen containing fertilizers substantial amounts of energy are consumed. From both an environmental- as well as a cost point of view, energy efficiency of production processes is of utmost importance. Over the last decades the European Fertilizer producers have achieved remarkable reductions in energy and the European fertilizers producers nowadays belong to most energy efficient producers in the world. This became clear from the outcome of the regular benchmarks EFMA members perform. Further information on this issue can be found in the paper "Energy consumption and Green House Gas Emissions" by Gunnar Kongshaug. as slightly adapted by T. Jenssen and presented at the IFS on 03-04-2003. As the largest single sectoral user of natural gas in the EU's manufacturing sector, the European fertilizer industry applauds the EU institutions' renewed commitment to establish a truly world competitive EU single gas market. To achieve this EFMA feels strong actions are required. Amongst these actions EFMA encourages voluntary energy efficiency schemes such as mentioned above. More can be found in EFMA's publication: The European Fertilizer Industry's Vision of a World Competitive European Gas Market.
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- GREENHOUSE GASES Abatement of the emissions into air and into water is also an important issue regarding the reduction of acidification, ozone depletion and eutrophication. The so called Green House Gases related to Fertilizer production and use are Carbon Dioxide (CO2; from ammonia production), Nitrous oxide (N2O; from nitric acid production and fertilizer use) and methane (CH4; from anaerobic digestion). By using Best Available Techniques (see chapter 3.1.3.2.) and Best Practice Agriculture (see chapter 3.1.8.) losses into the environment have been reduced substantially. EFMA's position paper on Green House Gases mentions: "It should be recognized that fertilizers are necessary for the growth of plants, by which solar energy is converted into biomass through the photosynthesis. The additional solar energy captured when using fertilizers, is more than 6 times greater than the energy used to produce and apply the same fertilizers. Furthermore, plants capture atmospheric CO2 as a carbon source for the synthesis of plant tissues. When using fertilizers for plant growth, the additional volume of CO2 captured is more than 5 times greater than that emitted in the production and use of the fertilizers. For these reasons, the fertilizer industry should be viewed as a contributor to GHG reductions rather than a source for GHG emissions". For further information see: EFMA's position paper on Green House Gases EFMA's position paper on N2O gases has been established in early 2005. EFMA is in favour of having N2O included in the ET trading system of the EU in the second round (2008-2112), this to start with the implementation of abatement technology which becomes available and by this reduce the N2O emissions to the environment and the get back some of the investment in abatement technologies. Discussions on the setting of a baseline for emission trading are ongoing. Energy Recovery by Crops in Dependence on the Input of Mineral Fertilizers, 1999. Harvesting Energy with Fertilizers, 2003
-EMISSION TRADING As a tool to reduce the global emissions of Green House Gases, such as CO2, N2O and Methane, the Kyoto Protocol was signed in 1997 by over 130 countries in the world. By signing this protocol the authorities in those countries committed themselves to reduce the emissions by an agreed percentage. Several tools to achieve such a reduction, such as voluntary agreements, tax, emission trading etc. where proposed on EU level. The EU Commission, as a result of many discussions, has proposed emission trading as the way forward and has issued in 2003 the Directive 2003/87/EC establishing a scheme for Green House Gas allowance trading within the Community as an amendment to the IPPC Directive. A guidance for monitoring and reporting of Green House Gas emissions can be found in Commission Decission 2004/156/EC. Directive 2003/87/EC Establishing a scheme for Green House Gas allowance trading within the Community and amending Council Directive 96/61/EC. OJ 25-10-2003. L275/32 The Member States are obliged to forward monitored greenhouse gas emissions to the Commission annually to enable the assessment of actual progress towards meeting the Community's and its Member States' commitments relating to the limitation or reduction of all greenhouse gas emissions under the United Nations Framework Convention on Climate Change (UNFCCC) and the Kyoto Protocol. Decision 280/2004/EC of the European Parliament and of the Council of 11 February, 2004 concerning a mechanism for monitoring Community greenhouse gas emissions and for implementing the Kyoto Protocol. OJ L 49 of 19.2.2004 p1, lays down the procedures for monitoring. This Directive gives guidelines to the MS for a biannual reporting of emissions in different sectors using approved methodology or by calculation using emission factors (CORINAIR), Remarkable is that for reporting some anthropogenic emissions (Agriculture) such as NH4 from manure and N2O from fertilizer use are mandatory included. Reference is made to the revised 1996 IPPC guidelines for national greenhouse gas inventories. Commission Decision of 4 May 2005 establishing a questionnaire for reporting on the application of Directive 2003/87/EC of the European Parliament and of the Council establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Direcitve 96/61/EC OJ L126 19-05-2005 p43 Reporting Directive for Member States. An overview of the decisions adopted by the Commission related to national allocation plans notified by Member States to the Commission for the trading period 2005-2007 can be found in Decisions adopted by the Commission pursuant to Article 9 of Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme fro greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC. The authentic text (s) of these decisions can be found at the following website: http://www.europa.eu.int/comm/environment/climat/emission_plans.htm A Commission decision regarding double counting of GHG emission reductions can be found in: A Commission decision regarding a scheme for greenhouse gas emission allowance trading within the Community can be found in: The Commission is preparing its position regarding GHG in the period 2012-2020. The greenhouse gas emission allowance trading system will be extended to cover all GHG and in addition it will cover ammonia, nitric acid and fertilizer plants. The industry is forwarding detailed information on the energy intensivity and trade exposure of our industry with the purpose to get some free allowances based on benchmarking. For detailed information on the Commission proposal see:
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WORKPLACE SAFETY (OCCUPATIONAL HEALTH) Part of Best Practice Production Standards include safety at the workplace. Employees should have proper knowledge on and training with the chemicals where they daily work with. Safety information such as SDS's should be supplied (see chapter 3.1.5.2). Employers have the legal obligation to protect the employees on the workplace from over exposure to certain compounds, noise, vibration, radioactivity and electromagnetic fields (see Directives on Workplace Safety) Employees should be protected by approved adequate personal protective equipment (PPE) as regluated by Directive 89/686/EC as ameneded by Directives 93/68/EEC, 93/95/EEC, 96/58/EC and by the several Communications on this subject by the Commisison the latest being 2004/C 204 0f 12/08/2004.(see Directives in relation to Personal Proctective Equipment.) |
3.1.3.3.ESTABLISH BEST PRACTICE SAFETY MANAGEMENT
| -Safety principles EFMA members adhere to the 11 basic safety principles for production (EFMA/IFA, 2002). ) A procedure should be in place covering EFMA's safety management principles. |
-Safety performance The Lost Time Injury Rate (LTIR) is a good indicator for safety performance in a company. Since 1996 EFMA yearly gathers the LTIR¡¯s of member companies with the purpose to benchmark EFMA against the European Chemical Industry (CEFIC). The results show a decreasing trend over the years. For the individual EFMA companies it is a good tool to compare their performance with other EFMA members and to strive for even better results in the coming years. |
-Accident analyses Nobody wants to have accidents. It distresses and it causes unnecessary costs. However, although companies do their utmost best to prevent accidents to happen, unfortunately they occur. EFMA a keeps record of all relevant accidents that have happened in our Industry and in the rest of the world in the EFMA accident database. Experts of EFMA analyze these accidents in regular meetings, this for reasons of ¡°lessons to be learnt¡± and for preventing that these accidents happen again. Selected safety themes are part of the yearly EFMA Safety Seminar where EFMA members have the chance to exchange views and to learn from each other. |
EFMA's Safety seminar Almost every year EFMA organises a Safety Seminar. This to exchange views and to learn from each other. EFMA member companies send their experts to this seminars:
Valuable information from the presentations and discussions are made availble on CD ROM to EFMA members. They sometimes form the bases for new guidelines. In October,2008 EFMA will organise a Safety Seminar with the theme "Fire Hazards and behaviour based aspects of safety" |
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3.1.3.4. REVIEW
CHANGES TO MANUFACTURING PROCESSES FOR IMPACT ON PRODUCT RISK (MANAGEMENT
OF CHANGE)
| A vital safety precaution for all industries, and one of EFMA's 11 principles for safety management, is the control of changes in process design, equipment and operations. This includes the proper review of SHE implications and of operability conditions in general, of changes in raw materials compositions, new additives and coating material, for new chemicals and catalysts used for the manufacturing processes, etc. Normally, a Hazard and Operability (HAZOP) study will be carried out before approving changes, with the addition of quantitative risk assessments and/or reliability studies for issues considered to be of high risk. Reference is made to available textbooks on the carrying out of such studies. |
3.1.3.5. ASSESS RISKS AND ESTABLISH EMERGENCY PLANS
The Control of Major Accident Hazard Regulations 1999 (COMAH) implement EC Directive 96/82/EC (known as the Seveso II Directive). COMAH replaced the Control of Industrial Major Accident Hazards Regulations 1984 COMAH) which implemented the original Seveso Directive (82/501/EEC). (82/501/EEC has been amended several times: 87/216/EEC, 88/610/EEC and 91/692/EEC). COMAH came into force on 1st April 1999 and its aim is to prevent major accidents involving dangerous substances and limit the consequence to people and the environment of any which do occur. The Directive has recently been amended by Directive 2003/105/EC of the European Parliament and of the Council of 16 December 2003 Amending Council Directive 96/82/EC on the control of major-accidents hazards involving dangerous substances.OJ L345/97 31-12-2003. (Seveso). COMAH applies to establishments that have the potential to cause major accidents because they use, or store, significant quantities of dangerous substances, such as oil products, natural gas, chemicals or explosives. COMAH applies at two thresholds the lower-tier and top-tier depending upon the quantity of dangerous substances stored. COMAH places duties on the Competent Authority to inspect activities subject to COMAH and prohibit the operation of an establishment if there is evidence that measures taken for prevention and mitigation of major accidents are seriously deficient. It also has to examine safety reports and inform operators about the conclusions of its examinations within a reasonable time period. An analysis to identify and evaluate emergencies should be conducted and based on this an emergency plan should be developed, checked on its suitability and effectiveness. The emergency plan should be communicated to company employees and contractors, off-side public, authorities and emergency training should be carried out in cooperation of emergency services. Special attention should be given to the dissemination of information regarding the hazards of fertilizer decomposition to emergency services and port authorities and how to best deal with such accidents. SDS's should be readily available for responding to internal and external emergencies, A procedure for reporting and investigating incidents occurred during the manufacturing process should be in place. Qualified persons should be nominated to respond to internal and external enquiries on product and process related emergencies. The Commission has for the Member States adopted a reporting form for a major accident
Interpretation of the Directive Interpretation of the Seveso directive is not always easy. To assist EFMA members but also National Authorities is a proper interpretation of the various Seveso descriptions relevant to Ammonium nitrate and Ammonium nitrate fertilizers EFMA has prepared the note: "Comparison of Sevso, EFMA Interpretation and ADR classification". (See also chapter 3.1.6. ADR) . "Comparison of Sevso, EFMA Interpretation and ADR classification"EFMA 2006
Land-use planning in Seveso The commission issued in 2006: Land Use Planning Guidelines in the Context of Art. 12 of the Seveso Directive 96/82/EC as amended by Directive 105/2003/EC. September 2006. The document is intended to give guidance for risk assessment in the Land Use Planning (LUP) in general as far as the major accident potential of industrial establishments is concerned.
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3.1.3.6 PRODUCT
SAFETY (SDS ETC)
For detailed information please see 3.1.5 Product marketing and sales
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Bulk blending Instead of distributing single-nutrient fertilizers separately or making use of factory-manufactured multi-nutrient fertilizers (complex fertilizers), the farmer may wish either to mix the fertilizers himself or to make use of the services of one of the retailers with blending units. This provides the opportunity to prepare special blends with nutrient ratios to suit the particular farmer's needs appropriate to his own soils and crops. Fertilizers which are to be mixed must be compatible both chemically and physically.
As regard to blending of fertilizer material care should be taken taking into account safety aspects. The compatibility data as they are appear in the public domain are limited as far as possible combinations of fertilizers are concerned and are often only based on quality aspects, not on safety aspects. The matrix as given in the former version of the program does not apply to powders, fines or deteriorated products, which will have more restricted compatibility. See EFMA guidance for Safe Handling and Utilization of Non-conforming Fertilizers and Related Materials for Fertilizer Producers 2003 and similar guidance for Fertilizer Importers, Distributors and Merchants, 2004
Fertilizer Blend Raw Material Compatibility CheckSelect Materials:- Compatibility result:- Notes:- (For further details, refer to full EFMA Guidance document) DISCLAIMER: The information and guidance given in this matrix is based on the EFMA Guidance for the Compatibility of Fertilizer Blending Materials (June 2006). EFMA, its members and staff accept no liability for any loss or damage arising from the use of either the Guidance or the "Compatibility matrix". If in doubt seek expert advice when using an unlisted/uncommon component.
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3.1.3.8.
CONTRACTOR MANAGEMENT
Companies should have procedures in place covering EFMA's guidelines for contractor sourcing and management for the on-site operations. These guidelines cover: Qualification of contractors
Training
Safety passport
Contact persons
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Training shall be given and documented for company employees and contractors whenever relevant on:
Procedures for training and training need have to be reviewed at least annually:
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EFMA Requirements In response to the increased concern related to terrorism and misuse of fertilizers, EFMA recognises the need for addressing security in production, storage, transportation and sales of fertilizers. Hence, EFMA has updated its Product Stewardship program to cover this important topic in more depth and in accordance with recently expressed demands by the authorities. EFMA's recommendations for security measures are not made available in this description of EFMA's Product Stewardship program. It is available for EFMA members only and is part of the EFMA auditing system for evaluating the adherence to the recommendations amongst the members.
EFMA's recommendations for security measures. Members Only Click on logo to access
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