Slide title

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Chlorinated Solvents (Cs)
STEVEN BEDDEGENOODTS Supply Chain EHS, European
Transportation Operations Regulatory
Management Dow Belgium bvba Prins Boudewijnlaan
41 B 2650 Edegem Belgium Mobile [phone]
531 beddegs_at_dow.com Tel [phone]
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Chlorinated Solvents
Section Chlorinated Solvents
Specific hazard characteristics - ground / water
pollution - long term irreversible effects
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• Subject of public concern
• Numerous special regulations within the EU

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- Special needs for safe use and handling of
chlorinated solvents all along the supply chain
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This section shall address the additional special
requirements and care needed to assure
RESPONSIBLE CARE compliance over the whole
distribution chain of chlorinated solvents in
order to enhance their acceptance by society and
their sustainnability.
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Scope

• Covered chlorinated solvents
• Perchloroethylene (Per) (synonym of
  Tetrachloroethylene, Tetrachloroethene)
• Trichloroethylene (TRI) (synonym of
  Trichloroethene)
• Dichloromethane (DCM) (synonym of Methylene
  Chloride)
• Companies in the distribution of chlorinated
  solvents shallcomply in minimum to
• Di Standard activities
• S Site assessment (relevant sections)
• Cs Chlorinated solvents

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Section Chlorinated Solvents

• Content
• Product Stewardship
• General characteristics of the distribution chain
• Legal requirements and important guidelines
• Storage
• Repackaging / handling
• Bulk transport and loading / unloading
• Packed products transport and delivery
• Waste management

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Section Chlorinated Solvents

• Content
• Product Stewardship
• General characteristics of the distribution chain
• Legal requirements and important guidelines
• Storage
• Repackaging / handling
• Bulk transport and loading / unloading
• Packed products transport and delivery
• Waste management

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Product Stewardship (2.1.1a/c 2.1.3)

• - Proper description of the enduse application
• - Clearly indentify the use of the solvent eg
• metal surface cleaning
• determination of asphalt composition
• dry cleaning

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Record system / procedure for each customer
- Volume information
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- Procedure in place to check- miss-use (e.g.
cold cleaning / open application) - unsafe use,
handling or disposal (hazard for ground /
water, worker exposure and ful- fillment of
legal requirements)
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- Procedure in place to- avoid delivery in case
of obivious miss- use, unsafe handling or
disposal and customer refusal for corrective
actions
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Information available to support Product
Stewardship initiatives?
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Product Stewardship (2.1.5a/c)

• SDS, ECSA or producer handling guidelines shall
  be provided at the time of initial product
  distribution
• Dissemination of SDS shall be repeated
  periodically
• Up-dates of important literature shall be send
  automatically

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Product Stewardship (2.1.5a/c)
Records of SDS dissemination and preferably also
the dissemination of all additional important
product safety, health and environmental
information or literature shall be
recorded. System(s) in place shall give evidence
of above. Because of the essential importance of
these requirements for a safe use of chlorinated
solvents, the auditor shall check if the
questions Di-4.5.7 are specifically fulfilled
regarding chlorinated solvents.
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Product Stewardship (2.1.6 b/c)
Procedures to strongly urge users to handle,
store, use and dispose chlorinated solvents in a
safe way.
Possible risks involved

• State of the art equipment
• use

• handling, storing and disposal

Full product traceability also in cases of
sub-distribution?
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Product Stewardship (2.1.10)
Distribution records shall be kept for all
shipment of chlorinated solvents

• Product name
• Lot number
• Name and location of receiving company
• Quantity
• Carrier and date of shipment
• only repacked material
• repacking date
• Full traceability of filling of the bulk tanks
  (product name, lot number, supplier, carrier,
  date)

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Repackaging / handling (6.1.3, 6.1.6)
Design and construction of equipment
To help prevent soil and groundwater
contamination, a secondary containment system is
required, which is already a legal requirement in
many countries A closed vapour system (vapour
return line) is preferred in order to prevent
emissions. The repacking should be carried out
only by properly trained employees under adequate
supervision.
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Repackaging / handling (6.1.1)
Design and construction of equipment
Carbon steel is generally satisfactory - however
stainless steel can be used in special cases
where high quality and purity of the product is
demanded (steel according to BS EN 10025
(replacing DIN 17100) respectively DIN EN 17155
and stainless steel, according to DIN 17440
(partly replaced by DIN EN 10088)). Equipment
used in storage, handling and processing must not
contain aluminum, magnesium, zinc or any alloys
of the material.
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Repackaging / handling (6.1.7)
Explosion risk evaluation for repackaging of DCM
and TRI
The chlorinated solvents discussed exhibit
neither flash point nor fire point by standard
methods. These solvents except for
perchloroethylene, DO however have flammable
limits in air, these vapours might burn in
contact with a source of high energy. For this
reason electrical equipment approved for used in
hazardous locations is recommended for work in
closed tanks, in accident situations or in
locations where high concentrations of solvent
may accumulate.
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Repackaging / handling
For details refer to the ECSA technical document
Storage and handling of chlorinated solvents

• Storage
• Unloading of bulk solvent
• Transfer from storage
• Recommendation for handling drums and small
  containers
• Maintenance
• Safety precautions for tank cleaning and repairs
• Appendices

Storage and Handling of Chlorinated
Solvents ECSA
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Repackaging / handling (6.2.3)
Characteristics of state of the art
technologies for safe handling
ADR regulations

• Fix connections for liquid transfer to avoid
  spills / leakages
• Vapor return lines to minimize air emissions
• Appropriate control equipment to avoid
  overfilling
• Double walled IBC or safety drum container
• Material compatible with and resistant to
  chlorinated solvents (most of todays generally
  used plastic containers are regarded as not
  suitable as long as their suitability has not
  been specially proven)
• Consideration of vapor pressure of
  Dichloromethane (Methylene Chloride)

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Section Chlorinated Solvents
Here more information is provided by ECSA
www.eurochlor.org
Your questions?