RAL Quality Assurance Association excluded from CECED discussion meeting
The RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment Containing CFCs has not been invited to attend the roundtable discussion meeting on the treatment of hydrocarbon-containing waste refrigeration equipment that was announced by CECED at a conference in Hamburg in January this year. The Quality Assurance Association, which since 1998 has been actively addressing issues relating to the quality of the fridge recycling process, has made numerous requests to CECED to be allowed to attend the meeting and contribute towards finding a constructive solution. The European headquarters of the manufacturers’ organization has now chosen not to invite the RAL Quality Assurance Association citing differences of opinion. RAL is now concerned that the results from the roundtable meeting will fail to comply with existing environmental legislation.
The RAL Quality Assurance Association has been actively engaged in trying to clarify the numerous misunderstandings and misinterpretations that have arisen in relation to the WEEE directive and its implementation in the national laws and regulations of the EU member states. The Quality Assurance Association has made a number of significant contributions aimed at rationalizing and objectifying the issues (see “Background information” below).
During a presentation at a WEEE conference in Hamburg, a CECED representative announced a roundtable discussion meeting involving CECED, the WEEE Forum and EERA (an association representing a number of recycling companies) that was to be held in spring of 2006. As the only professional organization focused solely on issues relating to fridge recycling, it seemed clear that the RAL Quality Assurance Association would also be invited to participate at this meeting, and repeated requests were submitted to CECED. In the end, RAL’s request to participate in the consultation meeting was declined, because, as a letter from CECED to the Quality Assurance Association put it: “the RAL position provides no room for compromise”.
The RAL Quality Assurance Association is very disappointed with this response, but strongly believes that neither the existing laws nor the facts of the case offer any real room for compromise. According to Association Secretary Christoph Becker, the fact that not only RAL but also the EU environmental agencies are being excluded from discussing future approaches to handling and treating hydrocarbon appliances leaves the impression that the organizers have little interest in any strict compliance with the WEEE directive and the related national laws. It is thus to be feared that in future the driving force behind the practical implementation of the WEEE legislation will be commercial interests, rather than environmental protection as originally intended by legislators.
The RAL Quality Assurance Association calls upon those groups involved in the forthcoming discussions to ensure that all institutions and organizations working in this important area are given the opportunity to contribute to the roundtable meeting. If one-sided resolutions are to be avoided, it is essential that not only the RAL Quality Assurance Association, but also representatives from the EU Commission, European environmental agencies and relevant scientific institutions (such as the Fraunhofer institutes) are allowed to attend the meeting.
The results of the meeting, should it fail to provide a discussion forum for all stakeholders in the field, will be analysed in detail by RAL. The Quality Assurance Association will be publishing its response to the results in due course and will continue to work towards the full and systematic implementation of the WEEE directive and the environmental protection legislation put in place by EU member states. In this particularly sensitive area any compromise that jeopardizes climate and environmental protection is unacceptable.
The RAL Quality Assurance Association nevertheless hopes that it will be asked to participate in the talks in Brussels and would welcome an invitation from the meeting organizers.
RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment Containing CFCs Headquarters
B.P. 1228, L-1012 Luxembourg
Phone: +352-488361-41
Fax: +352-488361-42
info@ral-online.org
http://www.ral-online.org
Background information on the treatment of waste refrigeration equipment containing hydrocarbons:
CECED, the European Committee of Domestic Equipment Manufacturers, was and remains convinced that it is wholly acceptable to allow the “˜controlled emission’ of hydrocarbons into the environment, i.e. the complete release of all hydrocarbons by diluting their concentration in the exhaust air stream.
However, in September 2005, the EU Commissioner for the Environment made it unambiguously clear in his response to questions posed by the RAL Quality Assurance Association that the Association’s interpretation of the law was correct and that in his opinion hydrocarbons contained in waste fridges and freezers, such as cyclopentane or R600a, are to be removed and then recycled or disposed of appropriately.
Despite the additional confirmation provided by the legal opinion of the respected law firm Prof. Versteyl, and despite the submissions received by RAL from numerous EU environmental agencies, and the fact that many European recycling plants have been modified to incorporate current best available technology, the opinion of the Brussels-based CECED remains unchanged.
According to Dr. Viktor Haefeli, Chairman of the RAL Quality Assurance Association, there are more than just purely legal reasons why waste refrigeration appliances containing hydrocarbons must be treated with the same due care and attention as appliances that contain CFCs. “˜The fact that new appliances are still being produced that are not clearly marked as containing hydrocarbons is itself reason enough to ensure that existing CFC-extraction plants are capable of handling hydrocarbon appliances,’ said Haefli; adding: “˜The additional cost and effort that would be necessary if CFC and hydrocarbon appliances were to be separated prior to undergoing separate treatment can now be avoided completely, as the technology for the joint processing of CFC and HC appliances is available. If waste refrigeration equipment is “treated” in car shredders, the recovery rates stipulated in the WEEE directive are unlikely to be achieved. And, just as importantly, there is the strong environmental argument to minimize emissions of VOCs (volatile organic compounds) to which the hydrocarbons used in fridges belong.’
Christoph Becker, Secretary to the RAL Quality Assurance Association, raised a further argument against a separate processing channel for hydrocarbon appliances: “˜Experience has shown that whenever an apparently cheaper option is available to the waste management sector, this is the path taken. If car shredders are approved as an acceptable method of treating CFC-free appliances, it is inevitable that CFC-containing appliances will also end up at these sites, and in numbers that neither we nor legislators feel are tolerable. This seems all the more likely to happen given that transparent handling, separation and treatment procedures are hardly going to be priority issues when the approach to waste treatment is focused on quantity rather than quality.’
More information on this and other issues is available from the “˜News’ page at Ral Online
