OCS programme gets attention

CLEAN UP THE WORLD

PLASTICS POLLUTION • RIDDING THE WORLD’S OCEAN OF MICROPLASTICS WILL BE A LONG TASK BUT INDUSTRY IS ALREADY WORKING ON IT; THE SUPPLY CHAIN WILL ALSO BE SUBJECT TO CONTROLS

PUBLIC AWARENESS ABOUT the environmental impact of waste plastics, especially in the world’s oceans, is a relatively recent phenomenon but industry has been alert to the issue for some time. Operation Clean Sweep® (OCS) was established first in North America in the 1990s and has been implemented in Europe since 2015. It aims to prevent the loss of plastics granules during handling and their release into the environment and is one of the projects of the Global Plastics Alliance’s Marine Litter Solutions programme.

OCS is going to be more firmly established in Europe very soon. The European Chemical Industry Council (Cefic) and PlasticsEurope have been formalising their cooperation in developing external auditing tools and, during the course of 2020, work has been going on to define the four audit modules. These will cover: production; master-batching, compounding and converting; transport and logistics; and recycling.

For those involved in the transport and logistics function, this raises the possibility of a further round of auditing, on top of those already experienced. In an online meeting this past June, the European Chemical Transport Association (ECTA), the European Federation of Chemical Distributors (Fecc), the European Plastics Converters (EuPC) and PlasticsEurope strongly supported the idea that this module of OCS auditing should be integrated with – or at the very least closely related to – existing auditing modules within the Safety & Quality Assessment for Sustainability (SQAS) programme. Such an approach would avoid the need for additional auditing costs and time, while also recognising the work done under the SQAS programme to address the issue.

ALIGNING AUDITS ECTA says that an extra revision cycle may be needed to the existing SQAS modules in 2021 to incorporate specific aspects required by OCS and it will be working with Cefic on this process.

ECTA warns that, if logistics companies involved in the polymer supply chain are not able to provide evidence through SQAS that their self-regulation is sufficient to ensure zero pellet loss during their operations, then wider legislation may be introduced, which may involve new international standards and a separate certification scheme.

ECTA membership includes a commitment to Responsible Care principles and their annual reporting to ECTA, including improvement plans, can be expanded to include key performance indicators (KPIs) under OCS. ECTA notes that those OCS requirements are also included in the ECTA Responsible Care Commitment statements. In the near term, ECTA is eager to hear from its members with their reactions to the OCS development and, if necessary, it will organise a separate webinar early in 2021 to discuss the matter further.

Meanwhile, PlasticsEurope reports that all its 52 member companies are now part of the OCS programme, after it made it compulsory as from the start of 2020. Indeed, by the end of 2019, nearly 700 companies and associations along the entire plastics value chain in Europe had joined the programme, representing a 40 per cent increase in just one year. Notably, more than 100 logistics operators added their names in 2019 alone. The Port of Antwerp and PD Ports in the UK were early signatories and, during 2019, the Spanish ports of Cartagena and Tarragona, along with the port of Felixstowe in the UK, also joined the programme.

WHERE IT STARTED In Europe, OCS includes six commitments, one of which is to audit performance

regularly; another is to encourage partners in the value chain – including logistics providers and distributors - to pursue the same goals. In order to achieve those goals, PlasticsEurope has committed to the development of a certification scheme with third-party auditing. This will provide a way for all participants to demonstrate their efforts towards zero pellet loss and represents, PlasticsEurope believes, the most effective and efficient approach to achieving that goal.

OCS certification is also fully in line with the measures to curb microplastics pollution in the oceans proposed in the 2018 EU Plastic Strategy, which specifically included a certification scheme along the plastics supply chain. As proposed, the OCS certification scheme will set common requirements, based on the six commitments of OCS, that will be audited regularly. PlasticsEurope is aiming to have the scheme ready for implementation by 2022.

PlasticsEurope also reports that, in 2019, around 90 per cent of companies surveyed said that they are already carrying out periodic inspections of their facilities to verify their performance in terms of OCS. Most of these involve internal audits but more than one-third of respondents said that OCS is now part of an external management certification such as ISO 14001 or ISO 9001.

It is unlikely that there will be a workable ‘off-the-shelf’ solution to OCS certification, PlasticsEurope says. “The size and technical set-up of production sites differ, and so do production and logistical processes. Also, companies may be on different levels regarding pellet containment and awareness of staff. Therefore, it is crucial that companies assess individually where and how risks of pellet loss occur and how these can be tackled.”

GOING IN THE GULF It is not just in Europe that OCS is gaining traction. This past September, the Gulf Petrochemicals and Chemicals Association (GPCA), which represents the chemical industry in the Arabian Gulf adopted the programme, with the aim of improving sustainability and ensuring best environmental practices among plastics manufacturers and logistics operations in the Gulf Cooperation Council (GCC) area. The announcement was made on World Cleanup Day 2020.

GPCA notes that OCS is practiced in more than 60 countries around the world and is now a global initiative, aimed at ultimately achieving zero pellet, flake and powder loss and contributing to global efforts by plastics producers to protect the environment and minimise their environmental footprint.

Plastics manufacturers in the GPCA area produce more than 32m tonnes of polymers annually and, GPCA says, pellet, flake and powder loss is a growing problem with a significant economic and business cost and a threat to the industry’s reputation within local communities. OCS aligns with GPCA’s commitment to the Marine Litter Solutions programme and, specifically, its aim to address marine litter at the source though plastic pellet containment.

“GPCA is steadfast in its resolve to champion this important initiative in the Arabian Gulf and empower both our member companies and their employees to drive change from the ground up,” says Dr Abdulwahab Al-Sadoun, GPCA’s secretary general. “As demonstrated in our recent Responsible Care Performance Metrics report, the regional chemical industry is in the leadership position in environment, health, safety, and security (EHS&S) performance, and its commitment to sustainability will only be strengthened by Operation Clean Sweep. When compared to alternative materials, plastics reduce environmental costs by nearly four times and adopting more robust pellet containment practices will help improve the industry’s sustainability impact even further.” www.opcleansweep.eu www.marinelittersolutions.com www.ecta.com www.gpca.org.ae

EFFECTIVE CONTAINMENT DURING PRODUCTION,

CONVERSION AND THE LOGISTICS CHAIN CAN

PREVENT PLASTICS PELLETS BEING RELEASED

TO THE ENVIRONMENT, WHERE THEY REPRESENT

GETTING TO GREEN

STRATEGY • THE EU HAS BOLD AMBITIONS FOR DECARBONISATION AND GREATER SUSTAINABILITY. ITS STRATEGY FOR CHEMICALS HAS, THOUGH, RAISED SOME CONCERNS

THE EUROPEAN COMMISSION adopted the EU Chemicals Strategy for Sustainability this past 14 October. The Strategy is a first step and will clarify the EU’s ambition for a “toxic-free environment” as set out in the recent ‘Green Deal’ document, which caused some consternation during discussions at last month’s EPCA Annual Meeting.

The Commission says the Strategy will “boost innovation for safe and sustainable chemicals and increase protection of human health and the environment against hazardous chemicals”, while recognising the “fundamental role of chemicals for human well-being and for the green and digital transition of European economy and society”. It seeks to set out concrete actions to make chemicals “safe and sustainable by design” and that they are used more safely and sustainably.

“We owe our well-being and high living standards to the many useful chemicals that people have invented over the past 100 years,” says Virginijus Sinkevicius, Commissioner for the Environment, Oceans and Fisheries. “However, we cannot close our eyes to the harm that hazardous chemicals pose to our environment and health. We have come a long way regulating chemicals in the EU, and with this Strategy we want to build on our achievements and go further to prevent the most dangerous chemicals from entering into the environment and our bodies, and affecting especially the most fragile and vulnerable ones.”

WHAT EU WANTS Flagship initiatives included in the Strategy include: - phasing out use of the most harmful substances in consumer products - minimising and substituting as far as possible the presence of substances of concern in all products - addressing the combination effect of chemicals, and - ensuring that producers and consumers have access to information on chemical content and safe use. Thus far, the Strategy appears to be little more than an extension of the existing Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation, which has pulled together the information on all chemical substances on the EU market that will be required to make informed decisions on the initiatives set out in the Strategy.

The European Commission, though, does say that the actions announced in the Strategy will “support industrial innovation so that such chemicals become the norm on the EU market and a benchmark worldwide”, indicating that innovation will be required to deliver the end-points established in the Strategy. This will rest on the development of design criteria for safe and sustainable by design chemicals, although there is the promise of financial support for the commercialisation of sustainable chemicals. There is mention of targeted amendments to the REACH Regulation, along with some sectoral legislation, and a beefing up of enforcement both at the borders of the EU and within the single market. There is also the promise of an EU-wide research and innovation agenda, aimed at filling knowledge gaps on the impact of chemicals, promoting innovation and moving away from animal testing.

INDUSTRY COOLS Industry has not been wholehearted in its response to the release of the Strategy. Commenting on it, Marco Mensink, directorgeneral of the European Chemical Industry Council (Cefic), said: “Cefic welcomes the new compliance, enforcement and innovation proposals in this new Chemical Strategy for Sustainability, which we have been calling for as being much-needed in Europe. The strategy has become more balanced. However, overall this has become a missed opportunity for a strategy to accelerate how Europe’s fourth largest industry can deliver on the Green Deal, as a growth strategy, while reinforcing EU global leadership on chemical regulations.

“What we have today reads more like a long list of regulatory measures lacking sufficient clarity on how they will be joined up, how they relate to real-world geopolitical context like Brexit or how they will all add up to achieve the Green Deal objectives,” Mensink continued. “This is especially concerning at a time when the rest of the world has not yet followed REACH and is unlikely to. With 96 per cent of manufactured goods relying on chemicals, Europe’s chemical industry is at the heart of almost all value chains and Green Deal solutions, from solar panels to batteries, wind turbines and hydrogen to building insulation, EU-made pharmaceuticals and more powerful electronics, to name just a few.

“This uncoordinated policy risks undermining the role the EU’s homegrown industry can play, in favour of simply outsourcing the Green Deal technology solutions to other parts of the world. From this point onwards, it is crucial that a much more coordinated approach is taken to how the impacts of this strategy are assessed, how the various measures come together towards a shared objective and how this strategy should be implemented.”

A WAY AHEAD Cefic has its own ideas on how to proceed, as Mensink explained: “Looking forwards, what Europe still needs is a Green Deal ‘game plan’ for its chemical industry, from large companies to SMEs and all its downstream customers, which can deliver the investments needed at scale to meet the chemical strategy goals and at the same time invest in things like electric crackers, hydrogen, chemical recycling, Carbon Capture Storage and Utilisation. This is why we are calling for a sectoral Green Deal for chemicals to help fulfil the enabling role of Europe’s chemical industry.

“Companies need the right policy signals and signposts to invest at unprecedented new scale in Europe, and above all industry needs regulatory predictability,” Mensink added. “We are encouraged to see a proposal in the strategy for further industry and stakeholder dialogue and Cefic stands ready to participate fully to help make the Green Deal a reality. Such dialogue is deeply needed to strike the right balance.”

For the European Association of Chemical Distributors (Fecc), director-general Dorothee Arns added to the call for coordination, saying: “Fecc welcomes the proposals included in the new Chemical Strategy for Sustainability, which can be a real opportunity for our sector. This applies specifically to SMEs, provided that it can support the industry to deliver on the European Green Deal objectives and strengthen Europe´s strategic value chains. Potential risks lie in additional complexity for SMEs to implement the regulatory measures, which appear to lack clarity on how to cope with the current geopolitical context and how they can contribute to achieving the objectives spelled out in the European Green Deal.

“Fecc calls on regulatory predictability in combination with more EU investments in innovation and a science-based approach towards REACH and other major pieces of technical regulation as major legislative framework in the chemical sector. At the same time the distribution sector would appreciate it if this valuable initiative could also lead to a more harmonised approach between REACH and the Biocidal Products Regulation (BPR) on substance identity,” Arns added.

“The Covid-19 pandemic has not only shown that chemicals are essential enablers for meeting the societal mega-challenges, but also that the Commission can identify processes to simplify methodologies for regulations without compromising compliance with the highest HSE standards. Fecc sees the strategy as an opportunity to review these types of overlaps in support of the Chemical Strategy for Sustainability objective of simplifying and strengthening its legal framework, fully in line with the Commission´s Better Regulation agenda, while ensuring its full enforcement in Europe.

“However,” Arns concluded, “the strategy’s success can only be ensured by greater policy coherence and a coordinated approach to support the Green Deal objectives. This could be achieved by means of an intense stakeholder dialogue with the entire chemical value chain, to which the European distributors would be more than happy to actively contribute.” cefic.org www.fecc.org

DIALOGUE IS NEEDED IF THE CHEMICAL INDUSTRY,

AN ESSENTIAL ENABLER IN MEETING SOCIETAL

MEGA-CHALLENGES, IT TO BE ABLE TO FULFIL