POWER & UTILITIES REACH Regulation and Biocidal Product Directive Compliance Assessment Combined Cycle Gas Turbine CHP Plant, UK
Project Summary
REACH Regulation and Biocidal Product Directive Compliance Assessment Combined Cycle Gas Turbine CHP Plant, UK
Key Project Elements Combined Cycle Gas Turbine CHP Plant European Legislation REACH Regulation EC/1907/2006 Biocidal Product Directive 98/8/EC Regulation of Chemicals and Biocides Compliance Assessment In-Situ Production of Biocides
Pre-Registration and Registration Obligations
CRA is providing a range of consultancy services to a combined cycle gas turbine combined heat and power (CHP) installation in the UK, including assisting in health, safety and environmental compliance management. REACH is a European Union (EU) regulation (EC/1907/2006) concerning the registration, evaluation, authorisation and restriction of chemicals which came st into force on 1 June 2007. REACH is based on the premise that industry should be responsible for demonstrating that all chemicals put on the market do not have an adverse affect on human health or the wider environment. The Biocidal Product Directive (98/8/EC) aims to harmonise the European market for biocidal products and their active substances in order to provide a high level of protection for humans, animals and the environment. CHP installations use a range of chemicals to maintain the quality of water used in the process, including active chlorine based biocides. To minimise the inventory of hazardous chemicals on-site, the client used in-situ generation of sodium hypochlorite with temporary storage before injection into the water treatment system. CRA was commissioned by the client to investigate whether the in-situ production of hypochlorite impacted on their obligations under the REACH regulation. In consultation with the local competent authority for the REACH Regulation and the Biocidal Product Directive (the Health and Safety Executive), CRA determined that the client was obliged to pre-register the production of hypochlorite under the REACH Regulation. This requirement arose due to the specific nature of the installation at the client’s site, in particular the use of temporary storage for generated product, and the situation that the equipment suppliers had not registered the produced products under the Biocides directive. CRA identified options for the client to remove the obligation to pre-register hypochlorite production under the REACH Regulation, including amending the process to remove the temporary storage stage. CRA also provided advice to the equipment suppliers for the in-situ generation of hypochlorite to facilitate avoidance of their customers being required to pre-register/register production of hypochlorite under the REACH regulation.
Ref: PS0073