Strengthening chemicals management in Best Available Techniques Reference Documents

On the EU level the main instrument to control industrial releases is the Industrial Emissions Directive (IED), particularly through the publication of BAT Reference documents (BREFs) and the corresponding key chapter, the BAT conclusions. The objective of the IED is to achieve a high level of environmental protection as a whole. This target can only be achieved when the BREFs include all chemicals and substances used in or potentially released from industrial processes, both the ones that have already been identified as hazardous and regulated, as well as the less known and non-regulated ones. At the centre of this report is the analysis of the information exchange under the IED, which results in BREFs and corresponding BAT conclusions. This report proposes how relevant information on chemicals used in or released from industrial processes can be more systematically addressed during BREF reviews. Special emphasis is given to possibilities to better use the available data generated in the context of other pertinent EU legislation such as REACH and POPs Regulation and Water Framework Directive (WFD). The HAZBREF project recommends further systemic cooperation and exchange of information between the European IPPC Bureau coordinating the BREF work and chemical experts from REACH, WFD and the POP convention community. To identify the hazardous chemicals relevant for a given industrial sector and to strengthen the measures to control them, BREF reviews require extended frontloading, systematic identification of chemicals and reinforcing the BREF Technical Working Group (TWG) with knowledge on chemicals. The HAZBREF project further recommends including a specific chapter on chemicals in all BREFs and BAT conclusions and proposes the key topics to be addressed. The proposals of this report seem to fall within a favourable political context with the recently published European Green Deal that defines a new policy framework requiring a deep transformation for the EU’s economy for a sustainable future. One of the key commitments of the EGD is the EU’s zero pollution ambition for a non-toxic environment, which is supported by the Chemicals Strategy for Sustainability published in October 2020. The proposals made by the HAZBREF project would further strengthen the future BAT conclusions and support the IED in achieving the abovementioned EU policy objectives