Integrierte Vermeidung und Verminderung der Umweltverschmutzung

Chapter 7
The risks associated with the use of EDTA have been assessed by the European Chemicals
Bureau [256, European Communities European Chemicals Bureau, 2004]. The report of the risk
assessment refers to the total European market for EDTA and states “A high level of usage is
the dairy and drinks industry, with 50 % of the total reported tonnage”. The report discusses
removal rates for some on-site WWTPs and some MWWTPs. It concludes “There is a need for
limiting the risks; risk reduction measures which are already being applied shall be taken into
account. This conclusion is reached because of the high emissions due to the use of EDTA in
industrial detergents. The exposure near sites within dairy and beverage industry with no
effective EDTA removal in their treatment plants is expected to lead to a risk for aquatic
organisms”. The report then also mentions other industrial sources of EDTA emissions to water.
During the information exchange, the use of EDTA and its emission to water was acknowledged
to be an ongoing problem in the FDM sector. The TWG agreed that it is BAT to minimise the
use of EDTA. Throughout the work, the TWG reported that for some applications there are no
known effective substitutes which can be used to completely eliminate the use of EDTA and
that the effectiveness and environmental impact of some potential substitutes had not been
adequately assessed. During the final TWG meeting, it was reported that EDTA is not used in
dairies in the UK. The possibility of determining BAT to eliminate the use of EDTA could be
greatly helped if information about alternative substances already in use was provided and
research into other alternatives was undertaken, before this document is reviewed.
A number of activities, particularly in relation to vegetable processing, are seasonal. Some
members of the TWG have expressed concern about the application of generic BAT to seasonal
activities, due to different economic standards, although specific information about these
difficulties was not provided. This issue is not well covered in this document. Information about
seasonal activities should be collected in the future.
Some information was provided by the TWG after the consultation period when it was too late
to take it into account. For example, late information was received about enzymatic degumming
of vegetable oils and fats and enzymatic interesterification of fully hydrogenated vegetable oils
and fats. Such information can be considered when this document is reviewed. It is
recommended that degumming of vegetable oils be fully appraised when this document is
reviewed. The TWG discussed the use of either citric acid or phosphoric acid, particularly with
reference to their relative impacts on the final phoshorus content of treated waste water and their
economic viability. The TWG did not reach a conclusion about which technique is BAT.
Other issues have been raised during the information exchange, but not fully appraised. It is
recommended that information be provided about these for discussion when this document is
reviewed. These issues include:
• as a general principle, a wider examination of the applicability of techniques reported to be
applied in one sector that could be carried out in other sectors. This would optimise the
opportunity for sectors to learn from each other. For example, pigging was reported for use
in jam making, but it is already widely applied in the FDM sector and may be applicable as
a dry cleaning technique in other FDM sectors, for which it has not yet been considered
• identification of more opportunities for by-product valorisation, to optimise the use of food,
drink and milk materials and to minimise waste generation
• economic information about the costs of investing in and operating techniques and the
associated direct and indirect savings, e.g. due to reduced energy or waste disposal costs, or
reduced losses from unintentional losses due to leakage or spills
• identification of BAT associated with high, medium and low pressure cleaning. The TWG
were unable to determine which of these techniques is BAT. Increasing the pressure can
remove solid residues by physical force and potentially reduce the consumption of hot and
cold water and detergents. Increasing the pressure also increases the aerosol levels produced
and this can cause hygiene problems, particularly if it is necessary to carry out cleaning
during production
• although many air abatement techniques are described in this document, there is very little
information about their application and applicability in the FDM sector
620 January 2006 RHC/EIPPCB/FDM_BREF_FINAL