Miljøprojekt, 1134 – Evaluation of the Danish Statutory Order on Lead

Evaluation of the Danish Statutory Order on Lead

8 Discussion and summary

Possible amendments to the Lead Order are summarised in Tables 8.1 and 8.2. Table 8.1 concentrates on lead in chemical compounds, while Table 8.2 concentrates on lead as a metal.

The tables list the amendments to the Lead Order which are deemed technically possible and practicable. In order for substitution to be practicable, there must be alternatives and these must cover the largest part of the current consumption within the relevant area of use. However, it is rarely possible to identify alternatives which cover current consumption 100 %, as in many situations special conditions such as specific product properties must be provided for; so, in practice 100 % cover often requires tests to adjust other parameters.

Therefore, it is always likely that individual manufacturers will have special problems finding practical alternatives, and thus will need to seek exemption.

The current Lead Order has been designed as a general ban (with exemptions) on lead as a chemical compound, while bans on lead as a metal have been introduced for selected uses. Accordingly, this report provides specific recommendations regarding lead as a compound, while for uses of lead as a metal, which are currently not regulated, the report concentrates on alternatives sufficiently well-developed to make a ban possible.

In general, compared with the use of lead and the status of alternatives before the Lead Order was introduced in the late 1990s, there has been a considerable movement away from lead for many areas of use (cf. [Hansen & Brønnum 1998]).

For example, use of lead as a pigment in plastic and as a stabiliser in PVC. Both these uses have been important, but today they have either ended altogether (pigment) or they have almost ended (stabilisers). Another example is the use of lead to balance wheels on cars, which has now been banned for new cars.

The general benefits arising from this development are lower emissions of lead into the environment, either directly through use or production of products containing lead, or indirectly in waste treatment and disposal.

There have been several forces behind this development, including that Danish enterprises have continued to make significant efforts to develop lead-free alternatives, even though the Statutory Order provides exemptions for these uses. For example cable mantles on underground electrical cables, where it is now possible to eliminate lead in all underground cables. Brake linings and porcelain are other examples.

Table 8.1 Uses of lead as a chemical compound where amendments to the Statutory Order on Lead could be considered

Use	Possible amendment	Remarks
Special purposes in elastomers	There is no need for a general exemption for heat stabilisers.	It is possible there may be applications for exemptions.
Stabilisers in electrical cables incorporated in products	There is no need for a general exemption for electrical cables incorporated in products. The exemption could be limited to an exemption for high-flexible cables in machine components which move relative to each other. This exemption is also relevant for cables which are not incorporated in products.	Electrical cables incorporated in products are subject to the RoHS Directive. It is possible there may be applications for exemptions.
Brake linings	There is no real reason to continue the exemption for brake linings. The exemption could be replaced with an exemption for increased content of lead in raw materials for brake linings as in the EU End-of-Life Vehicles directive.	Brake linings in cars of up to 3.5 tonnes are subject to the EU End-of-Life Vehicles Directive. It is clear that applications for exemption will be submitted.
Electrical discharge lamps	The exemption should possibly be repealed. If the exemption is retained it should be made more specific so that it corresponds with the exemption in the RoHS Directive.	Electrical discharge lamps are subject to the RoHS Directive
Paint for special purposes	No change – the exemption should be re-evaluated after some years.
Glass for special purposes	There is no need for exemptions for car window screens and coating of plane glass. It is possible that the exemption should be repealed for picture tubes, light sources, optics and plates in photocopiers. With regard to glass for protection against radiation, crystal and silicate glass for sand blasting, the exemption should be re-evaluated after some years.	Picture tubes, light sources, optics and filter glass, and plates in photocopiers are covered by the RoHS Directive. Car window screens are covered by the EU End-of-Life Vehicles Directive.
Glaze, enamels and pigments on art and handicrafts	It should be possible to repeal the exemption for works of art.	There will be a need to exempt Flora Danica porcelain and other art of cultural-historic significance. Clearly exemption applications will be submitted.
Glaze on tile, vitrified brick, brick and spark plugs	The exemption for glaze on tile, vitrified brick, and brick should be continued and re-evaluated after some years. The exemption can be repealed for spark plugs for cars of up to 3.5 tonnes.	Spark plugs are covered by the EU End-of-Life Vehicles Directive. How to promote development of alternatives for glaze on tile, vitrified brick, and brick should be considered.
Electronic components	No change – the exemption should be re-evaluated after some years.	Electronic components are subject to the RoHS Directive.
Superconductors	An exemption for superconductors should be introduced - the exemption should be re-evaluated after some years.
Red lead	The exemption for red lead to restore historical objects should be considered.	Alternatively other methods of restoration should be developed.
Aviation fuel	No change	There should be consideration on how trading in unleaded aviation fuel can be ensured in Denmark. Certain aircraft or piston engines for aircraft can require permanent exemption to be able to use leaded fuel.
Primers for ammunition	There is a need for a general exemption for lead compounds in primers for ammunition and detonators. This exemption should be reassessed after some of years.
Lead in incandescent lamps	The need to introduce exemptions for lead as a chemical compound in special incandescent lamps should be considered.	Lead in incandescent lamps is covered by the RoHS Directive.

Table 8.2 Uses of lead as a metal where amendments to the Statutory Order on Lead could be considered

Use	Possible amendment	Remarks
Flashing on roofs	There is no need for a general exemption for repairs, rebuilding and extensions on houses. The exemption can probably be limited to listed buildings or those classified as worthy of preservation, and where, for architectural reasons, it is deemed appropriate to use lead.	There is clearly a need to retrain ”older” tradesmen who have not been trained in the new materials and techniques.
Lead solder on zinc gutters	No change - should be reassessed after some of years.	There is a need to gather, evaluate and if necessary report German experience with using glue on zinc gutters.
Roof covering	Exemption for lead roof covering on historical or listed buildings should be considered	Alternatively other roofing materials should be developed which can replace lead roofing on these buildings.
Fishing tackle	No change	The exemptions should be extended.
Soldering alloys for electronics	No change	Soldering alloys for most types of electronics are subject to the RoHS Directive. A general ban in Denmark could make it hard to import important products.
Low-melting-point alloys	No change	Fuses in many types of electrical and electronic equipment are covered by the RoHS Directive. Only modest amounts of lead are used for this purpose.
Other alloys	No change - should be reassessed after some of years.	Corresponding alloys are covered by both the RoHS Directive and the EU End-of-Life Vehicles Directive.
Balancing	It should be possible to ban lead wheel weights on all vehicles. It could be considered whether it is relevant to ban balancing wind-turbine wings with lead.	Lead wheel weights for cars with up to 8 seats and vans with a total weight of up to 3.75 tonnes are banned under the EU End-of-Life Vehicles Directive.
Protection against radiation	No change
Sound and vibration suppression	No change	Vibration suppression in cars is covered by the EU End-of-Life Vehicles Directive.
Cable mantles	It is possible to extend the ban on lead cable mantles to all underground cables.
Ammunition	It should be possible to stop the use of metallic lead in rifle ammunition for hunting and possibly also for sports shooting.	Use of lead in rifle cartridges will be banned in Sweden from 1 January 2008 both for hunting and sports shooting, unless the spent ammunition is gathered up and disposed of appropriately.
Other purposes	Restrictions on the use of lead for certain of the uses involved could be considered.

Introduction of the EU RoHS Directive and the End-of-Life Vehicles Directive has in many ways accelerated developments, especially because “at one blow” the regulation covers such a large market, that manufacturers globally must adapt their production to meet the requirements. In this way it has been possible in practice to introduce substitutes for lead in solder, lead as a stabiliser in electrical cables, lead in weights on car wheels, lead in brake linings, and lead for many more purposes.

The introduction of these directives also means that removal of a number of exemptions from the Lead Order could be considered, as regulation of these uses has been taken over by the Directives.

Finally, technological developments mean, for example, that the use of lead in picture tubes in televisions and computer screens is coming to an end without regulation because the traditional picture-tube screens are disappearing from the market as flat screens take over.

Examples of areas where no significant progress is being made towards substitution are equipment for commercial fishing and glazing on tiles, vitrified brick and bricks.

Considerable efforts have been invested in equipment for commercial fishing, including by the suppliers of equipment. However, the fisheries sector is currently under financial pressure and it has so far not been possible to develop alternatives, except for simple sinkers, which are financially competitive with traditional lead solutions, there has been no motivation to market alternatives. For the moment it is suggested that the exemptions be extended for this area.

With regard to glazing for tiles, vitrified bricks and bricks, it seems that the lack of efforts could be due to a lack of motivation to develop alternatives, and therefore a special effort is recommended for this area.

A particularly important area for Denmark is flashing around windows etc. on roofs. Large quantities of lead have traditionally been used for this purpose. Developments in this area, however, have been successful and alternatives have been developed which could replace traditional lead flashing for all uses. Consideration for listed buildings and other buildings classified as worthy of preservation, and where for architectural reasons it is considered appropriate to use lead, today seem the only real arguments for continuing to use lead.

The Lead Order includes a general exemption for repairs, rebuilding and extensions for houses. This exemption means that lead felt for flashing is still sold at do-it-yourself centres and can thus be used by both tradesmen and do-it-yourself enthusiasts, even though alternatives are available. In order to prevent this abuse, it is suggested that the exemption for repairs, rebuilding and extensions to houses be repealed for lead flashings.