Miljøprojekt, 1080 – Evaluering af blybekendtgørelsen

Evaluering af blybekendtgørelsen

Summary and Conclusions

An assessment of the need for revision of the Ministry of Environment's Statutory Order No. 1012 of 13. November 2000 (the Lead Order) has been undertaken. This assessment shows that it is relevant to adjust the Order with respect to a number of issues. The suggested adjustments inter alia include the following:

That a number of the present exemptions to the ban of the Order against the use of lead should be revoked, as lead free alternatives have been developed.
That exemption is proposed for some applications, which at present are covered by the ban.

Furthermore, options for introducing use restriction for certain uses of lead as metal, which are not presently restricted, have been identified. It may also be considered to revoke some of the existing exemptions to the ban, which are also covered by EU regulation

Background and objectives

Since the Lead Order was introduced, an ongoing development of substitutes to lead has taken place in Denmark as well as internationally. This development is a consequence of the Lead Order as well as the EU RoHS directive (EU directive 2002/95/EC) and the EU directive on end-of-life vehicles (EU directive 2000/53/EC) and - not the least - the general effort in the industry aimed at substituting hazardous substances.

It has since 2003 been planned that the Lead Order should be reassessed in order to identify the need for adjustments. In this context special attention has been paid to the general exemption of the use of lead for repair, rebuilding and extension of houses.

The purpose of this investigation has thus been to assess the need for revision of the Lead Order and in this context consider the practical experiences from the implementation of the Lead Order as well as the new knowledge and technology developed within the field covered by the Order since the Order went into force.

The investigation

The investigation has consisted in collection and evaluation of information from private companies, technical schools, the internet and the literature on the state of art regarding alternatives for the different application areas.

Special focus has been given to those areas, for which dispensations have been granted and the general exemption of lead for repair, rebuilding and extension of houses. Furthermore has emphasis been given to investigation of those uses of lead as chemical compound, which so far have been exempted from regulation.

Finally, for all uses of lead as metal, which so far have been exempted from regulation, it has been assessed, whether significant new developments has taken place that could make regulation realistic. This has been investigated partly by personally contact to key companies in Denmark, partly by studying the development in an international perspective inclusive of the consequences of new EU directives as the RoHS Directive and the end-of-life vehicle directive.

For all uses, for which dispensations have been granted, personal contact has been made to the companies in question to investigate the background of the dispensation application and the actual situation regarding the use in question and availability of alternatives etc.

Conclusions

The investigation has shown that it is relevant to adjust the Statuary Order on several issues.

Lead as a chemical compound
Regarding the use of lead as a chemical compound it is assessed that the following exemptions from the ban on lead can be revoked, as substitutes have been developed that by and large may replace lead:

Heat stabilisers in elastomers
Brake linings
Glazes, enamels and pigments for arts and crafts

A need for dispensations must be envisaged especially for arts and crafts, as lead also is used in the manufacture of products with of cultural and historic importance as e.g. Flora Danica.

Concerning stabilisers in electrical cables integrated in products and electrical cables in general, it is assessed that exemption is needed only for high-flexible cables for machine parts moving relatively to each other, inclusive of lift cables.

The exemption can, furthermore, be revoked for car windows and coating of flat glass. It may, furthermore, be considered to revoke the exemption for uses as discharge lamps, and lead glass for cathode ray tubes, lamps, optical purposes and plates in copy machines, as these uses today are covered by the RoHS directive.

However a number of uses exist for which no alternatives to lead to the best of knowledge seem to be available. For these uses there is a need for exemption or another form of prolonged dispensation. The uses in question include the following:

Superconductors
Igniters for ammunition
Lead paint for restoration of historical items

It may, however, be possible that the need for lead paint could be solved by developing other routines for restoration works.

Today dispensation is given for the use of leaded gasoline to small planes driven by piston engines, as lead free gasoline is not marketed in Denmark. Lead free gasoline is, however, marketed in Sweden and it is expected that the majority of the planes in question could use lead free gasoline. Therefore it is relevant to consider if lead free gasoline can be marketed in Denmark and how the practical arrangements can be made.

Lead as metal
Regarding the use of lead as metal it is assessed that the general exemption of the use of lead for repair, rebuilding and extension of houses can be revoked with respect to lead flashing around windows etc., as adequate alternatives today are available for all applications. The exemption may probably by limited to buildings preserved or classified as preservation-worthy and for which it based on architectonically reasons is deemed relevant to continue the use of lead.

It is also possible to expand the present ban on the use of lead in cables sheaths for cables in soil above 24 kV to include all cables in soil.

It should be considered, whether it is possible to introduce a general ban on lead in wheel balancing weights. Lead weights are today banned in the EU for cars with seats for up to 8 passengers and vehicles for transport of goods with a maximum weight of up to 3.75 tonnes. Other vehicles are not covered by the EU directive on end-of-life vehicles, but in principle it should be technically possible to develop lead free wheel balancing weights also for these vehicles.

It should furthermore be considered, whether the use lead for balancing of wings for wind mills could be avoided.

Also with respect to ammunition it is technically possible to reduce the use of lead. Today lead free riffle ammunition in standard calibres for hunting is available on the market, and it should be considered to introduce a ban on the use of lead for this purpose corresponding to the ban that will enter into force in Sweden on 1. January 2008. Restrictions may also be considered regarding lead ammunition for sports shooting, but alternatives to lead seems to be less developed than for hunting ammunition.

Apart from this no other changes concerning the use of metallic lead have been proposed. It is noted that the experiences with the substitution efforts related to equipment for commercial fishing shows that in this field it is very difficult to develop competitive alternatives to lead based equipment. Therefore a need exist for extension of the existing dispensations.

All in all it must be concluded that for many fields of application a significant movement away from lead has happened compared to the situation before the Lead Order was introduced. The benefit following from this development is a reduced emission of lead to the environment directly by manufacturing and use of products containing lead as well as indirectly by waste handling and disposal.