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    CHANGES IN THE COATINGS INDUSTRY OF IRELAND WITHIN THE PAST TEN YEARS

    BY: Wayne Kenny

    Date: 15/09/09

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    TABLE OF CONTENTS

    Executive Summary: .......................... ............................ .......................... ............... 1

    Introduction .......................... ........................... ........................... ........................... . 2

    United Nations:............................................ ........................... .......................... ...... 3

    European Union: ........................ ........................... .......................... ........................ 3

    Top of Form IPPC Licensing & Environmental Agency: .......................................... 4

    Decorative Paints Directive: ............................. ........................... ........................... . 5

    REACH: ................................................................................................................ 5

    Conclusion .................................................. ........................... .......................... ...... 6

    References ........................ ........................... ........................... .......................... ...... 7

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    Executive Summary:

    Concern for the environment has led the changes in Ireland for the coatings industry

    for the past ten years. As world agencies such as the United Nations published

    detailed convention statements and protocols of implementing increasing

    limitations on the emission of volatile organic compounds (VOCs). These

    emissions are believed to be the primary cause of photochemical smog and ozone

    pollution. Due in part to their comments to these protocols the European

    Community adopted a Directive for Integrated Pollution Prevention Control

    Licensee. This directive was the umbrella for following directives such as The

    solvent Emissions Directive 1999/13/EC .The industry regulator was the

    Environmental Protection Agency (EPA). In 2001 the European Union adopted

    two further directives, The National Ceilings Directive and the Ozone Directive.

    The National Ceilings Directive gave ceiling limits on VOCs and other chemicals

    for all EU member states using 2010 as a bench mark. The ozone Directive is to

    establish long term objectives, target values and thresholds for ozone occurring in

    ambient air in EC member states designed to avoid adverse effects to human health.

    This led to the decorative paint directive. The EC established REACH

    Registration Evaluation Authorization of Chemicals. These directives lead to

    centralization of traditional paint manufacturing in Ireland, drove innovation

    (compliant coatings) and market opportunity for companies who continued to

    manufacture in Ireland.

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    Introduction

    This article will show that concerns for the environment by world agencies such as the

    United Nations Economic Commission for Europe and adopted by directives the EC lead to

    dramatic changes within the coatings industry in Ireland the past ten years. The industry

    which traditionally considered environmental issues as nuisance concerns were turned head

    over heals by the introduction of Integrated Pollution Control Licenses and the daughter

    legislations that followed. The Environmental Protection Agency aggressively pursued

    companies for the full implementation of IPPC license. The monetary cost of the license on

    some companies lead to centralized manufacturing of operations away from Ireland. This

    was the major driving force for Crown Paints the largest paint manufacturer in Ireland fordecades to concentrate its manufacturing in the UK and hence reduce the cost of having an

    IPPC license on two manufacturing sites, the same can be said of Trimite Truecoat the

    largest Irish industrial paint manufacturer. The companies that remained manufacturing and

    maintained their IPPC license saw further Directives such as The solvent Emissions

    Directive 1999/13/EC, The National Ceilings Directive and the Ozone Directive. These

    directives related directly or in directly to VOCs. This drove the innovation of paint

    formulations to become compliant. Traditionally paint companies formulations would not

    change for years now they were all under pressure to become compliant on the quantities ofVOCs. What this meant was all paint companies were on level playing fields in aspect of

    reformulating. This gave a great advantage to the remaining manufacturing companies in

    Ireland to take on the established larger companies. Everlac paints had a turn over of 250k

    punts and after 4 years from the introduction of IPPC licensing had increased to over one

    million. It was taking sales from the larger companies whom no longer manufactured in

    Ireland (this was an unique selling point, USP for Everlac) also the difference between

    formulations from its competitors was very little because they all switched to higher solids

    coatings to achieve compliance with the solvents directive.

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    United Nations:

    In the 1970s and the 1980s the realization that the worlds air pollution needed

    action resulted in the United Nations taking part in conventions resulting in various

    agencies e.g. United Nations Environment Programme (UNEP), United Nations

    Economic Commission for Europe etc. These groups provided discussion,

    published detailed recommendations, convention statements and protocols.

    However it was still up to national governments to introduce legislation.

    EuropeanUnion:

    The European Union first adopted a directive Integrated Pollution Prevention

    Control License. The following directives such as The solvent Emissions

    Directive 1999/13/EC were daughter directives of the IPPCL. The European

    Union published Best Available Techniques or BAT for the application industry

    but not paint manufacture. This lead innovation by paint companies from their

    customers as they sought a reduction in VOC content of paint. This was being

    achieved by elimination at source by Higher solids paints and waterborne

    coatings. The European Union established a singular regulatory body for chemicals

    Reach Registration, Evaluation, Authorization of chemicals. The REACH system

    will replace four legal instruments in the community i.e. Directives 67/548/EEC,

    Directive 88/379/EEC, Council Regulation (EEC) 793/93 and Directive

    76/769/EEC. This once again has formulation changes for the industry as some

    chemicals will be no longer supplied by paint suppliers as registration is to costly or

    the reclassification of such chemicals gives rise to labeling problems.

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    Top of Form IPPC Licensing & Environmental Agency:

    The EPA has been licensing paint manufactures with over 10 tones of solvents

    usage activities since 1994. Originally the licensing system was known as

    Integrated Pollution Control (IPC) licensing, governed by the Environmental

    Protection Agency Act, 1992. The Act was amended in 2003 by the Protection of

    the Environment Act, 2003 which gave effect to the Integrated Pollution Prevention

    Control (IPPC) Directive.

    IPPC licences aim to prevent or reduce emissions to air, water and land, reduce

    waste and use energy/resources efficiently. An IPPC licence is a single

    integrated licence which covers all emissions from the facility and its

    environmental management.

    All related operations that the licence holder carries in connection with the

    activity are controlled by this licence.

    The introduction of the IPC license to paint manufactures in Ireland saw larger

    paint manufactures centralizing operations. This was due to the cost of compliance.

    The larger manufactures such as Crown and Trimite closed their manufacturing

    operations in Ireland and returned them to the United Kingdom. The thought

    process was simple, one manufacturing site, one IPPC License and one cost of

    compliance. The EPA would not allow the loss of jobs in Ireland as a threat for

    none compliance. They allowed a period of time for compliance but still the larger

    manufacturers choose to centralize. This created an opportunity for the smaller

    companies to establish a better slice of the sales in Ireland. They could take

    advantage of there new USP (Unique Selling Point). This was evident with Everlac

    paints as there sales increased by 75%. The new customers were established

    Trimite customers but they preferred a manufacture in Ireland that could deliver

    novel solutions to problems in quick time.

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    Decorative Paints Directive:

    The Directive on the Limitations of Emissions due to the use of organic solvents in

    certain Paints, Varnishes and Vehicle Refinishing Products, (Decorative Paints

    Directive) Directive 2004/42/EC, limits the VOC content of these widely used

    products. The Directive was enacted into Irish law by the Limitation of Emissions

    of Volatile Organic Compounds due to the use of certain Paints, Varnishes and

    Vehicle Refinishing Products Regulations 2007 (Statutory Instrument 199 of 2007).

    This directive again induced innovation in paint formulations.

    REACH:

    REACH is the Regulation for Registration, Evaluation, Authorisation and

    Restriction of Chemicals. It entered into force on 01 June 2007 to streamline and

    improve the former legislative framework on chemicals in the EU.

    REACH switches most responsibility of control and safety of chemicals from

    authorities, to chemical manufacturers, importers and users and places greater

    responsibility on industry to manage risks that chemicals may pose to human

    health and the environment. REACH also aims to promote alternative methods

    for the assessment of hazards of substances and eliminate unnecessary testing,

    especially on animal.

    Both new and existing substances are covered by REACH. All substances

    manufactured or imported into the EU in quantities greater than or equal to one

    tonne per year must be registered with the European Chemicals Agency

    (ECHA) in its central database.

    In Ireland, theHealth and Safety Authority (HSA), the Environmental Protection

    Agency and the Minister for Agriculture Fisheries & Food have been designated

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    under the Chemicals Act 2008 as the competent authorities for REACH. REACH

    has reduced the amount of available raw materials to the formulator but it does

    allow the reporting of unauthorised products.

    Conclusion

    Environmental issues have been the main driving force of change in the coatings

    industry in Ireland in the past ten years. Although they were vigorously opposed

    and initially may have indirectly led to job loses. I think they have strengthened

    Irish manufacturing companies by inducing innovation. The directives have

    created a level playing field for all companies as they achieve compliance. The

    industry was traditionally dominated by a few larger companies but this

    domination has been reduced by centralisation of some companies to the UK. The

    industry has also entered a time of continuous reformulating. This is

    unprecedented, as formulations may have remained stagnant for decades.

    We are entering an industry more focused on environmental issues and are

    leaving behind the mentality of environmental situations being a nuisance.

    EU chemical strategy still under development aiming at protecting human health

    and the environment will become a major challenge for the paint industry with in

    Ireland but if we embrace these challenges we can achieve a stronger industry

    based on innovation.

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    References

    .