The European Commission has drawn up new guidelines to speed up the BREF (Best Available Techniques Reference Document) review. The technical working group (TWG) involved in shaping the BREF for smitheries and foundries consists of 17 members, including the European Foundry Association (CAEF), delegations from the European Member States, the Industry, the EU Commission and European Environmental Associations.
Certain work is carried out within a so-called front-loading procedure. Unlike the ‘wish list’ used in the past, in which the members of the TWG could formulate their revision requests related to the BREF contents, now ‘initial positions’ are developed by the BREF authors and submitted to the TWG for comment. These initial positions include proposals and requests for potential adjustments to an existing BREF; for example regarding the scope and structure of the document, relevant key environmental issues (KEI) and organisation of data collection as well as potential BAT candidates.
In a statement CAEF said: “The SME structure of the foundry industry has to be taken into account during the whole BREF revision activities. Thus, the European Foundry Association welcomes the more focused approach as required by the EU Commission. Only processes and parameters being definitely of environmental relevance should be the object of the review. In particular, some of the proposed KEI have been seen as very critical by the foundry industry.
“So, CAEF does not consider requirements for energy or material efficiency as being reasonable. Due to the huge variety of applied materials, technologies, processes and manufactured products, the setting of certain limit values can never satisfy the individual conditions of our companies.”
In March, the assessed items of the initial positions were submitted to the Seville Bureau. They form the basis for a ‘kick-off’ meeting scheduled for September 2019.
The European foundry industry consists of 4,700 companies. Nearly 300,000 employees are generating a turnover of €43 billion. European foundries are recruiting 20,000 workers and engineers per year. No industrial sector exists without using cast components. www.caef.eu