Surveys available until now show that the printing industry as a predominant user of VOC-containing products contributes considerably to the total VOC emissions (about 70kt/a) in Germany. Some types of printing installations fall within the scope of the above Directive due to the relevance of their emissions. These installations have to fulfil the requirements related to the technique and organisation of the Directive as soon as it will be implemented in German legislation.

In view of the described background it was the goal of this survey to compile the existing VOC-controlling measures in the printing industry and to assess their reduction potentials and economic effects. In addition it was the aim to determine the scope and the reduction effects of the CD 99/13/EC and possibly to identify problems arising from its practical implementation in the printing installations.

The realisation of this project was accompanied by a series of intensive discussions with representatives of the printing associations and printing experts.

In order to obtain meaningful data for the selection and assessment of the different emission reducing measures it became necessary to compile a clearly more detailed database of VOC use and VOC emissions than it has been available by now.

Image carrier production as well as varnishing processes during printing activities have been considered in this data base. However, lamination and glueing processes causing relevant emissions as well could not be listed. The data available at present in this field show a lack of specification, which makes a precise classification of the glueing and printing processes for the whole sector impossible.

As agreed with the Federal Environmental Agency printing processes in areas such as textile printing, wall cover screen printing and tampon printing have not been examined in this study. The exclusion of these printing processes was due to the fact that they represent a specific group of stakeholders.

The total emissions of 53.293 kt/a is well in line with the emission estimates and reduction prognoses of the VCI/BMU-Dialogue on environmental targets in which VOC are taken as an example[2]. The estimates have a comparable scope with regard to the production processes in question. However, there are significant differences in main emission areas. Whereas the VOC emissions from graphic printing processes are lower according to the Ökopol database[3] in comparison with the VCI/BMU-Dialogue, the packaging printing processes show noticeably higher emission values[4] according to the VCI/BMU-Dialogue database.

Only the types of installations that are marked grey in table Z1 belong to the areas of activities that fall under the CD 99/13/EC. A part of the other types of installations (machine constellations) however, also contribute significantly to the total VOC emissions. To which extend this difference in legal requirements will lead to a distortion in competition in the printing market is hard to estimate since various market sectors need to be considered.

In Annex IIA of the CD 99/13/EC thresholds for the total VOC Input are listed indicating that an installation falls under the regulations of the Directive. Usually printing installations reach these values fairly quickly which is mainly due to the extensive use of VOC in auxiliary products.

The following table Z2 shows an estimation at what amount of printed ink per year an installation is subject to the CD 99/13/EC.

Furthermore it is striking that installations using water-based ink systems are object to the CD 99/13/EC at a comparatively small amount of printed ink per year. Apart from the VOC amounts already inherent in the ink systems the reason for this lies in the usage of VOC in other auxiliary processes such as cleaning of machinery.

The scope of the CD 99/13/EC is illustrated in the following table:

[ÖKOPOL 1999]

With a close examination of the detailed VOC database the emission reducing measures to be evaluated primarily have been chosen according to the following criteria:

1. Relevance of quantities, which means that the reduction measures concentrate on processes that are relevant with regard to the total emissions (>1% of the total emissions of the industry, that is the emissions of the process > 530 t/a)
2. Feasibility, meaning that according to the opinion of printing experts it is likely that the measure in question may technically and environmentally play a significant role in VOC reduction in the coming ten years.

Measures chosen accordingly were evaluated within the framework of a 10-year prognosis with regard to their reduction effect, their (technical) feasibility and their costs.[5]

Models[6] have been used for the calculation of the economic effects where emission reducing measures were calculated on the basis of concrete products and actual prices.

The following table Z4 shows the reduction effect of the measures examined with regard to the main emission processes.

[ÖKOPOL 1999]

Based on the 10-year prognosis it would be possible to reduce VOC emissions in the German printing sector from approx. 53.29 kt/a (reference year 1997) by as much as 50% to approx. 26.36 kt/a. However, it needs to be considered that this is a summation of the maximum values that are expected in the individual reduction areas. Less than half of the reduction potential is found in plants submit to the Council Directive 99/13/EC (CD 99/13/EC plants)[8]. Furthermore, it needs to be taken into account that particularly the last quarter of this amount can only be achieved with a clearly sinking marginal utility[9] of the financial input.

On the basis of the above calculations the main areas of VOC reduction, the figures of the 10-year prognosis, the requirements in Annex IIA and the requirements of a reduction scheme stated in Annex IIB of the CD 99/13/EC[10] have been listed in the table Z5.

[ÖKOPOL 1999]

Main conclusions from the above assessment:

• It is sensible and necessary that the multipliers for the calculation of reference and target emissions in the reduction schemes in Annex IIB[12] have been adjusted to the achieved emission reduction standard in the draft of the Federal Environmental Agency for the implementation of the VOC Directive in German legislation. It ensures that the principle formulated in the Directive regarding the equivalence of both instruments "The achievement of the emission reduction standards in Annex IIA" as well as the "Implementation of a VOC reduction scheme in Annex IIB" is being complied with.

• Even a complete implementation of the requirements of the CD 99/13/EC in its present form would reduce the emissions in the printing sector by a maximum of 12.9%. While the existing reduction potentials of "CD 99/13/EC plants" would be covered, significant reduction potentials of the "Non-CD 99/13/EC plants" would not be taken into account. If the above-mentioned environmental target is to be realised, it is indispensable to include "Non-CD 99/13/EC plants" as well.

The exemplary application of the CD 99/13/EC in existing printing plants shows that the collection of data causes problems. The information on solvent flows that is currently available in most of the companies is not sufficient at all to meet the documentation requirements in Annex III of the EG VOC-RL.

The problems range from a lack of knowledge of the VOC and solids content in used inks, varnish and adhesives, over problems depending on the split of auxiliary products in the different processes, to questions about the actual collection and destruction rate in abatement equipment.

Inquiries with the chemical suppliers, the use of the actual split-factors from comparable operations and the application of typical efficiency factors could make up temporarily for this lack of data in the course of our primary examinations. When the CD 99/13/EC is actually implemented in German Legislation there is, however, a lot of support is needed with the development of practical data management systems. This also implies the listing of VOC contents in the product information and safety data sheets by the chemical suppliers.

During intense expert discussions with the different stakeholders in the printing industry in the course of this project it became obvious that there is a broad consensus among all parties that it is necessary to put in joint efforts to achieve the emission reduction targets. Moreover, the stakeholders have already contributed constructively to the implementation of reduction measures in the past.

The following recommendations of the authors for the different groups of stakeholders are to be understood explicitly as contributions to continue this successful and constructive dialogue.

• Evaluating marketing and use restrictions for low-boiling solvents (e.g. Al-cleansing agents[14]) as supporting measures in the area of very small installations, that are hardly reachable even for the sector associations.

• Application of multipliers that have been adjusted to the achieved emission standard for the determination of reference and target emissions in Annex IIB of the CD 99/13/EC as described in the draft of the Federal Environmental Office for the implementation of the CD 99/13/EC in German Legislation of 20/09/99

• Introduction of a practice-relevant multiplier for the determination of reference and target emissions in Annex IIB of theCD 99/13/EC for Heatset-Offset printing of O.65

• Making out model reduction schemes as an implementation aid for operators and inspectorates

• Adjustment of the emission limit values expressed in mg C_ges/Nm³ of Annex II A to the emission limits of the German TA-Luft measured in mg substance/ Nm³ on the basis of typically used solvents (or solvent mixtures)

• Use of exact definitions when implementing the CD 99/13/EC in German Legislation. This concerns inter alia the demarcation of quantities of mass flows within the solvent management plan (Annex III) that should be made operationable through practice-relevant questionnaires

• Clarification of how to determine precisely the volumes of waste air (waste air according to the EG VOC-RL) in printing operations so that verifications of the emission limit values will be possible according to Annex IIA

• Determination of the use of "toluene-reduced inks" as best available technique in publication gravure installations

• Evaluation of whether the use of the "closed ventilation" in publication gravure within the framework of a media-spanning assessment (IPPC-Examination – integrated polution prevention and control approach) can be regarded as an environmentally sound alternative and thus should be seen as best available technology

• Determination of an isopropanol content of < 8% in damping solutions of heatset rotary installations as best available technology, if necessary using respective gauging techniques and control engineering

• Declaration of cleaning machines for machine components which work in closed systems and are connected to the waste gas treatment as best available technology in solvent-based packaging printing installations

• Promotion of training programmes for operators and employees, emphasising on the careful use of VOC-containing products and on the application of substitutes if appropriate
• Promotion of techniques reducing the IPA use in the offset printing in small operations

• Practice-relevant questionnaires for solvent management plans in different machine constellations should be worked out. Simple computer-based solutions can be used in which the respective calculation factors of the CD 99/13/EC, the features of typical input substances, and the collection and destruction rates of exhaust treatments are listed

• Model reduction plans should be set up for the various machine constellations

• Active information of the association members about progressive means of emission reduction and execution of respective training programmes as a part of the industry-wide training scheme
• Further development of the requirements defined by the initiative "Lösemittelarmes Drucken". Particularly the efforts to reduce IPA in offset machines should be intensified. An approximate value for the IPA content is to be determined possibly graded by types of installations and with the exemption of certain problematic products. A limit value of < 5% in damping solutions for new installations would be conceivable whereas for existing installations a limit value between 8–10% could be realised
  
  A more precise and more progressive target definition than "Conversion to A III-agents"[16] should be chosen in the area of the cleansing agents. It would be up- to-date and useful to state the value of the maximum vapour pressure for the agents applied, for example maximum vapour pressure < 1hPa[17]. A precondition for the practical implementation are easily understandable instructions in the product information and safety data sheets.

• Considering options for emission reduction possibilities (Encasement, Applicability of cleansing agents with high boiling points, ...) as a selection criteria when purchasing new machinery.
• Continuous examination and maintenance of the abatement-equipment to ensure optimal function
• Adaptation of the systems for purchase and material flow so that input substances (such as printing inks) with very different VOC contents can be balanced separately. In that respect it is necessary to quote the quantities delivered/used in these systems in addition to the prices.
• Installation of gauges for flow measurements in solvent recycling installations and the different areas of solvent use thus improving the database necessary for working out solvent management plans.
• Implementing best practice in operating the installations with regard to the emission reduction (e.g. switch of colours, avoidance of VOC-containing varnishing in installations without waste gas treatment, .........)
• Installation of gauges for flow measurements in solvent recycling installations and the different areas of solvent use thus improving the database necessary for working out solvent management plans.

• Information of the customers about the VOC contents (given as percentage of weight) in their products (e.g.as additional information in the product descriptions and safety data sheets). Additionally the product's density should be declared, so that mass calculations can be carried out. It would be even more favourable to indicate the respective VOC amounts in kg(t) in the delivery notes/invoices or to provide a listing of the annual supply to the customers.

• Inclusion of understandable and practical advice on handling of products in its description to ensure an effective reduction in VOC. In this context a comprehensive strategy would be useful to find ways of including key advice into the health, safety and environment management. Such qualified product information could become a very important tool for the implementation of work instructions.
• The suppliers of adhesives, thinners and varnish should set up internal delivery statistics as well as statistics of their respective associations which immediately show the delivered quantities (including the respective VOC amounts) that exceed the thresholds of the EG VOC-RL. Either the status quo or the effect of the emission reduction measures in the respective activities can only be made transparent and be discussed appropriately among experts and policy makers on such a basis.
• Carrying out a training programme for service staff (distribution, service, instruction,...) to enable them to pass on profound knowledge on progressive, emission reduction measures.
• Purchasers of VOC-containing products are to be advised offensively on substitution alternatives
• Development of products with a low VOC content (e.g. UV ink systems in packaging printing) for further application areas should be promoted strongly.

• As part of their responsibility the manufacturers of printing installations should set up offensive training programmes for their service staff (distribution, service, instructors,...) to enable them to pass on profound knowledge on progressive, emission reduction measures
• Prices and marketing should be reasonable so that barriers against the client-specific adaptation to emission-reducing technology and products can be avoided. E.g. the installation of IPA-free damping units through third suppliers should be carried out by crediting the original damping units and the additional costs for the machine adaptation should be made transparent. Furthermore the costs to upgrading machines or the use of low-emission products should be reduced as much as possible