SHE REPORT

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EFMA

SAFETY HEALTH &

ENVIRONMENT REPORT APRIL 2009

APRIL 2009

european fertilizer manufacturers association

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Copyright 2009-EFMA EUROPEAN FERTILIZER MANUFACTURERS’ ASSOCIATION AVE. E. VAN NIEUWENHUYSE, 6 B-1160 BRUSSELS BELGIUM

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EFMA SAFETY HEALTH AND ENVIRONMENT REPORT

CONTENTS

Introduction

2

EFMA’s Product Stewardship Programme

3

Safety

5 ●

EFMA’s Safety Survey in Production

6

●

EFMA’s Incident Reporting

7

●

EFMA’s Safety Seminar

8

●

EFMA’s Guidance Documents

9

❍

Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines

9

❍

Guidance for Inspection of Atmospheric Refrigerated Ammonia Storage Tanks

10

Health

11 ●

●

Chemical Policy

11

❍

REACH

11

❍

Material Safety Data Sheets

11

EFMA’s Guidance Documents

12

❍

Guidance for the Preparation of Safety Data Sheets for Fertilizer Materials

Environment

12 13

●

EFMA’s Environmental Benchmark Survey in Production

14

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EFMA’s Ammonia Energy and CO2 Emissions Survey

16

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EFMA’s Preparation for Emission Trading Scheme 2012

16

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EFMA’s Activities in Agriculture

17

List of EFMA publications

19

Prepared by EFMA

1

DISCLAIMER: The information and guidance provided in this document is given in good faith. EFMA, its members and staff accept no liability for any loss or damage arising from the use of this guidance.

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INTRODUCTION

This is the fourth annual EFMA Safety, Health and Environment (SHE) report since the first SHE report was issued in 2005. The report describes various joint SHE activities of EFMA members during the year 2008. This report demonstrates that the EFMA Product Stewardship Programme, as an umbrella of all EFMA’s SHE activities, is anchored deeply in the EFMA community. Special emphasis is given to EFMA’s REACH activities and EFMA’s preparation for the forthcoming regulation on CO2 emissions trading.

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E F M A’ S P R O D U C T S T E WA R D S H I P P R O G R A M M E

The Product Stewardship Programme (PS) covers the ‘life cycle’ of fertilizers, describing the responsibilities of fertilizer companies for the safety, security, health and environmental aspects in the whole supply chain starting from sourcing of raw materials, in production, storage and distribution and for providing guidance to farmers.

It is mandatory for EFMA members to implement the programme and this is available on a CD-ROM with guidance on how to implement PS in their companies. It is also made publicly available on EFMA’s website www.efma.org. In addition, an audit manual to facilitate self-assessments has been made available for EFMA members. Audits of the members’ operations are carried out by an independent 3rd party (SGS) every three years, to confirm the members’ adherence to the requirements of the programme. All EFMA’s SHE activities form part of this PS concept.

The first full audit took place in 2004-2005 and the results were presented to EFMA’s board of Directors. A small number of companies that did not meet the challenging criteria of the PS requirements, were audited again in 2006. A second full audit was performed at the end of 2007/beginning of 2008. All companies passed the audit and received their certificates.

EFMA has further developed the existing PS programme into a recognised standard in compliance with ISO Guide 65.

EFMA updated the PS programme in the reporting year 2008. The updated version of the programme (version 1.4) can be found on the EFMA website www.efma.org.

Comprehensive training was given to new EFMA member companies in July 2008, in preparation for the next full audit due at the beginning of 2011.

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EFMA’s Product Stewardship Programme for Fertilizers is regularly updated. The latest version (version 1.4) can be found on EFMA’s website www.efma.org.

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SAFETY

The safety of our employees, contractors and consumers gets our utmost attention. Towards this objective EFMA’s activities include: • Safety targets for member companies • Safety benchmarks • Analysis of accidents and incidents • Publication of Guidance Documents • Annual safety seminars

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EFMA’S SAFETY SURVEY IN PRODUCTION EFMA Lost Time Injury Rates 1997-2008 25.00

LTIR

20.00 15.00

Employees Contractors Combined

10.00

Dotted lines target 2009

5.00 0.00 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Year

Note 1: The high figure in 2001 is the result of the Toulouse explosion but was not related to commercial grade fertilizer material.

Note 2: LTIR is defined as the number of injuries per million worked hours leading to the absence from work for 1 day or more.

Figure 1 LTIR trends of EFMA’s safety performance (reporting years 1997-2008) and target for 2009.

Lost Time Injury Rate (LTIR) figures are a good indicator of the safety performance in a company (see Figure 1).

In 1997 EFMA started to collect LTIR data from member companies on an annual basis. The target is to reduce the LTIRs for employees and contractors continuously and for this purpose EFMA started to define target figures in 2006. The graph shows the EFMA average LTIR figures as trend lines from 1996 to the reporting year 2008.

After a gradual decline of the LTIR figures from 1995 to 2006, the trend appears to have stagnated. For that reason the Technical, Environment and Safety Committee has advised each member company to draw up an occupational safety performance plan and to submit this to EFMA.

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EFMA’s INCIDENT REPORTING EFMA members report occupational accidents, environmental incidents and process related accidents that occur in the fertilizer industry in Europe and elsewhere. The information is stored in EFMA’s incident database. The database is regularly updated and contains more than 700 entries from a period of more than 90 years. The most recent version of the database (version 1.1, 01-08-2008) has been distributed to EFMA members.The purpose of this database is to share information amongst EFMA members.

New incidents are reported and discussed in EFMA’s Technical, Environment and Safety Committee (TESC) and in EFMA’s Permanent Working Group (PWG) on Product Safety and Transport. This enables the industry to share knowledge and to learn from these incidents. Selected topics are part of the annual EFMA Safety Seminar for a more detailed analysis of the incidents.

EFMA’S Incident Database contains more than 700 incidents and is an important source of information.

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EFMA’S SAFETY SEMINAR In October 2008 EFMA experts met in Brussels for the 11th Safety Seminar. The topic of this seminar was “Fire hazards and behaviour based aspects of safety”. Seventeen valuable presentations were given during the one and a half day seminar, this also included ample time to share and discuss the information presented.

The list below shows the topics of the eleven Safety Seminars held since 1997.

1997:

Learning from incidents.

1998:

Ammonia.

1999:

Nitric acid.

2000:

Ammonium nitrate.

2001:

Safety management systems.

2003:

Regulatory issues.

2004:

EU legislation related to the Fertilizer Industry.

2005:

Transport including loading and unloading.

2006:

Incidents and lessons to be learned.

2007:

Maintenance, major shut-downs, SIL criteria and corrosion.

2008:

Fire hazards and behaviour based aspects of safety.

A safety seminar has been planned for 2009 and it will be based on the following main topics: • Job safety analyses (occupational safety) • Pump/Compressor safety issues • Process precautions in start-up, stand-by and shut down situations • Presentation of at least one of the latest EFMA guidance documents

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EFMA’S GUIDANCE DOCUMENTS One of the many joint activities of EFMA’s Technical, Environment and Safety Committee (TESC) is establishing and issuing industry guidance documents and easy-to-read information leaflets.

These documents are considered best practice standards for safe and environmentally correct operations. The documents are made freely available on EFMA’s website www.efma.org for anyone interested.

In the report period 2008 a new guidance for inspection of and leak detection in liquid ammonia pipelines was issued: Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines

GUIDANCE FOR INSPECTION OF AND LEAK DETECTION IN LIQUID AMMONIA PIPELINES

2008 european fertilizer manufacturers association

The guidance focuses on pipelines with a diameter of at least 75 mm, transporting cold (close to the atmospheric boiling temperature of -33°C) or warm liquid ammonia. It deals with above-ground and underground (also called buried) pipelines which are often located outside battery limits i.e. not inside ammonia or downstream plants but between ammonia plants and harbour, tank storage, other plants or between sites. Thus, the guidance covers off-site pipelines and certain on-site pipelines, as defined above.

The guidance is based on inspection and leak detection practices of various experienced liquid ammonia pipeline operators in the EU. It does not cover fabrication inspection. The underlying intention is to maximise the operational safety and reliability of these pipelines and to reduce environmental and health risks.

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Guidance for Inspection of Atmospheric Refrigerated Ammonia Storage Tanks

GUIDANCE FOR INSPECTION OF ATMOSPHERIC, REFRIGERATED AMMONIA STORAGE TANKS

2008 european fertilizer manufacturers association

Another EFMA document concerns guidance for inspection of atmospheric, refrigerated ammonia storage tanks.

This document provides guidance for the periodic in-service inspection of fully refrigerated anhydrous liquid ammonia storage tanks, which operate at or near atmospheric pressure and -33째C and are located in Europe. The Guidance focuses on major periodic inspection, covering its periodic frequency, method of inspection and regular monitoring between major inspections. It does not cover fabrication inspection. In considering the inspection frequency it describes as an option a risk based inspection (RBI) approach requiring the evaluation of the probability and consequences of failure for each individual tank. The underlying intention is to maximise the operational safety and reliability of these tanks.

This Guidance is a revision of the Recommendations for Safe and Reliable Inspection of Atmospheric, Refrigerated Ammonia Storage, which was published in 2002.

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H E A LT H

We accept the responsibility to minimise health risks for our employees and our customers in production, processing, distribution and use of fertilizers. We provide all necessary information and training to our employees regarding the safety of operations and any health hazards associated with raw materials, chemicals, production processes and finished products. We offer information to our customers regarding the safe handling and use of fertilizers.

CHEMICAL POLICY REACH The EFMA Task Force Registration, Evaluation and Authorisation of CHemicals (REACH) serves as a discussion platform for questions and queries that arise from REACH. The TF has also prepared recommendations for joint EFMA activities such as further testing of a number of selected common products, quantifying exposure scenarios and formation of pre-consortia.

In 2008 the Fertilizer And Related Materials (FARM) consortium was formed; a steering committee oversees the preparatory work which is done in the substance committees whilst technical committees assist in technical matters. The FARM consortium covers some 30 substances and further information can be found at EFMA’s website: http://cms.efma.org/EPUB/easnet.dll/ExecReq/Page?eas:template_im=000BC2&eas:dat_im=001242 The consortium will be accessible to non-EFMA companies.

Safety Data Sheets

11

In 1996 EFMA produced a guidance booklet on the preparation of Safety Data Sheets (SDSs) for the benefit of its members. Its purpose was to help EFMA members in the preparation of their own SDSs by describing the requirements according to various sections in the relevant EC directives, 67/548/EEC and 1999/45/EC for preparations and by providing agreed versions of model SDSs for several fertilizer materials. It was recognised that some of the materials covered did not legally need to fulfil this requirement but they were included on the principle of good responsible care.

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The above-mentioned directives have been superseded by a new far-reaching regulation, Regulation (EC) No 1907/2006, widely known as REACH. This Regulation now defines SDS requirements and also introduces new requirements. It has, therefore, become necessary to revise the 1996 EFMA guidance with a view to facilitate compliance with the current REACH legislation. It has been decided to split the original guidance of 1996 into two separate complimentary publications: the first to give guidance on the SDS requirements to comply with REACH and the second to provide jointly agreed typical model SDSs for a number of fertilizer materials. The first document has been published as an EFMA guidance and was issued in 2008. The second guidance, jointly agreed typical model SDSs of a number of fertilizer materials, will be released in 2009-10.

Guidance for the Preparation of Safety Data Sheets for Fertilizer Materials

GUIDANCE FOR THE PREPARATION OF SAFETY DATA SHEETS FOR FERTILIZER MATERIALS Firm logo

Safety Data Sheet Conforms to 1907/2006/EC Version Issue date

Product name

1

Identification of the substance/preparation and of the company/undertaking Commercial product name Common chemical name Synonyms Chemical formula EU index number (Annex 1) EC No CAS No. REACH or National Product Registration No. Use of the substance/preparation Company name Company address Company telephone Company e-mail for SDS Emergency telephone

2

Hazards identification Classification Physical and chemical hazards Health hazards Environmental hazards Other

3

Composition/information on ingredients Hazardous ingredients Chemical name

2008

Chemical name

EC no. means EINECS or ELINCS number.

4

First aid measures General Inhalation

european fertilizer manufacturers association

Ingestion Skin contact Eye contact Note to physician

12

CAS no.

EC no.

% (w/w)

CAS no.

EC no.

% (w/w)

Other ingredients

Classification

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ENVIRONMENT

Taking care of the environment means reducing emissions associated with the production and use of fertilizers, using energy and natural resources efficiently and thereby promoting good manufacturing and agricultural practices.

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EFMA’s ENVIRONMENTAL BENCHMARK SURVEY IN PRODUCTION For 12 years EFMA has been conducting yearly environmental benchmarking surveys amongst its members.

Data on the emissions of various compounds to water and air from our production facilities are gathered and displayed graphically. This enables EFMA to monitor the improvements and other changes in the emissions from the European fertilizer industry and allows all members to compare their plants to other participants in the survey.

The TESC encourages open discussion among its members in order to improve the environmental performance of European fertilizer production. In August 2007 the EU Best Available Techniques (BAT) Reference Document Ammonia, Acids and Fertilizers was issued by the Commission. This document serves as guidance for National Authorities to set permits to operate. However, BAT threshold values are not necessarily standard for every plant. When setting limit values, the Authorities shall consider local conditions and infrastructure (e.g. waste water treatment downstream) for each site, as well as economic feasibility or the relation of expense and success (i.e. emissions reduction) of technical measures.

Displayed below are trends over the last 12 years in emission rates to atmosphere of NOx from ammonia plants (Figure 2), of NOx from nitric acid plants (Figure 3) and N2O from nitric acid plants (Figure 4).

120

120

100

100

80

80

60

60

40

40

20

20

0

Emission Rate (kg emission per tonne produced) Base year is 100% Total Production in indices

Total NH 3 Production

Annual NOx Emission Rate

NOx to Air Emission Rate From EFMA Ammonia Plants (Base year = 1996)

0 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

Figure 2 NOx in air emissions from ammonia plants.

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NOx to Air Emission Rate From EFMA Nitric Acid Plants

120

120

100

100

80

80

60

60

40

40

20

20

0

Emission Rate (kg emission per tonne produced) Base year is 100% Total Production in indices

Total Nitric Acid Production

Annual NOx Emission Rate

(HNO3 100% ; Base year = 1996)

0 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

Figure 3 NOx in air emissions from nitric acid plants.

N2O to Air Emission Rate From EFMA Nitric Acid Plants

120

120

100

100

80

80

60

60

40

40

20

20

0

Emission Rate (kg emission per tonne produced) Base year is 100% Total Production in indices

Total Nitric Acid Production

Annual NOx Emission Rate

(HNO3 100% ; Base year = 1996)

0 1999 2000 2001 2002 2003 2004 2005 2006 2007

Figure 4 N2O in air emissions from nitric acid plants.

The above trend shows a general decrease of emissions over most of the years. In the reporting year 2007 there is an increase in NOx emissions, which is partly due to the fact that the survey was extended to more member companies. The industry will strive to reduce these emissions further in complying with Integrated Pollution, Prevention and Control (IPPC).

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EFMA’s ENERGY EFFICIENCY AND CO2 EMISSION BENCHMARK SURVEY IN AMMONIA PRODUCTION Ammonia is the basic starting material for all main nitrogen containing fertilizers. Production is based on the use of gas, oil or coal and represents by far the most energy consuming part of the fertilizer manufacturing processes. It is therefore important that ammonia production is as energy efficient as possible. Due to the high cost of energy in European countries compared to other regions of the world and due to strict environmental regulations in Europe, European ammonia producers are amongst the most energy efficient global companies with the lowest emissions. This is evident from regularly held European (EFMA) and Global (IFA) benchmarks.

The most recent Energy Efficiency and CO2 Emissions Benchmarking survey of EFMA members’ ammonia plants over the 2006-2007 operating period became available in December 2008.

EFMA’S PREPARATION FOR EMISSION TRADING AFTER 2012 The European Commission is preparing a revision of the Emission Trading Directive for the period starting in 2013. The fertilizer industry is deeply involved in the consultation process concerning ammonia and nitric acid plants. Auctioning of allowances to be given could play a larger role and the industry could therefore face the additional direct costs for the emission of CO2 equivalents. A study outsourced by EFMA to Pellervon has revealed that these costs will indeed be substantial.

The Effects of a Revision of the Emission Trading Directive for the period starting in 2013 on the European Nitrogen Fertilizer Industry

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EFMA is of the opinion that in the absence of an international binding agreement, which can level the playing field in carbon reduction, only a free allocation of emission rights to the European fertilizer industry, based on benchmarks, can safeguard its competitiveness and can prevent sizeable carbon leakage.

Benchmarks which are already available in EFMA (see EFMA’s Environmental Survey in Production and EFMA’s Energy Efficiency and CO2 Emission Benchmark Survey in Ammonia Production) will be used in the discussion with the Commission to decide on the allocation of free emission rights.

EFMA’S ACTIVITIES IN AGRICULTURE The European fertilizer industry has agreed to the goal set by the European Union to reduce greenhouse gas emissions by 20% by the year 2020.

In the agriculture area, where our products are used and which are outside the scope of the ETS activities, the EU target for GHG reduction, presented as “effort sharing”, is set at 10%. The potential for reducing greenhouse gas emissions from agriculture is certainly still important, and this is a domain where our agronomists develop best recommendations to reduce emissions when applying nitrogen fertilizers. As a practical contribution to this concern, EFMA has published a brief booklet presenting the main principles which should be adhered to when applying Good Fertilization Practice aimed at mitigating GHG emissions from soil: “Mind the… GAP – Good Agricultural Practice to Manage Greenhouse Gas Emissions in Crop Production”.

Furthermore, the recent food crisis has brought back attention to the first and essential mission of agriculture, feeding a global population expected to grow by 50% in the coming 40 years. In that respect, it is important to bear in mind that 48% of the current world population is fed thanks to mineral fertilizers: it is therefore important to remind policy makers and the whole of society, of the strategic role of mineral fertilizers for the well-being of mankind. For a large circulation and good understanding of this message, EFMA has published a short document, “Modern Agriculture Feeds the World… and helps protect the environment… and the climate”.

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The above documents were first presented at the EFMA conference “Agriculture, Fertilizer and Climate Change�, in February 2009.

Going further on the product level, EFMA has put particular emphasis on the necessity to consider the whole life-cycle when addressing GHG emissions: some fertilizers (especially urea) generate less GHG emissions during their production process compared to some other products (for example, ammonium nitrate) but, on the contrary, give rise to significantly more GHG emissions when they are applied to soil. As a first contribution to this important issue, EFMA has joined the EU LCA platform, a data base available to the public which gives reference data on energy use and GHG emissions for industrial products.

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L I S T O F E F M A’ S P U B L I C AT I O N S

Publications in the areas of: 1 Technology, Safety and the Environment 2 Agriculture and Environment are listed below. They are available from our website http://www.efma.org/ 1990

Hazardous Properties of Ammonia

1991

Recommendations for Safe Storage and Handling of Wet Process Phosphoric Acid (Phosphoric Acid Produced from Sulphuric Acid)

1992

Selected Tests Concerning the Safety Aspects of Fertilizers

1992

Handbook Safe Storage of Ammonium Nitrate Based Fertilizers (2007)

1996

Guidance for the Compilation of Safety Data Sheets for Fertilizer Materials (2008)

1998

Guidelines for Transporting Nitric Acid in Tanks

1998

Code of Best Agricultural Practices for Nitrogen

1999

Energy Recovery by Crops in Dependence on the Input of Mineral Fertilizers

2000

Code of Best Agricultural Practices for Urea

2000

Best Available Techniques

Booklet No. 1: Production of Ammonia Booklet No. 2: Production of Nitric Acid Booklet No. 3: Production of Sulphuric Acid (in collaboration with ESA) Booklet No. 4: Production of Phosphoric Acid Booklet No. 5: Production of Urea and Urea-Ammonium Nitrate Booklet No. 6: Production of Ammonium Nitrate and Calcium Ammonium Nitrate Booklet No. 7: Production of NPK Compound Fertilizers by Nitrophosphate Route Booklet No. 8: Production of NPK Compound Fertilizers by Mixed Acid Route

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2000

Understanding Phosphorus and its Use in Agriculture

2001

Sustainable Soil Management: An Achievable Goal

2002

11 Basic Safety Principles (EFMA/IFA)

2002

Harvesting Energy with Fertilizers

2003

Guidance for Safe Handling and Use of Non-conforming Fertilizers and Related Materials for Producers

2003

Leaflet Fertilizers and Fire

2003

Farming for the Future

2003

EFMA’s Position on Greenhouse Gases

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2003

The European Fertilizer Manufacturers’ Association’s position on the European Commission’s proposal for a Directive on the EU Emissions Trading (12.12.2003)

2003

Understanding Potassium and its Use in Agriculture

2004

Delivering Quality to your Food: The Benefits of Mineral Fertilizers

2004

Guidance for Safe Handling and Utilization of Non-conforming Solid Fertilizers and Related Materials for Fertilizer Importers, Distributors and Merchants

2004

Understanding Nitrogen and Use in Agriculture

2004

Guidance Relating to Sea Transport of Ammonium Nitrate Based Fertilizers,

2005

EFMA’s leaflet short version Guidance for Handling Non-conforming Ammonium Nitrate Based Fertilizers in Distribution Chain

2005

Guidance for Ammonia Transport by Rail (2007)

2005

Guidance for the Storage of Hot Ammonium Nitrate Solutions

2005

EFMA’s position paper on N2O Gases

2005

EFMA’s SHE Report October 2005

2006

Guidance for the Compatibility of Fertilizer Blending Materials

2006

Guidance for the UN Classification of Ammonium Nitrate Based Substances

2006

Sustaining Fertile Soils and Productive Agriculture

2006

Producing BioEnergy and Making the Best of European Land

2006

EFMA’s SHE Report October 2006

2007

Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizers

2007

Guidance for Ammonia Transport by Rail (English/German)

2007

EFMA’s SHE Report October 2007

2008

Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines

2008

Guidance for Inspection of Atmospheric Refrigerated Ammonia Storage Tanks

2008

Guidance for the Preparation of Safety Data Sheets for Fertilizer Materials

2009

Mind the… GAP – Good Agricultural Practice to manage Greenhouse Gas emissions in crop production

2009

Modern Agriculture Feeds the World… and helps protect the environment… and the climate

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Avenue E. van Nieuwenhuyse, 6 B-1160 Brussels Belgium Tel: +32 2 675 35 50 Fax: +32 2 675 39 61 E-mail: main@efma.be For more information about EFMA visit the web-site www.efma.org

european fertilizer manufacturers association