BVAA - Influencing the future of the valve industry
Photo credit: James Walker
Peter Dix CEng MIMechE, Principal Technical Consultant and Chief Lecturer
BVAA Technical Services work over much of 2023 has been dominated by two exceptional regulatory issues with the potential to significantly affect our industry both in the UK and further afield.
Through its unique position representing the UK’s valve and actuator supply industry, the BVAA has been working to ensure that members are not only informed about these issues, but also have a collective voice to ensure that the authorities understand the potential impact of their proposals.
Use of the CE Mark extended indefinitely
The BVAA has been lobbying UK Government for several years about the damaging effects of product regulations that force valve and actuator manufacturers to make different products for sale in Great Britain compared to the rest of the EU. In August, the UK Government announced that the CE mark could continue to be used indefinitely to indicate compliance with regulatory requirements in the GB market.
This positive outcome comes as a result of direct, all be it belated, UK Government consultation with BVAA and other industry bodies. The BVAA contributed to the dialogue that ensured the change to this aspect of Brexit legislation allowing the same products to be sold across both UK and European markets resulting in lower costs and retained competitiveness for the UK valve and actuator industry.
Since the August announcement the UK Government has continued to consult with industry as they continue to consider development of regulations that might provide an advantage to UK PLC. The BVAA will continue to represent its members in these activities to ensure that the views of the UK valve and actuator industry are heard by the policy makers.
EU Proposal to ban PTFE and FKM materials in valves
The acronym PFAS entered our industry’s vocabulary when the BVAA issued a Hot Spot at the beginning of 2022 warning of the proposal to ban the use of Polyfluoroalkyl substances in the EU. PFAS manufacturers report that vital fluoropolymers are used in a vast range of components that touch 50% of the EU’s $16 trillion economy. PTFE and FKM is typically used for valve seats, bearings, seals and diaphragms that fall into this PFAS group and BVAA members’ data confirmed that 90% of industrial valves sold into the EU contain the material.
If the restriction proposal is implemented as written, it is likely to have a profound effect on the valve industry and the competitiveness of manufacturing in the EU in general, with real potential for dire socio-economic consequences for the region. BVAA members data indicates that the cost of re-qualifying replacement non-PFAS materials for use in the EU will be significant, repeating the necessary fire and fugitive emissions type tests alone will exceed $268M requiring over 36,600 testing days.
The main reason for the proposal to ban PFAS is that they do not break down and are environmentally persistent, properties that have led the popular press to describe PFAS as “forever plastics”. The restriction proposal on PFAS was submitted to the European Chemical Agency (ECHA) in March and a 6 month public consultation commenced which ended in September.
The BVAA formed a PFAS TEG group and set about collecting members’ views and usage data specific to valves to submit to the consultation. The BVAA response also identified how vital PFAS are to society and their unique place in driving continuing progress towards reducing emissions and energy use as well as developing new zero carbon technology.
PFAS used in industrial valves are not dangerous to health and do not enter the environment whilst the valve is in use. Only the end-of-life disposal of the material presents a potential issue for the environment, and this can be eliminated by simply improving waste management regulations and requiring re-cycling or incineration, slim grounds to justify a total ban on their use.
The ECHA consultation closed in September and resulted in more than 5,500 responses, many relating to the use of fluoropolymers, demonstrating significant objections to the proposal. The next milestone, a 60 day public consultation period to respond to the published ECHA draft opinion, is unlikely to begin until the second half of 2024 at the earliest. The BVAA will remain engaged with this issue and contribute alongside other trade associations to maintain awareness and shape public opinions over the coming months.
Maintain the volume of our collective voice
It seems likely that regulation changes such as these will remain on the BVAA technical agenda for some time to come. A key role of the BVAA is to represent the collective views of its members creating a significant voice to influence the lawmakers and regulators by ensuring that they understand the consequences of their proposals.
I would like to thank all those members who have participated in BVAA technical meetings during the year. 2023 has been an exceptional year demonstrating that it has never been more important for members to actively contribute to BVAA technical activities and become a part of the voice seeking to shape the future of our industry.
Author: Peter Dix CEng MIMechE, Principal Technical Consultant and Chief Lecturer
Published: 30th October 2023
What is it? On July 19th 2023 the new EU Machinery Regulation 2023/1230 ...
LinkedIn reminded me the other week that I’d reached my 20th anniversary ...
The recent planned shutdowns of two major refineries for up to two months has ...
The BVAA’s biggest annual event is now SOLD OUT! This year, it will take ...
The NEW Safety Valves Manual is a brand-independent technical publication, ...
ROSS Pneumatrol is delighted to announce that it has received a patent for ...
MAXIM Engineering Software Consultancy, part of PDL Engineering Group, work ...
PDL Engineering Group are experts in applying advanced engineering software to ...