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e u r o p e a n f e r t i l i z e r m a n u f a c t u r e r s a s s o c i a t i o n

EFMA

SAFETY

HEALTH

&

ENVIRONMENT REPORT

APRIL 2009

APRIL 2009

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Copyright 2009-EFMA

EUROPEAN FERTILIZER MANUFACTURERS’ ASSOCIATION

AVE. E. VAN NIEUWENHUYSE, 6B-1160 BRUSSELS

BELGIUM

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CONTENTS

1

E F M A S A F E T Y H E A L T H A N D E N V I R O N M E N T R E P O R T

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 12

Environment 13

● EFMA’s Environmental Benchmark Survey in Production 14

● EFMA’s Ammonia Energy and CO2 Emissions Survey 16

● EFMA’s Preparation for Emission Trading Scheme 2012 16

● EFMA’s Activities in Agriculture 17

List of EFMA publications 19

Prepared by EFMA

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

2


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

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EFMA’S PRODUCT STEWARDSHIP PROGRAMME

3


The Product Stewardship Programme (PS) covers the ‘life cycle’ of fertilizers, describing the responsibilities offertilizer companies for the safety, security, health and environmental aspects in the whole supply chain startingfrom 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 withguidance on how to implement PS in their companies. It is also made publicly available on EFMA’s websitewww.efma.org. In addition, an audit manual to facilitate self-assessments has been made available for EFMAmembers. Audits of the members’ operations are carried out by an independent 3rd party (SGS) every threeyears, to confirm the members’ adherence to the requirements of the programme. All EFMA’s SHE activitiesform 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. Asmall number of companies that did not meet the challenging criteria of the PS requirements, were audited againin 2006. A second full audit was performed at the end of 2007/beginning of 2008. All companies passed theaudit and received their certificates.

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

EFMA updated the PS programme in the reporting year 2008. The updated version of the programme (version1.4) 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 nextfull 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

5


The safety of our employees, contractors and consumers gets our utmost attention. Towards this objectiveEFMA’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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6


EFMA’S SAFETY SURVEY IN PRODUCTION

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 reducethe LTIRs for employees and contractors continuously and for this purpose EFMA started to define targetfigures in 2006. The graph shows the EFMA average LTIR figures as trend lines from 1996 to the reportingyear 2008.

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

EFMA Lost Time Injury Rates 1997-2008

0.00

5.00

10.00

15.00

20.00

25.00

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

Year

LT

IR

Employees

Contractors

Combined

Dotted lines target 2009

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7


EFMA’s INCIDENT REPORTING

EFMA members report occupational accidents, environmental incidents and process related accidents that occurin the fertilizer industry in Europe and elsewhere. The information is stored in EFMA’s incident database. Thedatabase is regularly updated and contains more than 700 entries from a period of more than 90 years. The mostrecent version of the database (version 1.1, 01-08-2008) has been distributed to EFMA members.The purposeof 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 industryto share knowledge and to learn from these incidents. Selected topics are part of the annual EFMA SafetySeminar 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 “Firehazards and behaviour based aspects of safety”. Seventeen valuable presentations were given during the one anda 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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9


EFMA’S GUIDANCE DOCUMENTS

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

These documents are considered best practice standards for safe and environmentally correct operations. Thedocuments 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 wasissued:

Guidance for Inspection of and Leak Detection in Liquid Ammonia Pipelines


2008

GUIDANCE FOR INSPECTION OF AND LEAK DETECTIONIN LIQUID AMMONIA PIPELINES

The guidance focuses on pipelines with a diameter of at least 75 mm, transporting cold (close to the atmosphericboiling temperature of -33°C) or warm liquid ammonia. It deals with above-ground and underground (alsocalled buried) pipelines which are often located outside battery limits i.e. not inside ammonia or downstreamplants but between ammonia plants and harbour, tank storage, other plants or between sites. Thus, the guidancecovers 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 pipelineoperators in the EU. It does not cover fabrication inspection. The underlying intention is to maximise theoperational 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


2008

GUIDANCE FOR INSPECTION OF ATMOSPHERIC,REFRIGERATED AMMONIA STORAGE TANKS

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 liquidammonia storage tanks, which operate at or near atmospheric pressure and -33°C and are located in Europe. TheGuidance focuses on major periodic inspection, covering its periodic frequency, method of inspection andregular monitoring between major inspections. It does not cover fabrication inspection. In considering theinspection frequency it describes as an option a risk based inspection (RBI) approach requiring the evaluation ofthe probability and consequences of failure for each individual tank. The underlying intention is to maximisethe 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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HEALTH

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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 employeesregarding the safety of operations and any health hazards associated with raw materials, chemicals, productionprocesses and finished products. We offer information to our customers regarding the safe handling and use offertilizers.

CHEMICAL POLICY

REACH

The EFMA Task Force Registration, Evaluation and Authorisation of CHemicals (REACH) serves as adiscussion platform for questions and queries that arise from REACH. The TF has also preparedrecommendations 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 thepreparatory work which is done in the substance committees whilst technical committees assist in technicalmatters. The FARM consortium covers some 30 substances and further information can be found at EFMA’swebsite: 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

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

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The above-mentioned directives have been superseded by a new far-reaching regulation, Regulation (EC) No1907/2006, widely known as REACH. This Regulation now defines SDS requirements and also introduces newrequirements. It has, therefore, become necessary to revise the 1996 EFMA guidance with a view to facilitatecompliance with the current REACH legislation. It has been decided to split the original guidance of 1996 intotwo separate complimentary publications: the first to give guidance on the SDS requirements to comply withREACH and the second to provide jointly agreed typical model SDSs for a number of fertilizer materials. Thefirst document has been published as an EFMA guidance and was issued in 2008. The second guidance, jointlyagreed 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


2 008

GUIDANCE FOR THE PREPARATION OF SAFETY DATASHEETS FOR FERTILIZER MATERIALS

Version

Issue date

1 Identification of the substance/preparation and of the company/undertaking

2

3

CAS no. EC no. % (w/w)

CAS no. EC no. % (w/w)

4

Conforms to 1907/2006/EC

Safety Data Sheet

Hazardous ingredients

Other ingredients

Chemical name

Chemical name

EU index number (Annex 1)

Use of the substance/preparation

Company e-mail for SDS

Emergency telephone

First aid measures

Composition/information on ingredients

Hazards identification

Skin contact

Environmental hazards

Health hazards

Classification

Physical and chemical hazards

Note to physician

Eye contact

Other

General

Ingestion

Inhalation

EC no. means EINECS or ELINCS number.

Classification

Synonyms

Chemical formula

CAS No.

EC No

Company name

Company address

Company telephone

Product name

Commercial product name

Common chemical name

REACH or National Product Registration No.

Firm logo

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ENVIRONMENT

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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 agriculturalpractices.

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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 anddisplayed graphically. This enables EFMA to monitor the improvements and other changes in the emissionsfrom the European fertilizer industry and allows all members to compare their plants to other participants in thesurvey.

The TESC encourages open discussion among its members in order to improve the environmental performanceof European fertilizer production. In August 2007 the EU Best Available Techniques (BAT) ReferenceDocument Ammonia, Acids and Fertilizers was issued by the Commission. This document serves as guidancefor National Authorities to set permits to operate. However, BAT threshold values are not necessarily standardfor 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 andsuccess (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).

NOx to Air Emission Rate From EFMA Ammonia Plants

(Base year = 1996)

0

20

40

60

80

100

120

1996 1997 1998 19992000 2001 2002 20032004 2005 2006 2007

An

nu

al N

Ox

Em

iss

ion

Ra

te

0

20

40

60

80

100

120T

ota

l NH

3 P

rod

uc

tio

n

Emission Rate (kg emission pertonne produced) Base year is100%Total Production in indices

Figure 2 NOx in air emissions from ammonia plants.

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NOx to Air Emission Rate From EFMA Nitric Acid Plants

(HNO3 100%; Base year = 1996)

0

20

40

60

80

100

120

1996 1997 1998 19992000 2001 2002 20032004 2005 2006 2007

An

nu

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Ox

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100

120

To

tal N

itri

c A

cid

Pro

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ctio

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Figure 3 NOx in air emissions from nitric acid plants.

N2O to Air Emission Rate From EFMA Nitric Acid Plants

(HNO3 100%; Base year = 1996)

0

20

40

60

80

100

120

1999 2000 2001 2002 2003 2004 2005 2006 2007

An

nu

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Ox

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iss

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40

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80

100

120

To

tal N

itri

c A

cid

Pro

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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 thereis an increase in NOx emissions, which is partly due to the fact that the survey was extended to more membercompanies. 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 EMISSIONBENCHMARK SURVEY IN AMMONIAPRODUCTION

Ammonia is the basic starting material for all main nitrogencontaining fertilizers. Production is based on the use of gas,oil or coal and represents by far the most energy consumingpart of the fertilizer manufacturing processes. It is thereforeimportant that ammonia production is as energy efficient aspossible. Due to the high cost of energy in Europeancountries compared to other regions of the world and due tostrict environmental regulations in Europe, Europeanammonia producers are amongst the most energy efficientglobal companies with the lowest emissions. This is evidentfrom regularly held European (EFMA) and Global (IFA)benchmarks.

The most recent Energy Efficiency and CO2 EmissionsBenchmarking survey of EFMA members’ ammonia plantsover the 2006-2007 operating period became available inDecember 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 in2013. The fertilizer industry is deeply involved in the consultation process concerning ammonia and nitric acidplants. Auctioning of allowances to be given could play a larger role and the industry could therefore face theadditional direct costs for the emission of CO2 equivalents. A study outsourced by EFMA to Pellervon hasrevealed that these costs will indeed be substantial.

The Effects of a Revision of the Emission Trading Directive for the period starting in 2013 on theEuropean 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 playingfield in carbon reduction, only a free allocation of emission rights to the European fertilizer industry, based onbenchmarks, can safeguard its competitiveness and can prevent sizeable carbon leakage.

Benchmarks which are already available in EFMA (see EFMA’s Environmental Survey in Production andEFMA’s Energy Efficiency and CO2 Emission Benchmark Survey in Ammonia Production) will be used in thediscussion 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 gasemissions by 20% by the year 2020.

In the agriculture area, where our products are used andwhich are outside the scope of the ETS activities, the EUtarget for GHG reduction, presented as “effort sharing”, isset at 10%. The potential for reducing greenhouse gasemissions from agriculture is certainly still important, andthis is a domain where our agronomists develop bestrecommendations to reduce emissions when applyingnitrogen fertilizers. As a practical contribution to thisconcern, EFMA has published a brief booklet presentingthe main principles which should be adhered to whenapplying Good Fertilization Practice aimed at mitigatingGHG emissions from soil: “Mind the… GAP – GoodAgricultural Practice to Manage Greenhouse Gas Emissionsin Crop Production”.

Furthermore, the recent food crisis has brought backattention 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 tobear in mind that 48% of the current world population is fed thanks to mineral fertilizers: it is thereforeimportant to remind policy makers and the whole of society, of the strategic role of mineral fertilizers forthe well-being of mankind. For a large circulation and good understanding of this message, EFMA haspublished a short document, “Modern Agriculture Feeds the World… and helps protect the environment… andthe climate”.

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The above documents were first presented at the EFMA conference “Agriculture, Fertilizer and ClimateChange”, in February 2009.

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

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LIST OF EFMA’S PUBLICATIONS

19


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

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 andRelated 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’sproposal 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 RelatedMaterials 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 BasedFertilizers 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


2007 Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizers

2007 Guidance for Ammonia Transport by Rail (English/German)


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 incrop production

2009 Modern Agriculture Feeds the World… and helps protect the environment… and the climate

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Avenue E. van Nieuwenhuyse, 6B-1160 BrusselsBelgiumTel: +32 2 675 35 50Fax: +32 2 675 39 61E-mail: [email protected]

For more information about EFMAvisit the web-site www.efma.org


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