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BAT - Best available technique

BAT - BREF Best Available Techniques REFerence Document

Since 29 March 2004 the EWPA is a member of the TWG (technical work group) "Surface treatment using solvents" which is organised by the EIPPCB bureau in Seville, Spain. The TWG consists of representatives of the several EU Environmental Bodies, Consultants, Industry and NGOs (non government organisation). They work out a BREF document in order to produce a new EU directive regarding the protection of environment. The following information will guide you through the way of a BAT (best available technique) concept becoming a BREF document.

Up to now, only three printing associations from Europe have been working on this project. Since the EWPA joined this TWG recently, it is possible to attract the attention to waterless offset being a BREF. That means that offset printing industry will do its job for a sustainable and clean environment in the future.

 

The IPPC directive 

What?

The EU has got common rules on permitting for industrial installations which are put together in the IPPC directive (1996). IPPC is for "Integrated Pollution Prevention and Control". This directive intends to minimize pollution of different entries within the EU. All industrial installations that are covered by Annex I need an official permission of the member states.

Without those permissions one is not allowed to run the installations. Permits must be based on the concept of BAT. In many cases, following BAT has a positive effect on the environmental circumstances but sometimes the adjustment on this standard causes high investments. In order to save the number of jobs while installations are being adapted to meet the requirements (BAT), the EU has set a time limit of 11 years since the directive came into effect.

 

Why?

European production methods and consumption are not sustainable. Besides the improvements that have been made in the past centuries referring to industrial pollution, industrial production still accounts for a considerable share of overall pollution in Europe. Chemicals that are used in every-day life and traffic also have a strong impact on the environment but industrial

pollutants such as greenhouse gases, acidifying substances, volatile organic compounds and waste are of the same danger.

That is why aiming at sustainable production to reduce industrial pollution is of big importance. It is obvious that it will be easier to change production process of let's say 20,000 industrial companies in Europe than the consumption behaviour of a hundred million citizens living in the EU. Standardisations like BREF's shall avoid so-called environmental-dumping. Companies shall no longer move their production to other countries within the EU where environmental demands are lower than in their origin country.

 

How?

The directive (see Article 249 of the Treaty of the European Community) is a good method for the EU to achieve harmonised permitting procedures. It contains basic rules to implement integrated permits. Being integrated means that the permits have to consider all effects of the industrial installation on the environment such as pollution of air, water and land, waste, choice and use of raw material, energy efficiency, noise, technical fault prevention, risk management et cetera.

To make sure that the permitting procedures are based upon the best available techniques, the authorities need help to find out what is the best available technique. In Annex IV of the directive the sectors one has to consider when trying to find out what is BAT are listed. The European Commission initiates an exchange of information among the expert involved such as EU, Industry and Environmental NGOs.

Coordination of the technical work is done by the EIPPCB in Seville. It is worked on approximately 30 sectors all geared towards Annex I of the directive. Every sector requires roundabout two years to finish a BREF-note. All notes will be completed at the end of 2005. Documents that are already finished can be downloaded from the server of EIPPCB or the IPPC-

homepage of the European Commission.

They are also available on CD. Soon, it will also be possible to download them from this homepage. BREF-notes can only be regarded as some kind of assistance for the permitting authorities. In particular case the authorities have the power to decide about the permission. On the one hand directive's 9th article says that, as appropriate, technical properties, local environmental conditions and site have to be taken into account. On the other hand, emission limit values (waste combustion and Grossfeueranlagen ) are already prescribed in some sectors and the possibility of enlargement exists (see Article 18 of directive).

Politicians, local authorities and administration and public need to be informed much better about the bad influence on environment of every single industrial installation. For this purpose a European Pollution? Emission Register (EPER) has to be introduced.

 

When?

The fifteen Member States had to adopt the laws, regulations and administrations covered by the directive to their national law by the end of October 1999. Whatever the case may be some of the Member States still have not informed the European Commission of having entered the directive into force or have only entered it partially (e.g Ireland and Luxembourg). Since October 1999 one has to make sure that new installations or fundamental changes in existing installations - which may increase pollution - have to correspond to the directive.

Remember: there is no direct effect on other installations that already exist. Another 8 years of grace are granted to make the installations meet the requirements.

 

Where?

For all 15 Member States equal regulations are in force. With the broadening of the EU the Accession Countries have tried to make their permitting procedures fit to the directive. Some of the countries had remarkable success others asked for temporary solutions during the process of accession.

 

Who?

The IPPC directive affects:

  • Permit authorities (national, regional and local) of the 15 (present) Member States of the EU whose permits are based on the concept of BAT.
  • The European Commission and the Environmental Committee (Department D.3 "Installations and Implementations") have to make sure that all 15 Member States meet the requirements.
  • Experts in the Member States (mainly from national environmental authorities and similar associations) who participate at the exchange of information concerning BAT.
  • Experts in Industry who take part at the exchange of information concerning BAT.
  • Environmental Organisations who participate at the exchange of information concerning BAT.
  • The Information Exchange Forum (IEF) which organises the exchange of information together with the European Commission. Representatives of the Member States, Industry, Environmental Organisations and the European Commission form the IEF.
  • The EIPPCB in the EU Joint Research Centre in Seville, Spain.
  • The IPPC experts and the IMPEL network.
  • Both forum support the communication among the several national authorities about topics which deal with implementation and performance of the directive.

 

Last but not least:

  • The public who is given access to the following (see Article 15):

a) Application forms for Permit

b) Permissions

c) Reports of supervision

d) EPER (European Pollution Emission Register)

The BREF-notes are going to be published on this homepage, too. Large public interest and active support are needed for further development of new environmental standards in industry.

The 2003/35/EG directive ensures that practical information of the permitting procedures is made available to the public.

 

EWPA - European Waterless Printing Association e. V.