4 th ECENA Exchange Programme for The Environmental Enforcement Agencies and Inspectorates

1. 4th ECENA Exchange Programme for The Environmental Enforcement Agencies and Inspectorates October 19 – 21, 2005 Cluj Napoca, Romania INSPECTAN Environmental inspection guidelines for tanning industry Alessandra Burali

2. BACKGROUND OF INSPECTAN Within the framework of the activities related to the knowledge of the environmental pressure of industrial cycles, APAT has started, in 2002, a comprehensive study of the tanning sector. The study was leaded by the Regional Agency of Venice (ARPA Veneto) with the participation of the ARPA Tuscany and ARPA Campania (the three major tanning districts in Italy).

3. The study, together with the existing BREF on tanning, will provide the basis and information needed to perform the proposed project on INSPECTAN OBJECTIVE OF INSPECTAN Provide a set of inspection guidelines based on the understanding of the main threats caused by the tanning industry.

4. FINAL PRODUCTS OF INSPECTAN A report describing basic principles for understanding potential environmental threats caused by the tanning industry A set of principles, guidelines and recommendations based on selected best practices and case studies which may go beyond minimum inspection requirements.

5. PARTICIPANTS The manager executor is ARPA Veneto (ARPAV) The project team and participants consisted of: Members of APAT ARPAV, ARPA Tuscany (ARPAT) France, Germany, Latvia, Poland, Spain and Sweden

6. BUDGET The “IMPEL budget” available for the project: Travel Accommodation Refreshment and lunch

7. A questionnaire was sent to the participants before the meeting • Information of the specific industrial sector • Information on the permitting system and legislation(s) • Information on inspections and controls

8. MEETINGS 3 meetings were held of 1 ½ or 2 days each 1st meeting: Venice from 23 - 24 September 2004 • Presentation of the Italian study • Presentation of the tanning industry system/cycle by the participants of the other Member States • Discussion and consolidation of the questionnaire

9. MEETINGS 2nd meeting: Florence from 31 January – 1 February 2005 • Discussion of the results of the analysis of the questionnaire • Discussion for the orientation for the report and guidelines (only methodology of inspections) • Discussion and definition for further need of information

10. MEETINGS 3rd meeting: Rome in 26 – 27 May 2005 • Discussion of the final draft of the report • Discussion of the draft of the guidelines Between the meetings exchange of information was being held by e-mails The Italian Tanning Industrial Associations (for Industries and for Craftsmanship) were involved in the project

11. The FINAL REPORT CONCERNING THE PRODUCTION CYCLE in the tanning industry is divided in three parts: part one:economical and productive analysis of the tanning sector • Number and dimension of tanning plants; According to the information received, Italy and Poland have the highest number of tanning activities. Spain, France, Germany, Sweden, Latvia follow in order of importance

12. Raw skin treated and final products, import/export market; Tanning concentrates in general on hides or skins from bovines, sheep, goats. France has relevant activities on skins of exotic/wild species. Sweden processes significant quantities of reindeer hides. Inventories are heterogeneous and do not allow for calculations of the amounts of finished hides/skins, or to ascertain final uses.

13. geographical dislocation (ex. Links and descriptions with the surrounding environment of the plant, peculiarity of the plant); Tanneries appear invariably associated to rivers or streams, providing water to the various operations of the tanning cycle

14. part two: comparison of the production cycle and mass and energy flows used in tanning industry • differences of technologies used in the participating countries; • principal environmental problems linked to tanning production cycle in each participant country; • comparison on the different legislation limits used for the same pollutants in each country; • comparison on the different legislation limits used for the same pollutants in each country;

15. solvents consumption • chemical products • water consumption • waste water discharge • energy consumption • releases into air • solid waste

16. part three: permitting system and legislation • permitting system for IPPC and non IPPC plants; • comparison on the different legislation limits used for the same pollutants in each country;

17. GUIDELINES and recommendations for inspections in the tanning industry Objectives • Describe different approaches to control activities of the tanning production sector • Supply the inspectors with instruments that can help them to plan and perform an inspection • Description of critical aspects of the product and process of the tanning cycle • Description of specific control activities that have to be applied to tanning industries

18. Approach to environmental controls

19. Planning of inspections • a table to highlight the critical aspects of the plant. This should detail the production cycle and the environmentally sensitive aspects of the neighbourhood; • some tables giving details of the inspection activities which are adequate for the inspection of the existing production cycle and relevant environmental aspects. • advice on the specific checks to be realized during the inspections

20. Identification of critical aspects of the product and process of the tanning cycle

21. Inspection activities According to recommendation 331/2001/EC and the BREF document on monitoring, inspections have been divided into 3 principal activities: • Administrative controls • Technical-operational controls • Analytical controls A table describes specific administrative, technical, operational and analytical control activities for each part of the process cycle.

22. Thank you