4th ECENA Exchange Programme for The Environmental Enforcement Agencies and

InspectoratesOctober 19 – 21, 2005Cluj Napoca, Romania

INSPECTAN Environmental inspection guidelines for tanning

industry

Alessandra Burali

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).

The study, together with the existing BREF on tanning, will provide the basis and information needed to perform the proposed project on INSPECTAN

Provide a set of inspection guidelines based on the understanding of the main threats caused by the tanning industry.

OBJECTIVE OF INSPECTAN

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.

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

The “IMPEL budget” available for the project:

Travel

Accommodation

Refreshment and lunch

BUDGET

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

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

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

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

part one: economical and productive analysis of the tanning sector

The FINAL REPORT CONCERNING THE PRODUCTION CYCLE in the tanning industry is divided in three parts:

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

Number and dimension of tanning plants;

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.

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

comparison on the different legislation limits used for the same pollutants in each country;

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;

solvents consumption

chemical products

water consumption

energy consumption

waste water discharge

solid waste

releases into air

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;

Description of specific control activities that have to be applied to tanning industries

Objectives

GUIDELINES and recommendations for inspections in the tanning industry

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

Approach to environmental controls

Indirect approach Site specific approach

Many plants in district area Few or isolated plants

Incomplete cycle plants Complete cycle plants

Monitoring quality of each environmental aspect

Monitoring environmental performance of the single plant

Single environmental aspect inspections

Integrated inspections

Face environmental emergencies

Face routine control activities

Planning of inspections

advice on the specific checks to be realized during the 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.

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

Process Unit Waste water Waste Air emission

Energy consumption

Chemicals

Environmental Risks Noise

Hide and skin storage and beamhouse operations

Trimming   • parts of the raw hidcs (trimmings)

        not particularly

relevant

Curing & Storing

  • salt      

Soaking • BOD, COD, SS, DS from soluble proteins • salts • org -N • AOX • emulsificis. surtaclants. biotides

    relevant for use of pollutant chemicals

Soil pollution; Ground and

surface water pollution

Fleshing BOD. COD. SS. DS from fat, grease

• fat, connective tissue, lime

   

Liming & Unhairing

• sulphides, • BOD, COD, SS, DS• lime • high pH •

org.-N, NHj-N

• hair • sludge from liming effluents (waste water treatment)

• sulphides • odour relevant for use of pollutant chemicals

Rinsing after Unhairing

     

Splitting • lime split • trimmings

   

Inspection activities

According to recommendation 331/2001/EC and the BREF document on monitoring, inspections have been divided into 3 principal activities:

A table describes specific administrative, technical, operational and analytical control activities for each part of the process cycle.

Administrative controls

Technical-operational controls

Analytical controls