# Commission Implementing Decision of 11 February 2013 establishing the best available techniques (BAT) conclusions under Directive            2010/75/EU of the European Parliament and of the Council on industrial emissions for the tanning of hides and skins (notified            under document C(2013) 618) (Text with EEA relevance) (2013/84/EU)         

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U.K.

# Commission Implementing Decision

# of 11 February 2013

# establishing the best available techniques (BAT) conclusions under Directive 2010/75/EU of the European Parliament and of                        the Council on industrial emissions for the tanning of hides and skins                     

# (notified under document C(2013) 618)

# (Text with EEA relevance)

# (2013/84/EU)

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions                           (integrated pollution prevention and control)(1), and in particular Article 13(5) thereof,                        

Whereas:

(1)Article 13(1) of Directive 2010/75/EU requires the Commission to organise an exchange of information on industrial emissions                              between it and Member States, the industries concerned and non-governmental organisations promoting environmental protection                              in order to facilitate the drawing up of best available techniques (BAT) reference documents as defined in Article 3(11) of                              that Directive.

(2)In accordance with Article 13(2) of Directive 2010/75/EU, the exchange of information is to address the performance of installations                              and techniques in terms of emissions, expressed as short- and long-term averages, where appropriate, and the associated reference                              conditions, consumption and nature of raw materials, water consumption, use of energy and generation of waste and the techniques                              used, associated monitoring, cross-media effects, economic and technical viability and developments therein and best available                              techniques and emerging techniques identified after considering the issues mentioned in points (a) and (b) of Article 13(2)                              of that Directive.

(3)‘BAT conclusions’ as defined in Article 3(12) of Directive 2010/75/EU are the key element of BAT reference documents and lay                              down the conclusions on best available techniques, their description, information to assess their applicability, the emission                              levels associated with the best available techniques, associated monitoring, associated consumption levels and, where appropriate,                              relevant site remediation measures.

(4)In accordance with Article 14(3) of Directive 2010/75/EU, BAT conclusions are to be the reference for setting permit conditions                              for installations covered by Chapter II of that Directive.

(5)Article 15(3) of Directive 2010/75/EU requires the competent authority to set emission limit values that ensure that, under                              normal operating conditions, emissions do not exceed the emission levels associated with the best available techniques as                              laid down in the decisions on BAT conclusions referred to in Article 13(5) of Directive 2010/75/EU.

(6)Article 15(4) of Directive 2010/75/EU provides for derogations from the requirement laid down in Article 15(3) only where                              the costs associated with the achievement of the emission levels associated with the BAT disproportionately outweigh the environmental                              benefits due to the geographical location, the local environmental conditions or the technical characteristics of the installation                              concerned.

(7)Article 16(1) of Directive 2010/75/EU provides that the monitoring requirements in the permit referred to in point (c) of                              Article 14(1) of the Directive are to be based on the conclusions on monitoring as described in the BAT conclusions.

(8)In accordance with Article 21(3) of Directive 2010/75/EU, within four years of publication of decisions on BAT conclusions,                              the competent authority is to reconsider and, if necessary, update all the permit conditions and ensure that the installation                              complies with those permit conditions.

(9)Commission Decision of 16 May 2011 establishing a forum for the exchange of information pursuant to Article 13 of Directive                              2010/75/EU on industrial emissions(2) established a forum composed of representatives of Member States, the industries concerned and non-governmental organisations                              promoting environmental protection.

(10)In accordance with Article 13(4) of Directive 2010/75/EU, the Commission obtained the opinion(3) of that forum on the proposed content of the BAT reference document for the tanning of hides and skins on 13 September 2012                              and made it publicly available.

(11)The measures provided for in this Decision are in accordance with the opinion of the Committee established by Article 75(1)                              of Directive 2010/75/EU,

HAS ADOPTED THIS DECISION:

# Article 1U.K.

The BAT conclusions for the tanning of hides and skins are set out in the Annex to this Decision.

# Article 2U.K.

This Decision is addressed to the Member States.

Done at Brussels, 11 February 2013.

*For the Commission*                            

Janez Potočnik                            

*Member of the Commission*                            

## ANNEXU.K.**BAT CONCLUSIONS FOR THE TANNING OF HIDES AND SKINS**

### SCOPEU.K.

These BAT conclusions concern the following activities specified in Annex I to Directive 2010/75/EU, namely:
          -  6.3
*Tanning of hides and skins where the treatment capacity exceeds 12 tonnes of finished products per day,*                                  
 
          -  6.11
*Independently operated treatment of waste water not covered by Council Directive 91/271/EEC* (4) *and discharged by an installation* undertaking activities covered under 6.3 above.                                 
 

Unless stated otherwise the BAT conclusions presented can be applied to all installations subject to these BAT conclusions.

Other reference documents which are relevant for the activities covered by these BAT conclusions are the following:

The techniques listed and described in these BAT conclusions are neither prescriptive nor exhaustive. Other techniques may                     be used that ensure at least an equivalent level of environmental protection.                  

### DEFINITIONSU.K.

For the purposes of these BAT conclusions, the following definitions apply:

#### 1.1.*General BAT conclusions for the tanning of hides and skins*U.K.

##### 1.1.1.*Environmental management systems*U.K.

###### 1.In order to improve the overall environmental performance of a tannery, BAT is to implement and adhere to an environmental                        management system (EMS) that incorporates all of the following features:U.K.

commitment of the management, including senior management;

definition of an environmental policy that includes the continuous improvement of the installation by the management;

planning and establishing the necessary procedures, objectives and targets, in conjunction with financial planning and investment;

implementation of procedures paying particular attention to:

structure and responsibility;

training, awareness and competence;

communication;

employee involvement;

documentation;

efficient process control;

maintenance programmes;

emergency preparedness and response;

safeguarding compliance with environmental legislation;

checking performance and taking corrective action, paying particular attention to:

monitoring and measurement (see also the reference document on the general principles of monitoring);

corrective and preventive action;

maintenance of records;

independent (where practicable) internal and external auditing in order to determine whether or not the EMS conforms to planned                                       arrangements and has been properly implemented and maintained;                                    

review of the EMS and its continuing suitability, adequacy and effectiveness by senior management;

following the development of cleaner technologies;

consideration for the environmental impacts from the eventual decommissioning of the installation at the stage of designing                              a new plant, and throughout its operating life;                           

application of sectoral benchmarking on a regular basis.

Specifically for the tanning of hides and skins, it is also important to consider the following potential features of the                              EMS:                           

to facilitate decommissioning, the maintenance of records of the locations on the site where particular process steps are                              carried out;                           

other items listed under BAT conclusion 2.

###### **Applicability**U.K.

The scope (e.g. level of details) and nature of the EMS (e.g. standardised or non-standardised) will generally be related                     to the nature, scale and complexity of the installation, and the range of environmental impacts it may have.                  

##### 1.1.2.*Good housekeeping*U.K.

###### 2.In order to minimise the environmental impact of the production process, BAT is to apply the principles of good housekeeping                        by applying the following techniques in combination:U.K.

careful selection and control of substances and raw materials (e.g. quality of hides, quality of chemicals);

input-output analysis with a chemical inventory, including quantities and toxicological properties;

minimisation of the use of chemicals to the minimum level required by the quality specifications of the final product;

careful handling and storage of raw materials and finished products in order to reduce spills, accidents and water wastage;

segregation of waste streams, where practicable, in order to allow for the recycling of certain waste streams;

monitoring of critical process parameters to ensure stability of the production process;

regular maintenance of the systems for the treatment of effluents;

review of options for the reuse of process/washing water;

review of waste disposal options.

#### 1.2.*Monitoring*U.K.

##### 3.BAT is to monitor emissions and other relevant process parameters, including those indicated below, with the given associated                        frequency and to monitor emissions according to EN standards. If EN standards are not available, BAT is to use ISO, national                        or other international standards that ensure the provision of data of an equivalent scientific quality.U.K.

#### 1.3.*Minimising water consumption*U.K.

##### 4.In order to minimise water consumption, BAT is to use one or both of the techniques given below.U.K.

The review of options for the reuse of process/washing water is part of an Environmental Management System (see BAT 1) and                     of the principles of good housekeeping (see BAT 2).                  

###### **The BAT-associated consumption levels for water**U.K.

See Table 1 (for bovine hides) and Table 2 (for sheepskins).

###### *Table 1*

**BAT-associated consumption levels for water for the processing of bovine hides**

###### *Table 2*

**BAT-associated consumption levels for water for the processing of sheepskins**

#### 1.4.*Reduction of emissions in waste water*U.K.

##### 1.4.1.*Reduction of emissions in waste water from beamhouse process steps*U.K.

###### 5.In order to reduce the pollutant load in the waste water before effluent treatment arising from the beamhouse process steps,                        BAT is to use an appropriate combination of the techniques given below.U.K.

##### 1.4.2.*Reduction of emissions in waste water from tanyard process steps*U.K.

###### 6.In order to reduce the pollutant load in the waste water before effluent treatment arising from the tanyard process steps,                        BAT is to use an appropriate combination of the techniques given below.U.K.

##### 1.4.3.*Reduction of emissions in waste water from post-tanning process steps*U.K.

###### 7.In order to reduce the pollutant load in the waste water before effluent treatment arising from the post-tanning process steps,                        BAT is to use an appropriate combination of the techniques given below.U.K.

##### 1.4.4.*Other reductions of emissions in waste water*U.K.

###### 8.In order to prevent the emission of specific pesticides in waste water, BAT is to only process hides or skins which have not                        been treated with those materials.U.K.

###### **Description**U.K.

The technique consists in the specification in supply contracts of materials free from pesticides that are:
          -  listed in Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental quality                           standards in the field of water policy(5),                         
          -  listed in Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic                           pollutants(6),                         
          -  classified as carcinogen, mutagen or reprotoxic according to Regulation (EC) No 1272/2008 of the European Parliament and of                           the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures(7).                         

Examples include DDT, cyclodiene pesticides (aldrin, dieldrin, endrin, isodrin), and HCH including lindane.

###### **Applicability**U.K.

Generally applicable to tanneries within the constraints of controlling the specifications given to non-EU hides and skins                     suppliers.                  

###### 9.In order to minimise the emissions of biocides in waste water, BAT is to process hides or skins only with biocidal products                        approved in accordance with the dispositions given by Regulation (EU) No 528/2012 of the European Parliament and of the Council                        of 22 May 2012 concerning the making available on the market and use of biocidal products(8).U.K.

#### 1.5.*Treatment of emissions to water*U.K.

##### 10.In order to reduce emissions to receiving waters, BAT is to apply waste water treatment comprising an appropriate on-site                        and/or off-site combination of the following techniques:U.K.

mechanical treatment;

physico-chemical treatment;

biological treatment;

biological nitrogen elimination.

###### **Description**U.K.

The application of an appropriate combination of the techniques described below. The combination of techniques can be implemented                     on site and/or off site, in two or three stages.                  

###### **BAT-associated emission levels**U.K.

See Table 3. BAT-AELs apply for:

direct waste water discharges from tanneries on-site waste water treatment plants;

direct waste water discharges from independently operated waste water treatment plants covered under Section 6.11 in Annex                              I to Directive 2010/75/EU treating waste water mostly from tanneries.                           

###### *Table 3*

**BAT-AELs for direct discharges of waste water after treatment**

##### 11.In order to reduce the chromium content of waste water discharges, BAT is to apply on-site or off-site chromium precipitation.U.K.

###### **Description**U.K.

See BAT 10, technique b.

The efficiency of chromium precipitation is higher in the case of segregated, concentrated chromium-bearing streams.

###### **Applicability**U.K.

Generally applicable for on-site and/or off-site treatment of waste water effluents of tanneries carrying out chromium tanning                     and/or retanning.                  

###### **BAT-associated emission levels**U.K.

See Table 3 for chromium BAT-AELs for direct discharges to receiving water, and Table 4 for chromium BAT-AELs for indirect                     discharges into urban waste water treatment plants.                  

##### 12.In order to reduce total chromium and sulphide emissions through indirect discharges of waste water from tanneries into urban                        waste water treatment plants, BAT is to apply chromium precipitation and sulphide oxidation.U.K.

###### **Description**U.K.

See BAT 10, technique b.

The removal efficiency is higher in the case of segregated, concentrated chromium/sulphide-bearing streams.

Sulphide oxidation consists of a catalytic oxidation (aeration in the presence of manganese salts).

###### **Applicability**U.K.

Chromium precipitation is generally applicable for on-site and/or off-site treatment of waste water effluents of tanneries                     carrying out chromium tanning and/or retanning.                  

###### **BAT-associated emissions levels**U.K.

See Table 4 for chromium and sulphide BAT-AELs for indirect discharges into urban waste water treatment plants.

###### *Table 4*

**BAT-AELs for total chromium and sulphide emissions through indirect discharges of waste water from tanneries into urban waste                           water treatment plants**

#### 1.6.*Airborne emissions*U.K.

##### 1.6.1.*Odour*U.K.

###### 13.In order to reduce the generation of ammonia odours from processing, BAT is to partially or completely replace ammonium compounds                        in deliming.U.K.

###### **Applicability**U.K.

The complete replacement of ammonium compounds by CO2 during deliming cannot be applied to the processing of materials whose thickness is over 1,5 mm.                  

The applicability of partial or complete replacement of ammonium compounds by CO2 during deliming is also limited to both new and existing processing vessels that allow the use of, or can be modified to                     use, CO2 during deliming.                  

###### 14.In order to reduce the emission of odours from process steps and effluent treatment, BAT is to abate ammonia and hydrogen                        sulphide by the scrubbing and/or biofiltration of extracted air in which odour of these gases are noticeable.U.K.

###### 15.In order to prevent the production of odours from the decomposition of raw hides or skins, BAT is to use curing and storage                        designed to prevent decomposition, and rigorous stock rotation.U.K.

###### **Description**U.K.

Correct salt curing or temperature control, both combined with rigorous stock rotation to eliminate decomposition odours.

###### 16.In order to reduce the emission of odours from waste, BAT is to use handling and storage procedures designed to reduce waste                        decomposition.U.K.

###### **Description**U.K.

Control of waste storage and methodical removal of putrescible waste from the installation before its decomposition causes                     odour problems.                  

###### **Applicability**U.K.

Applies only to plants which produce putrescible wastes.

###### 17.In order to reduce the emission of odours from the beamhouse effluent, BAT is to use pH control followed by treatments to                        remove the sulphide content.U.K.

###### **Description**U.K.

Maintaining the pH of effluents containing sulphide from the beamhouse above 9,5 until the sulphide has been treated (on or                     off site) by one of the following techniques:                  

catalytic oxidation (using manganese salts as a catalyst);

biological oxidation;

precipitation; or

by mixing in an enclosed vessel system fitted with an exhaust scrubber or a carbon filter.

###### **Applicability**U.K.

Applies only to plants carrying out sulphide unhairing.

##### 1.6.2.*Volatile organic compounds*U.K.

###### 18.In order to reduce the airborne emissions of halogenated volatile organic compounds, BAT is to replace halogenated volatile                        organic compounds used in the process with substances that are not halogenated.U.K.

###### **Description**U.K.

Replacement of halogenated solvents by non-halogenated solvents.

###### **Applicability**U.K.

Does not apply to the dry degreasing of sheepskins carried out in closed cycle machines.

###### 19.In order to reduce airborne emissions of volatile organic compounds (VOC) from finishing, BAT is to use one or a combination                        of the techniques given below, priority being given to the first one.U.K.

###### **BAT-associated solvent use levels and BAT-associated emission levels for VOC**U.K.

Both the solvent use rates associated with the use of water-borne coatings in combination with an efficient application system                     and the BAT-AEL range for specific VOC emissions where an extraction ventilation and abatement system is used as an alternative                     to the use of water-borne finishing materials are given in Table 5.                  

###### *Table 5*

**BAT-associated solvent use levels and BAT-AELs for VOC emissions**

##### 1.6.3.*Particulate matter*U.K.

###### 20.In order to reduce the airborne particulate matter emissions from the dry finishing stages of production, BAT is to use an                        extraction ventilation system fitted with bag filters or wet scrubbers.U.K.

###### **BAT-associated emission levels**U.K.

The BAT-AEL for particulate matter is 3 to 6 mg per normal m3 of exhausted air expressed as a 30-minute mean.                  

#### 1.7.*Waste management*U.K.

##### 21.In order to limit the quantities of wastes sent for disposal, BAT is to organise operations on the site so as to maximise                        the proportion of process residues, which arise as by-products, including the following:U.K.

##### 22.In order to limit the quantities of wastes sent for disposal, BAT is to organise operations on the site so as to facilitate                        waste reuse, or failing that, waste recycling, or failing that, ‘other recovery’, including the following:U.K.

##### 23.In order to reduce the chemical consumption and reduce the amount of leather waste containing chromium-tanning agents sent                        for disposal, BAT is to use lime splitting.U.K.

###### **Description**U.K.

Carrying out the splitting operation at an earlier stage of processing, so as to produce an untanned by-product.

###### **Applicability**U.K.

Applies only to plants using chromium tanning.

Not applicable:
          -  when hides or skins are being processed for full substance (i.e. unsplit) products, 
          -  when a firmer leather has to be produced (e.g. shoe leather), 
          -  when a more uniform thickness is needed in the final product, 
          -  where tanned splits are produced as a product or co-product. 

##### 24.In order to reduce the amount of chromium in sludge sent for disposal, BAT is to use one or a combination of the techniques                        given below.U.K.

##### 25.In order to reduce energy, chemical and handling capacity requirements of sludge for its subsequent treatment, BAT is to reduce                        the water content of sludges by using sludge dewatering.U.K.

###### **Applicability**U.K.

Applies to all plants carrying out wet processing.

#### 1.8.*Energy*U.K.

##### 26.In order to reduce energy consumed in drying, BAT is to optimise the preparation for drying by samming or any other mechanical                        dewatering.U.K.

##### 27.In order to reduce energy consumption for wet processes, BAT is to use short floats.U.K.

###### **Description**U.K.

Reducing the energy used to heat water by reducing hot water use.

###### **Applicability**U.K.

The technique cannot be applied in the dyeing process step and for the processing of calfskins.

Applicability is also limited to:
          -  new processing vessels, 
          -  existing processing vessels that allow the use of, or can be modified to use, short floats. 

###### **BAT-associated energy consumption rates**U.K.

See Table 6.

###### *Table 6*

**Specific energy consumption associated with BAT**

1

OJ L 334, 17.12.2010, p. 17.                           

2

OJ C 146, 17.5.2011, p. 3.                           

3

http://circa.europa.eu/Public/irc/env/ied/library?l=/ied_art_13_forum/opinions_article

4

OJ L 135, 30.5.1991, p. 40.                           

5

OJ L 348, 24.12.2008, p. 84.                           

6

OJ L 158, 30.4.2004, p. 7.                           

7

OJ L 353, 31.12.2008, p. 1.                           

8

OJ L 167, 27.6.2012, p. 1.