IMPLEMENTATION OF EUROPEAN REGULATION ON VOLATILE ORGANIC COMPOUNDS (VOC) EMISSIONS
The project pertains to identification and reduction of emissions generated by operators who use volatile organic compounds (VOCs) in their processes, building on the activities of the Ministry of Environmental Protection (MEP) in the implementation of Chapter V of the Industrial Emissions Directive (IED).
The general objective of the project is to support the Ministry of Environmental Protection of the Republic of Serbia and the Environmental Protection Agency of the Republic of Serbia in transposing Chapter V of the Industrial Emissions Directive into national legislation, as well as to support primarily small and medium enterprises that use volatile organic compounds in their production processes in fulfilling the requirements of the said Directive.
The Royal Norwegian Embassy in Belgrade financially supports implementation of the project with the grant amounting to € 430,000, while the Environmental Protection Agency of the Republic of Serbia (SEPA) contributes with € 15,000. The project implementation period is 4 years, staring from 1 December 2018, and closing on 30 November 2022.
Project objectives and goals
- Support to Serbia on its way to access the European Union and in preparation of the Negotiating Position for Chapter 27 – Environment and Climate Change, specifically the section related to emissions of volatile organic compounds.
- Improving the capacity of the Ministry of Environmental Protection in the implementation of Chapter V of the Industrial Emissions Directive.
- Increasing the competitiveness of Serbian operators, primarily small and medium enterprises, by strengthening their capacities related to proper use of organic solvents.
MAIN PROJECT ACTIVITIES
Activity 1: Full transposition of Chapter V of the Industrial Emissions Directive (IED)
Full transposition of the Industrial Emissions Directive (IED) into national regulations is an important step of Serbia in the EU accession process. Therefore, this project activity is aimed at supporting the Ministry of Environmental Protection in drafting legal documents necessary to transpose the requirements of Chapter V of the Directive applying to operators using volatile organic compounds (VOCs).
To this end, amendments to the Law on Air Protection have been proposed, while the Regulation on the list of industrial plants and activities wherein volatile organic compounds emissions are controlled has been updated, introducing new provisions pursuant to Chapter V of the Directive. Moreover, in order to establish the Register of VOC Operators, as a part of the National Register of Pollution Sources, it is necessary to amend the Rulebook defining the types, methods and deadlines for data collection.
Once completed, these legal documents will be subject to consultation with the Ministry of Environmental Protection and other stakeholders. Afterwards, they will be forwarded to the formal adoption procedure.
Activity 2: Technical support
Within this activity, the project provided the competent Ministry and the Environmental Protection Agency of the Republic of Serbia (SEPA) with complete technical support for the implementation of legal framework prepared under Activity 1. Technical support includes preparation of a preliminary list of VOC operators, as well as development, testing and start-up of the electronic registration and reporting system for entities classified as VOC operators.
Preliminary list of VOC operators
The lack of a full list of VOC operators has been identified as a major challenge in the implementation of Chapter V of the Industrial Emissions Directive. In order to overcome this issue, the project has cooperated with the SEPA and the Sector for Environmental Inspection of the MEP in identifying legal entities in Serbia that operate in the sectors listed in Annex VII of the Industrial Emissions Directive. Based on the data of the Serbian Business Registers Agency (SBRA), 9,870 legal entities have been identified to operate in sectors that are subject to the obligations set forth in the Regulation, i.e. potential VOC operators. Sector-specific questionnaires have been prepared for the sectors concerned, and distributed to companies to determine which volatile organic compounds they use, and to determine their annual consumption. The project experts, in cooperation with local environmental inspectors, collect and analyse the completed questionnaires, and the aim of this analysis is to identify operators who exceed the threshold for consumption of organic solvents prescribed by the Regulation and make a preliminary list of VOC operators. By the beginning of 2021, 3,500 questionnaires had been analysed, on the basis of which 157 VOC operators were identified, and the most represented among them were companies dealing with dry cleaning and printing. Based on the first results, it is estimated that about 500 VOC operators are active in Serbia.
Preparation of the electronic National Register of VOC Operators
The project has defined data that operators will have to submit to the Agency (SEPA) for the purposes of maintaining the National Register of Pollution Sources following the amendments to the Regulation on VOC. Based on the mentioned data, the development of electronic forms has started, and they will make an integrated part of the existing Register of Pollution Sources, maintained by Agency (SEPA). This system will be the main instrument for VOC operators, through which they will be able to fulfil the obligations that will be prescribed by the new Regulation.
Activity 3: Capacity building
Monitoring the implementation of the Regulation has proven to be a key step in its full implementation. For this reason, special attention is given to administrative capacity building, especially to the training of local inspectors. Another important part of this activity is the improvement of knowledge about VOC among operators and consultants.
In order to improve the skills of inspectors and their capacities regarding the inspection of VOC operators, training courses have been planned consisting of one general, and eight sectoral workshops. Field trainings have also been planned – joint inspections on the premises of operators from different VOC-related sectors.
During the entire duration of project activities, additional technical support will be provided to national and local inspectors through the Help Desk. In order to ensure the project sustainability, relevant experts will specially train a team of five inspectors who will continue to provide continuous support to their colleagues also upon the completion of the project.
The training course for consultants consists of six individual sessions with practical examples and exercises, envisaged for 20 consultants who were selected through a public competition. Experience gained in other countries indicate that consultants play an important role in the field of VOCs emissions as there is a number of companies that decide to outsource relevant experts in preparation of annual mass balance of solvents and of reports, as well as in the implementation of measures to reduce VOC emissions.
In order to help operators become familiar with the obligations envisaged by the Regulation, short videos will be produced and distributed. These videos will provide clear instructions (“tutorials”) regarding the obligations of VOC operators, such as registration, substitution of VOC substances, and preparation of the annual solvent mass balance. Each tutorial will be delivered to companies identified as VOC operators, and will be also available on the project website.
In order to provide long-term technical support, the project will also draft two manuals and several brochures for the sectors with the largest number of VOC operators.
Activity 4: Information and communication related to VOC regulations
The experience of countries where VOC regulations have been in place for a longer period of time, indicate that provision of updated information to stakeholders is very important, as well as that it is necessary to form a network within which this information will be exchanged.
Establishment of the Info Centre
In order to provide support to operators and government agencies in administrative, technical and informational terms, the project will establish a reference point – Info Centre, for all issues related to volatile organic compounds emissions.
The main task of the Info Centre will be to prepare and make simple and easily accessible detailed technical and operational data on the use of VOCs, as well as data on applicable legal provisions. The Centre will be a reference source of information for each stakeholder, which will ensure more effective implementation of the Regulation, thus making a greater contribution to environmental protection.
Specific role of the Centre will be to collect and distribute data and information on project activities, implementation of VOC regulations in Serbia and other countries in the region, good practice related to reducing the consumption or substituting the solvents, as well as reducing the pollution caused by VOCs emissions. Special attention will be paid to the provision of information on available funds for small and medium enterprises for technological improvements, innovations and compliance with VOC regulations.
In addition, one of the goals of the Info Centre is to improve knowledge and awareness about VOCs and their use, as well as the impact of these compounds on human health and the environment. Citizens from different places and different generations will be contacted through public opinion survies and campaigns launched via social networks, with the aim of being informed and animated regarding the prevention of pollution originating from these compounds.
Help Desk for operators and inspectors
Along with the Info Centre, a permanently available Help Desk will be established, so that stakeholders can receive relevant information via e-mail or directly from the project expert team.
The Help Desk will also provide support to VOC operators (15 VOC operators from the most significant sectors subject to the Regulation) in preparing the necessary data and filling in the electronic forms required to meet legal obligations.
If you want to contact the Help Desk, please send an e-mail to the following address: email@example.com.