BREF revision

Read the secretariat’s presentation from the bi-annual conference 2017 with an update on the revision process HERE

The EU legislation setting limits on all industrial emissions (IED) – in the atmosphere, water and soil – from the fishmeal sector is up for revision through revision of the BREF document “Slaughterhouses and Animal By-products Industries” (SA). The BREF (Best available Techniques Reference-document) will in the future be directly binding for the industry. BREF is based on possible emission levels using BAT (Best Available Techniques) and taking also economic implications for the industry into account.

In 2015, European Fishmeal decided to engage actively in the process and prepare for the coming revision. Since then, European Fishmeal has obtained a seat in the IED art. 13 Forum, the formal expert group overseeing the information exchange process on BAT. Furthermore, an internal technical working group (TWG) with expert representatives from each member country, was established. The internal TWG decided to benchmark all European Fishmeal factories on their compliance with the current SA BREF from 2005. Nils Christian Jensen was hired as an external consultant to perform the benchmark and he presented the initial results at the General Assembly in Hirtshals in 2016. The final report was presented to the TWG in March 2017.

The benchmark report provided no obvious recommendations on individual BAT-conclusions to be used for coming BAT-AELs. The report demonstrated huge differences between the factories on:

1. the level of implementation of existing BAT-conclusions,
2. the national and even local regulation of the factories and
3. actual consumption of natural resources and emission outlets.

Following the benchmark, our TWG decided to formulate a common European Fishmeal input to the SA BREF revision process. The input will be given to the EIPPCB (European Integrated Pollution Prevention and Control Bureau) SA BREF technical working group in Seville, that will be formed when the revision process is officially activated in late 2017.

National subgroups were created to help gather national information within European Fishmeal and after consultations between the subgroups and the TWG, the secretariat has put together the final input.

Our input is a “step by step” updated description of the production processes and techniques and technologies used across the whole industry with focus on environmental performance since last SA BREF in 2005. The input also includes data on the areas not covered by the benchmark report, comments on the scope of the BREF, the overlapping with the other BREFS, special recipient conditions as well as European Fishmeal recommendations and arguments about the irrelevance of some BAT-conclusions for the industry.