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  Inspection and Verification Measure for Environmental Protection of Fur Processing Companies

Inspection and Verification Measure for Environmental Protection of Fur Processing Companies

2019-12-05

来源:中国皮革协会

作者:

In order to further promote pollution prevention in the fur processing companies initialized by the China Leather Industry Association and further carry out inspection and verification of environmental protection in the fur processing industry in line with the Environmental Protection Law of the People's Republic of China (2014 Amendment), the Decision of the State Council on Implementation of Strengthening Environmental Protection with Scientific Outlook on Development (GF [2005] Document 39), the Approval of the Twelfth Five-Year Plan of Comprehensive Heavy Metal Pollution Prevention and Control by the State Council (GH [2011] Document 13), the Notice of the State Council on Issuing the Water Pollution Prevention Plan (GF [2015] Document 17) and HBH [2015] Document 273, this Measure is hereby concluded.

I. Scope of application

This Measure is applicable to all the fur processing companies in the territory of the People's Republic ofChina(excludingHong Kong,MacaoandTaiwan).

II. Procedure of inspection and verification

(1) Self-inspection

Every fur processing company should seriously carry out the self-inspection in accordance with this Measure. It is required to make the realistic, comprehensive and systematic analysis so as to find any current environmental protection problems and complete the rectification as soon as possible. Meanwhile, the application for environmental protection inspection and verification, the self-inspection report and other relevant evidence documents shall be submitted to the China Leather Industry Association and the provincial leather industry association of the company.

(2) Material review

Based on the industrial environmental protection discipline teams, the Environmental Protection Inspection and Verification Expert Team has been established by the China Leather Industry Association in order to inspect and verify materials submitted by the concerning fur processing company. For the company, which was determined to be qualified in line with all relevant regulations and rules after review of materials, it will go into the on-site inspection step. For the company, which was determined to be unqualified after review of materials, it shall provide supplemental documents in line with relevant requirements upon receipt of a notice issued by the relevant responsible head from the China Leather Industry Association and after it was determined to be qualified, it will go into the on-site inspection step. For the company, which failed to provide the supplemental documents as required, after inspection and verification, its environmental protection inspection and verification will be stopped and it is deemed to fail such inspection and verification.

(3) On-site inspection and verification

Based on the review of materials provided by the concerning fur processing company, the Environmental Protection Inspection and Verification Expert Team shall precede the on-site inspection and verification in accordance with relevant requirements and propose comments on rectification. Afterwards, the concerning company shall perform rectification according to the said comments and submit the materials related to rectification within the time as required.

(4) Review

The Environmental Protection Inspection and Verification Expert Team is responsible for review of the rectification materials submitted by the company, on-site review of the company in accordance with relevant requirements and proposal of review comments. The company in line with relevant requirements is allowed to be listed in the final announcement.

(5) Announcement

The List of Fur Processing Companies that passed the review will be announced to the pubic by the China Leather Industry Association. After verifying and processing all points of view, the List of Green Fur Processing Companies in line with relevant environmental protection regulations will be launched and submitted to the Ministry of Environmental Protection, the Ministry of Industry and Information Technology, the Ministry of Commerce, the General Administration of Quality Supervision, Inspection and Quarantine and other relevant departments for the record.

For the fur processing companies not passing the review, the China Leather Industry Association will send documents to inform the concerning company of the existing problems. In case that the company rectified itself on time and submit the rectification results and relevant evidence to the Expert Team, after passing the on-site review made by the Expert Team, the inspection and verification comments will be proposed by the Expert Team and submitted to the China Leather Industry Association. After that, the concerning company is able to go into the next step of batch announcement.

III. Main conditions to pass the environmental protection review

(1) Implementation of the environmental protection review and approval as well as the inspection and acceptance of environmental protection facilities for the project construction (including the new, renovated and expanded project).

1. In accordance with relevant laws, the company shall carry out the environmental impact assessment for the construction project and the environmental impact assessment documents shall be approved by the environmental protection administration with the approval right. After the completion of the construction project, the inspection and acceptance of completed environmental protection shall be approved by the environmental protection administration with the approval right.

2. For the project that has obtained the environmental protection approval, but has not started the inspection and acceptance of completed environmental protection after the trial product exceeded one year, the company shall organize the environmental impact assessment (EIA) according to the surrounding environment change and submit the EIA documents for the record. After that, the company shall take some measures for further improvement and obtain approval of inspection and acceptance of completed environmental protection by the environmental protection administration with the approval right.

(2) Implementation of the sewage discharge application, sewage discharge payment and sewage discharge permit system

The company shall apply and register for sewage discharge according to relevant laws and obtain the sewage discharge permit so as to meet requirements of the sewage discharge permit. The sewage discharge fee shall be paid in accordance with relevant regulations.

(3) The main pollutant discharge meets the needs of the overall control.

1. The chemical pollutant discharge, including oxygen, sulfur dioxide, ammonia, nitrogen oxide and total chromium, shall be in line with relevant requirements in terms of the overall control assigned to this company by the local environmental protection administration.

2. The annual pollutant discharge reduction task, including oxygen, sulfur dioxide, ammonia and nitrogen oxide, shall be completed.

(4) Standard discharge of main pollutants and featured pollutants

1. Within the period of inspection and verification, the discharge of waste water, waste gas, noise and other pollutants reach the corresponding national or local discharge standards. After the new standard come into force, the new standard shall be implemented.

2. The project shall be monitored in accordance with the indexes and requirements specified by the environmental impact report and environmental protection authorities at all levels. All indexes of the waste water and waste gas shall be monitored at least once every quarter and at the same time, the monitoring report issued by the provincial or prefecture-level municipal environment monitoring station within one year shall be provided. The monitoring results are not allowed to go beyond the standard and there should be no monitoring records exceeding the standard in the past year.

3. The company shall carry out self monitoring and self reporting work, establish the company's pollutant discharge monitoring archives and manage the quality of self monitoring well.

4. There should be no complaint of environmental problems from neighbors or the complaint has been sorted out.

(5) The general industrial solid waste and hazardous waste shall be disposed in an environmental friendly way.

1. The hazardous waste generated by the fur processing company shall be disposed in an environmental friendly way. In case the waste is needed to be transferred, it shall be disposed in accordance with the Management on the Hazardous Waste Transfer Form.

2. In case the hazardous waste is disposed by itself, the environmental impact assessment of the special facilities shall be performed in accordance with Article 13 and 14 of the Law of Solid Waste Pollution Prevention and the said facilities shall be designed, constructed and put into operation with the main project at the same time. The disposal process shall be in line with relevant pollution control requirements on storing, burning and burying hazardous waste. In case that the hazardous waste was disposed by the entrusted party, the concerning party shall provide the Hazardous Waste Disposal Permit.

3. In case that the general industrial solid waste is disposed by itself or is re-used comprehensively, the company shall provide the instruction of where those waste has gone at the end or the contract signed with the comprehensive re-use company.

(6) The environmental protection facilities and auto online monitoring equipment work stably.

During the inspection and verification period, the environmental protection facilities are complete and the stable operation rate reaches over 95%. In accordance with relevant regulations, the company shall install main pollutants and featured pollutants auto monitoring equipment, which shall be inspected and accepted by the environmental protection authorities, in order to make them connected to the environmental protection authorities on the line, guarantee the operation rate of monitoring facilities and monitor the data transmission rate and the data availability no less than 90%. The auto monitored data availability shall be submitted to the local environmental protect authorities regularly for review of the self-inspection report and the company shall automatically provide support to the review of the auto monitored data availability.

(7) It shall comply with relevant industrial policies and requirements of the limited chemical substance application.

There are no process, production facilities or products required to be banned or eliminated by our country with a limit term. The chemical indicators, including azo, formaldehyde, pentachlorophenol and hexavalent chromium, shall be in line with the limit requirements of laws, regulations and standards, and a copy of the Test Report issued by the national or international test center after quality tests shall be provided (In case that the time interval from the test date to the application date is within 6 months, the Test Report is deemed to be valid).

(8) The environmental management system and environmental risk prevention

1. The complete corporate environmental management system shall be established and operated efficiently.

2. The practical and feasible solutions to environmental emergencies shall be stipulated and the emergency practice shall be carried out regularly. The emergency engineering facility construction and emergency material reserve shall be in line with relevant regulations.

(9) There are no major environmental risks and no major environmental accidents occurred in the inspection and verification period.

The project shall be in line with the requirements of health protection distance and it will not impose any environmental threat on environmentally sensitive objects, including residential areas (settlements), nature reserves, scenic spots and drinking water source protection areas. During the inspection and verification period, no serious and major environmental accidents, no serious environmental violations and no fine of over 100,000 RMB punished by environmental protection authorities at all levels occurred.

(10) The clean production system shall be established and operated effectively.

The clean production system shall be established in order to guarantee the effective operation of process facilities, reduce the generation of pollutants, and effectively reduce the pollutant generation rate, including waste water, COD, ammonia nitrogen and other major pollutants.

(11) The chromium (heavy metal) pollution prevention shall be in line with relevant regulations.

The collection and disposal of chromium-contained waste water shall be reasonable and facilities shall be complete so as to ensure the effective separation of chromium-contained waste water and composite sewage and independent disposal to be in line with the standard.

IV. Supervision and management

Only if its subsidiaries or holdings with the same legal representative or the fur processing companies owned or controlled by the same natural person meet the relevant requirements, they can be counted in the List of Green Fur Processing Companies in line with relevant environmental protection regulations for announcement.

The List of Green Fur Processing Companies in line with relevant environmental protection regulations will be announced to the pubic by the China Leather Industry Association. Meanwhile, it will be submitted to the Ministry of Environmental Protection, the Ministry of Industry and Information Technology, the Ministry of Commerce, the General Administration of Quality Supervision, Inspection and Quarantine and other relevant departments to provide support for the development of relevant policies.

The monitoring system shall be established by the China Leather Industry Association so as to monitor and manage the listed fur processing companies. Once it is found that any listed company has polluted the environment, the China Leather Industry Association will order it to make regular rectification; if it was unqualified after regular rectification, the China Leather Industry Association will remove this company from the published List of Green Fur Processing Companies and such change will be submitted to relevant authorities for the record.











Appendix 2:


Application form of environmental protection inspection and verification for fur processing companies


Company name

Company address

Post code

Legal representative

Tel

Contact

Name

Tel

Position

Fax

E-mail

Annual skin production amount

Mink skins 1,000 sheets

Fox skins 1,000 sheets

Raccoon skins 1,000 sheets

Sheep skins 1,000 sheets

OthersIndicate the category of raw materials) 1,000 sheets

Categories of major products

Profile:

Signature and official seal

Date














Appendix 3:


Environmental Protection Self-Inspection Report of the Fur Processing Company




Company name:

Company address:

Contact:

Contact No.:

I. Overview of the corporate environmental protection work

It includes the corporate development historical revolution, production process workflow, main production facilities, environmental management systems, environmental protection investment, operation of environmental protection facilities, treatment and disposal of pollutants and so on.

II. The environmental impact assessment and the "Three simultaneous" inspection and acceptance implementation.

The environmental impact assessment and the "Three simultaneous" implementation shall be summarized and filled in Table 1. By referring to the major environmental protection measures indicated in the approval document of the environmental impact assessment and the approval document of the final inspection and acceptance, every implementation shall be explained step by step and shall be filled in Table 2. Copies of the environmental impact assessment for all the new, renovated and expanded projects and the approval document for the "Three simultaneous" final inspection and acceptance shall be summarized and incorporated into the Appendixes.


Table 1 Approval document for environmental protection

No.

Name of the construction project

Environmental impact assessment

Final environmental protection inspection and acceptance

Approval Unit

Approval No.

Approval Unit

Approval No.

Note: The environmental impact assessment of all the construction projects at all levels and "Three simultaneous" inspection and acceptance situation shall be listed and the environmental protection approval document shall be provided.


Table 2 Environmental protection requirements and practical implementation

No.

Name of the construction project

EIA approval and requirements on environmental protection provided by the final environmental protection inspection and acceptance.

Practical implementation

Note: The implementation of environmental protection requirements provided by the EIA approval and the comments on the final EIA inspection and acceptance shall be listed for the company in the order of numbers.

III. Implementation of the sewage application, sewage permit and sewage payment.

The registration document of sewage discharge application, the permit number, the permitted discharge volume and the practical discharge volume during the inspection and verification shall be listed and it shall be explained whether the permitted discharge volume has been met or not. The number, payment amount and actual payment of the payment notice for sewage discharge issued by the environmental protection authorities during the inspection and verification period shall be listed. Copies of the sewage discharge permit are summarized and incorporated into the Appendixes. It can be prepared by referring to Table 3 and 4.


Table 3 Implementation of the sewage application and sewage permit.


Permit No.: Issued by:

Pollutant category

Permitted discharge volume

Actual discharge volume

Qualification status

COD

Ammonia nitrogen

Total chrome


Table 4 Sewage discharge payment

Payment notification

Actual payment

Sewage charges collection agencies

Invoice No.

Invoicing date

No.

Amount payable


IV. The overall discharge control of major pollutants and requirement of the overall discharge reduction

The discharge volume of pollutants shall be listed during the inspection and verification and the data sources shall be explained. The overall discharge volume of pollutants shall be explained and whether the overall discharge volume indicator specified by the environmental protection authority complies with the requirement before the deadline shall be illustrated as well. By referring the indicators of the main pollutant reduction specified by the environmental authority, the company shall list the reduction measures to be taken, including the reduction measure name, main process, reduction efficiency and implementation. The documents and reduction task assignment related to the overall pollutants discharge volume indicator specified by the environmental protection authority shall be summarized and incorporated into the appendixes. For the company, which has no overall pollutant discharge volume indicator or no reduction task to be assigned, the situation shall be explained. It can be prepared by referring to Table 5 and 6.


Table 5 Implementation of the overall discharge control indicator of major pollutants

Pollutant category

Overall discharge control indicator

Indicator sources

Actual discharge volume indicator

Qualification status

COD

Sulfur dioxide

Ammonia nitrogen

Nitrogen oxide

Total chrome


Table 6 Implementation of the overall reduction of major pollutants

Pollutant category

Overall reduction indicator

Indicator sources

Actual reduction

Implementation

COD

Sulfur dioxide

Ammonia nitrogen

Nitrogen oxide


V. Qualified pollutant discharge situation

The qualified waste water and waste gas discharge situation of the company, the qualified noise situation at the factory border and the executed discharge standards shall be listed. The data sources shall be indicated for the monitored date to be adopted and the copies of monitoring materials to be adopted shall be summarized and incorporated into the appendixes. It can be prepared by referring to Table 7.


Table 7 Summary of qualified major pollutant discharge of the company

7-1 Qualification of water pollutant discharge

Outlet No.: Data sources:

□ a. Supervision monitoring; b. Inspection and acceptance monitoring; c. Entrustment monitoring.

Discharge standard No. to be implemented:

Water consumption: tons/day; the volume of generated waste water: tons/day; waste water treatment capacity: tons/day;

The actually treated waste water volume: tons/day; The basic water discharge volume for unit hide: tons/tons of raw hide;

Waste water discharge volume: tons/day, where the volume directly discharged into the body of water: tons/day, the volume discharged into the municipal pipe network: tons/day,

The volume discharged into the waste water treatment plant in the park: tons/day. .

Monitoring time

(MM/YY)

Flow

(Tons/day)

Pollutant concentration at the outlet (unit: mg/L except for pH and chromaticity)

PH

Chromaticity

Chemical oxygen

demand

BOD

Suspended solids

Ammonia nitrogen

Total nitrogen

Animal and vegetable oils

Chloride ions

Sulfides

Total chrome

Hexavalent chromium

Total phosphorus

Standard discharge limit

Qualification status

7-2 Qualification of atmospheric pollution source discharge

Outlet No.: Data sources:

□ a. Supervision monitoring; b. Inspection and acceptance monitoring; c. Entrustment monitoring.

Discharge standard No. to be implemented:

Monitoring time (MM/YY)

Waste gas discharge volume /h

Pollutant concentration at the outlet (Unit: mg/m3)

Sulfur dioxide

Nitrogen oxide

Smoke

Odor gas

Dust

Others

...

Standard discharge limit

Qualification status

7-3 Qualification of noise at the factory border

Data sources: □ a. Supervision monitoring; b. Inspection and acceptance monitoring; c. Entrustment monitoring.

Discharge standard No. to be implemented:

Monitoring time (MM/YY)

Noise range in the day

Noise range in the night

Impact of noise on the target

Standard discharge limit

Qualification status


VI. Disposal of general industrial solid waste and hazardous waste

The generation amount, comprehensive utilization amount and disposal amount of general solid waste shall be listed by referring to Table 8. In case that the solid waste was disposed by the entrusted party, the capability of comprehensive solid waste utilization and disposal of the entrusted party shall be explained and the relevant agreement shall be incorporated into the appendixes. The generation amount, storage amount, comprehensive utilization amount and final disposal amount of hazardous waste of the company during the inspection and verification period shall be listed by referring to Table 9. In case that the hazardous waste is disposed by the company itself, whether the disposal method is in line with the requirement related to the hazardous waste disposal standard shall be explained. In case that the Hazardous waste is disposed by the entrusted party, whether there is any hazardous waste disposal transfer form, the business range of hazardous waste and capability of hazardous waste disposal related to the entrusted party shall be explained. The copies of the entrusted hazardous waste disposal business license, the disposal agreement and transfer form shall be incorporated into the appendixes.


Table 8 Comprehensive utilization and disposal of general industrial solid waste

No.

Solid waste category

Generation amount (tons/year)

Comprehensive utilization amount

(tons/year)

Disposal amount (tons/year)

Disposal method


Table 9 Disposal of hazardous waste

No.

Hazardous waste category

Generation amount

(tons/year)

Storage amount

(tons/year)

Comprehensive utilization amount (tons/year)

Disposal amount

(tons/year)

Destination after disposal


VII. Construction and operation of environmental protection facilities and auto monitoring equipment

The operation and maintenance of the company's environmental protection facilities during the inspection and verification period shall be listed by referring to Table 10. The construction and operation of auto pollution source monitoring equipment of the company shall be explained by referring to Table 11.


Table 10 Stable operation of environmental protection facilities

No.

Main environmental protection facilities

(Type and process)

Disposal capacity

Disposal efficiency (%)

Synchronous operation rate with main facilities

Maintenance

Shutdown/

Idle




Table 11 Operation of auto monitoring equipment

No.

Name and type of auto monitoring equipment

Installation location

Monitored

items

Connected to the environmental protection authority on the line or not?

Pass inspection and acceptance or not?

Monitor the equipment operation rate

Data transmission rate

Data availability

Maintenance


VIII. It shall comply with relevant industrial policies and requirements of the limited chemical substance application.

Whether there are any process, production facilities or products required to be banned or eliminated by our country with a limit term. The chemical indicators, including formaldehyde, hexavalent chromium, pentachlorophenol and azo, shall be in line with the limit requirements of laws, regulations and standards, and a copy of the Test Report issued by the national or international test center after quality tests shall be provided (In case that the time interval from the test date to the application date is within 6 months, the Test Report is deemed to be valid) by referring to Table 12. The compliance of relevant policies shall be analyzed by referring to the Guiding Catalogue of Industrial Structure Adjustment (latest version) and policies related to the fur industry issued by relevant ministries.


Table 12 Limit requirement of azo, formaldehyde pentachlorophenol and hexavalent chromium

Item

Maximum limit

Direct contact with skins

General

Formaldehyde

75

150

Hexavalent chrome

3

Pentachlorophenol

5

Azo

30



IX. The environmental management system and environmental risk prevention

The basic situation of the corporate environmental management system shall be introduced and functions and roles of the corporate environmental management system shall be explained in the application of the environmental impact assessment and final Three Simultaneous inspection and acceptance, operation of environmental protection facilities, environment monitoring, clean production and environmental pollution accidents. It can be prepared by referring to Table 13. It indicates whether the solutions to environmental emergencies have been prepared and whether emergency solutions have been implemented and how the practice goes. It indicates the construction of emergency engineering facilities and storage of emergency materials.

Table 13 The corporate environmental management system

No.

Environmental management organization

Environmental management people

Environment monitoring station

Others

X. There are no major environmental risks and no major environmental accidents occurred in the inspection and verification period.

It indicates the impact of the company on the surrounding environment in terms of safety. Distribution of environmental sensitive objects, including the environmental overview (including residential areas (settlements)), nature reserves, scenic spots and water source protection areas within 1,000 meters around the company (including main projects and ancillary supporting projects), as well as their relative position from the company attached with the position diagram shall be listed. Whether the said positions are in line with relevant laws shall be explained and whether the production of the company imposes any risks on the safety of the surrounding environment and the surrounding residents shall be indicated as well. The corporate environment against relevant laws and regulations and environmental accidents happened during the inspection and verification period shall be explained completely and actually and the environmental protection violation and detailed rectification concerning the company shall be submitted in the format of Table 14.

Table 14 Details of corporate environment against relevant laws and regulations

No.

Punished department

Investigation and punishment time

Main environmental violations

Violation of clauses of laws and regulations

Punishment contents

Rectification measures and results

Evidence

materials

Note: Any administrative punishment or criminal penalties (including fines with the amount) due to violation of relevant environmental protection laws or regulations, serious and major environmental pollution accidents, petition letters or personal petitions caused by environmental protection complaints and other environmental protection violations happened during the inspection and verification period shall be included. In the column of "Evidence materials", any evidence documents, pictures and other evidence materials related to rectification that have been confirmed by the punishment authority shall be filled and the detailed materials shall be incorporated into the appendixes.


XI. Generated pollutant intensity and clean production implementation

The clean production system shall be established and operated effectively. The process workflow of the adopted clean production, application results and other relevant materials shall be provided. The generated pollutant intensity of waste water, COD, ammonia nitrogen and other major pollutants caused by one raw hide unit shall be explained and calculated.



XII. Heavy metal pollution prevention and control

The generated volume, independent collection, disposal and discharge of waste water with chromium shall be explained. It shall be explained that whether the daily heavy metal monitoring system and the discharge ledger were established according to the Guidance on Strengthening Prevention and Control of Heavy Metal Pollution, whether the monitoring results were reported to the local environmental protection authority, whether the heavy metal pollutant online monitoring devices were installed and connected to the environmental protection authority on the line. The key fur processing companies in the key heavy metal pollution prevention and control area shall purchase the environmental pollution liability insurance in accordance with relevant national regulations.

XIII. Disclosure of environmental protection information to the public

It is indicated for the company whether the environmental information has been disclosed timely, completely and accurately and the annual environmental report has been launched in accordance with relevant regulations concerning the environmental information disclosure. The annual corporate environmental report shall include industrial policies, EIA and "Three simultaneous" systems, standard discharge, overall discharge control, discharge application, discharge payment, heavy metal pollution prevention and control, operation of environmental protection facilities, toxic and hazardous substance application and management, environmental risk management and implementation of other environmental management systems.

XIV. Environmental protection problems and improvement

The environmental problems found in this environmental protection self-inspection shall be explained item by item, environmental protection measures planned to be taken shall be listed, and the implementation and improvement concerning every rectification measure as of the moment of formal submission of the environmental protection inspection and verification application shall be explained.

XV. Conclusions of the environmental protection self-inspection

For the above-mentioned contents concerning the environmental protection self-inspection, the conclusions shall be provided one by one, including rectification of the problems.

XVI. Appendixes

The index of appendixes of the environmental protection self- inspection report shall be listed with the uniform numbering system.

Appendixes include the followings: the corporate surrounding position diagram, approval documents of EIA and the "Three simultaneous" inspection and acceptance, discharge permits, the overall reduction task letter or no reduction task instruction, real photos of main environmental protection facilities, monitoring reports, copies of the entrusted or self-disposed hazardous waste disposal business license, copies of the disposal transfer form, relevant documents of clean production implementation, copies of relevant documents of disposal comments on the environmental pollution accident issued by relevant government, corporate commitment to continuous improvement and other necessary attachments.

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