Printing SA has outlined its response to the Air Quality Act and its proposed actions, as well as a new development in its training programme.
Declaring the print industry a controlled emitter
Over the last several months, Printing SA has sent numerous communications to its members regarding Section 23 of the Air Quality Act of 2004. The Department of Environment, Forestry and Fisheries (DEFF) is engaging with Printing SA regarding the recently published notice for comment on 7 August 2020. The notice intends to regulate the Printing Industry and have it declared a Controlled Emitter in terms of Section 23 of the Air Quality Act 2004. The deadline for comment was 7 September and Printing SA requested an extension to be able to solicit a more comprehensive response. The department gave an extension until 22 September 2020.
What does a Declared Controlled Emitter mean?
According to Section 23 (1) of the Act, the minister is granted the authority to declare an appliance or activity which results in atmospheric emissions that present a threat to health or the environment or which the minister reasonably believes poses such a threat as a Controlled Emitter. Such a declaration must be accompanied by Emission Standards setting the permissible amount, volume, emission rate or concentration of any specified substance or mixture of substances that may be emitted.
The proposed declaration on the printing industry in Section 23 places a requirement on the company to control emissions to the atmosphere through capital investment in abatement technologies. Failure of a Controlled Emitter to comply with the set emission standards is an offence under the Act, which may, on first conviction result in a fine of up to R5 million, or five-years’ imprisonment, or both.
Summary of why Printing SA strongly objects to the notice:
– The proposed Section 23 draft regulation will impose excessive economic impacts on the printing industry, without achieving significant improvements in air quality, human health and well-being.
– The Department of Environment, Forestry and Fisheries (DEFF) has not provided any evidence that the printing sector is causing a measurable deterioration in air quality.
– Based on the Draft Regulations’ VOC limits, it appears that the only solution to reach these limits is to use thermal oxidation (cost of which at October 2016 was R3 million) and implementing the technology generates zero return on capital and operational investment. In addition, for facilities with VOC concentrations less than 2000mg/Nm3, supplementary fuel would need to be provided to the system to allow optimum oxidation conditions to be maintained. This would mean the installation of an LPG tank and a continuous supply of LPG.
– Thermal oxidisers also produce Carbon Dioxide (CO2), a greenhouse gas (climate change and carbon tax implications).
– The costs of abatement technology will most likely be excessive for small to medium size operators. Closure of small to medium size facilities as a result of the costs of abatement does not offer any benefit to the environment (shown by technical studies undertaken by WKC Group in 2012).
– The draft regulations apply to installations with organic solvent consumption threshold equal to or more than 25 tonnes, however, based on technical studies it appears that small facilities (who would probably meet the 25-tonne threshold) with small VOC emissions have a negligible environmental impact. Based on technical studies it was submitted that the solvent consumption level could be amended to 100 tonnes per annum without generating any significant impact on the environment, human health and well-being.
What is Printing SA doing about the proposed Notice?
Printing SA, in fulfilling its commitment to promote the sustainable development of the printing industry, is initiating a thorough response to the department through the engagement of environmental lawyers Norton Rose Fulbright.
What are the costs for the mitigation techniques/equipment?
a) Carbon adsorption: an effective technology for VOC capture with a relatively low CAPEX and high (90%+ recovery performance).
– Normally applied at the smaller end of VOC control due to high cost.
– Purchase and disposal of carbon are around R20,000 per tonne.
– For a small facility from 25 tonnes to 100 tonnes VOC emissions per year, replacing carbon will cost R2 million to R6 million.
b) Thermal oxidisers: thermal efficiencies of the system are very high.
– CAPEX for small printing facility, 100 tonnes VOC per year: R3 million.
– Large printing facility, 1,000 tonnes per annum VOCs: R12 million.
Submission to DEFF
The Department has never disputed the findings of the WKC Group or provided scientific evidence to refute the findings of the technical study. Results of technical studies undertaken in a number of Test Case Facilities found that organic solvents detected in vents were not considered to be toxic and the air dispersion modelling indicated a negligible health risk to communities (due to the low toxicity of solvents used). Despite this scientific evidence, DEFF appears intent on regulating a sector without evidence that it causes harm or presents a threat to the environment or health.
Printing SA proposed that:
– The Printing Sector should not be regulated in terms of Section 23 (or Section 21).
– The sector will make a commitment to use alternative printing materials as these become more affordable and the transition will be conducted over a period which does not place an excessive economic burden on operators.
– The department could investigate a tax on organic solvent usage (for certain printing processes) and the tax should be used to offset the additional cost of alternative printing material to encourage change.
Operators will commit to transitioning to alternative printing materials as the printing equipment reaches the end of its operating lifetime.
You can view and download the following:
Section 23 Explained
Printing SA submission to DEFF 2020
Request for proposal: graphic design training provider
Printing SA’s has expanded its reach to include members from the visual communications industry. With the industry now under its wing, it is time for Printing SA to begin developing the services offerings which allow them to give new members the value that they expect and deserve.
To get the ball rolling, Printing SA is looking to partner with training providers within the visual communications sector, and it welcomes them to submit their proposals for the development of an Adobe Creative Suite e-learning course.
This course will form part of the new Printing SA Electronic Prepress Technician Curriculum, with the aim of further developing this material into blended eLearning courses. The second phase of the project will involve presenting the blended e-learning course in partnership with Printing SA on an ongoing basis.
– Develop an e-learning course that is geared to the printing, packaging and signage industries.
– Develop practical activities, online contact sessions and assessment instruments that ensure the Electronic Prepress Technician Curriculum assessment specifications are met.
– Development of an implementation strategy and rollout, which meets the demands of the industry.
Modes of learning:
– Approximately 8 hours of e-learning per course.
– Online contact session (Zoom or MS Teams).
– Video tutorials.
– PDF manuals.
– Learning briefs and assignments.
– Formative and summative assessments (practical and theoretical).
E-learning course development:
– Adobe Photoshop CC Essentials.
– Adobe Photoshop CC Intermediate.
– Adobe Photoshop CC Advanced.
– Adobe InDesign CC Essentials.
– Adobe InDesign CC Intermediate.
– Adobe InDesign CC Advanced.
– Adobe Illustrator CC Essentials.
– Adobe Illustrator CC Intermediate.
– Adobe Illustrator CC Advanced.
– Adobe Acrobat XI for Print and Prepress.
– Retouching and Colour Correction.
– Packaging Design Fundamentals.
– Blended e-learning course development timelines.
– Blended e-learning course development costs.
– A 2021 timetable indicating course presentation dates and locations.
– Blended e-learning course presentation costs.
– Accreditation as an Adobe Authorised Training Centre (AATC).
– SETA accredited training provider.
– Qualified and registered ETD staff.
– Previous experience and/or past performance history.
– Samples and/or case studies from previous projects.
– Projected costs.
– Industry-relevant experience and technical expertise in the printing, packaging, signage and visual communications industries.
The deadline for submission for all proposals is 20 November 2020.
For more information please see the following documentation:
Request for Proposal: Training Provider(s) able to develop and offer Adobe Creative Suite Blended eLearning in Partnership with Printing SA
Occupational Certificate: Electronic Prepress Flexographic Technician
Occupational Certificate: Electronic Prepress Gravure Technician
Occupational Certificate: Electronic Prepress Lithographic Technician
Occupational Certificate: Electronic Prepress Screen Technician