2014-05-30-fa10-caia-submission-may-2007-01aa857987c9306f.pdf

The Chemical and Allied Industries Association (CAIA) submitted a May 2007 proposal to the Department of Environmental Affairs and Tourism (DEAT) regarding the implementation of Section 21 of the Air Quality Act. The submission critiques the proposed criteria for listing activities and emission standards, advocating for a risk-based approach, the avoidance of legislative duplication, and the use of national standards authorities for measurement methodologies.

• CAIA argues that the proposed criteria for listing activities in the Air Quality Act are problematic and lack a risk-based approach, specifically noting that the use of 'large scale' as a criterion is vague because "Air pollution is not onty produced as a function of scale".
• The submission identifies a 'circular argument' in the proposed listing criteria where activities are listed based on their presence in Government Notice No. 386 or 387 of 2006 (NEMA EIA regulations), yet those NEMA listings often depend on whether the activity is already listed under other legislation like the Air Quality Act.
• CAIA disputes the inclusion of several specific industries—including pharmaceuticals, pesticides, and the explosives industry—on the list of activities, stating that evidence of a "significant detrimental effect on the environment" has not been provided for these sectors.
• The association opposes the development of different national minimum emission standards for the same pollutant based on the activity; instead, it suggests that site-specific standards should be based on local ambient air quality requirements.
• CAIA proposes that sampling and measurement methodologies should be developed by the South African National Standards Authority and that analysis be performed by laboratories accredited by the South Africa National Accreditation System, rather than relying solely on US EPA methods.
• The submission recommends a transitional period of 5 to 7 years from the date of promulgation for existing or planned plants, with the trigger date for this period being the authorization under the EIA process.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa10-caia-submission-may-2007-01aa857987c9306f.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA10-CAIA-Submission-May-2007.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa10-caia-submission-may-2007-01aa857987c9306f.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA10-CAIA-Submission-May-2007.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa10-caia-submission-may-2007-01aa857987c9306f.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA10-CAIA-Submission-May-2007.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa10caiasubmissionmay200701aa857987c9306fpdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa10-caia-submission-may-2007-01aa857987c9306f.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA10-CAIA-Submission-May-2007.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }