2014-05-30-fa15-caia-submission-12-2007-38679d22dd4db821.pdf

This December 2007 submission from the Chemicals and Allied Industries Association (CAIA) to the Department of Environmental Affairs and Tourism (DEAT) critiques the proposed minimum emission standards for listed activities. CAIA argues that the standards lack essential technical elements—such as averaging periods and compliance tolerances—and fail to follow the legally binding National Air Quality Framework. The association specifically opposes the adoption of European Union standards without considering the South African context, suggesting World Bank Standards as a more appropriate minimum baseline.

• CAIA asserts that it is impossible to meaningfully comment on quantitative emission standards because DEAT has failed to provide several critical elements of the standard, including the averaging period, permissible frequencies of exceedance, compliance timeframes, and compliance tolerances.
• The association claims that publishing the final document for public comment without following the standard-setting process defined in the National Air Quality Framework would be a "contravention of a legally binding document".
• CAIA argues that the selection of pollutants for the organic and inorganic chemical industries is flawed because it relies on "international best practice" rather than the mandate in the Act, which requires consideration of South African social and economic conditions.
• The document opposes the use of EU standards as the minimum emission standard for South Africa, suggesting instead the use of World Bank Standards, with EU standards reserved for cases where a local authority justifies stricter limits.
• Regarding combustion installations, CAIA requests the relaxation of sulphur dioxide (SO2) limits, noting that meeting a limit of 400 mg/Nm³ would require Flue Gas Desulphurization (FGD), leading to increased operational costs and lime supply issues.
• CAIA criticizes the inclusion of international measurement standards (ISO and EPA) in South African legislation, proposing that ISO standards be adopted as South African national standards via the SABS process to ensure compatibility with national realities.
• The association notes that for certain facilities, such as Sasol Sasolburg, a full implementation and compliance period of approximately 15 to 20 years would be required for the new standards.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa15-caia-submission-12-2007-38679d22dd4db821.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA15-CAIA-submission-12-2007.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa15-caia-submission-12-2007-38679d22dd4db821.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA15-CAIA-submission-12-2007.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa15-caia-submission-12-2007-38679d22dd4db821.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA15-CAIA-submission-12-2007.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa15caiasubmission12200738679d22dd4db821pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa15-caia-submission-12-2007-38679d22dd4db821.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA15-CAIA-submission-12-2007.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }