One of the environmental issues for companies of the leather and animal skin sector, in particular for tannery and leather dressing activities, can be the discharge into the water of toxic, metallic or organic products used in the process.
These activities are regulated by the general legislation, and in particular the order of 2 February 1998 relative to the water withdrawal and consumption as well as all types of emissions of permit holding classified installations for environmental protection.
It should be noted that this order stipulates various specific requirements for the sector:
The emission of volatile organic compounds due to the use of solvents at various stages of the process can also be a significant problem requiring discharge limitation.
Within the framework of the work carried out prior to the implementation of the Water Framework Directive, in order to reduce the discharge of these toxic substances, certain companies can be included in the discharge inventory programmes launched by the DRIRE and water agencies. Depending on the amount of discharge, product toxicity and impact on the environment, discharge reduction or elimination initiatives may be required.
For varnish and paint application activities (section 2940), the installations with a declaration obligation will undergo periodic inspection (every five years) by an accredited external organization, to verify the compliance of the installation’s layout and operation with a limited list of elements, which will be defined by ministerial order.
This requirement, in line with a general framework defined in 2006 and instituting this type of periodic inspection for certain installations with a declaration obligation (over thirty sections concerned), will be applicable in 2008 at the latest, once the ministerial order defining the elements to be inspected is established and signed (these orders are being drafted, trade associations are consulted during this phase and the companies will be informed of the date when the systems comes into force).
Furthermore, the companies belonging to this sector may be concerned by different sections of the nomenclature corresponding with “utilities” necessary for the industrial process such as combustion installations (2910).