Printing SA News: 29/10/2020
Over the last several months, Printing SA has sent numerous communications to our 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 we requested an extension to be able to solicit a more comprehensive response. The department gave us 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 that 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 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 object 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 2 000 mg/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 Norton Rose Fulbright, environmental lawyers.
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 small facility from 25 tonnes to 100 tonnes VOC emissions per year, replacing carbon will cost R2M to R6M.
b) Thermal oxidisers: Thermal efficiencies of the system are very high.
- CAPEX For small printing facility, 100 tonnes VOC per year: R3M.
- Large printing facility, 1,000 tonnes per annum VOCs: R12M.
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:
Printing SA’s recent expansion to include members from the Visuals Communications Industry is nothing short of a big and bold move which we are extremely proud of.
With the industry now under our wing, it is time for Printing SA to begin developing the services offerings which allow us to give our 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 we welcome them to submit their proposals for the development of an Adobe Creative Suite eLearning 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 eLearning course in partnership with Printing SA on an ongoing basis.
- Develop an eLearning Course which is geared to the Printing, Packaging and Signage industries.
- Develop practical activities, online contact sessions and assessment instruments which ensure that 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 eLearning per course
- Online Contact Session (Zoom or MS Teams)
- Video Tutorials
- PDF manuals
- Learning briefs and assignments
- Formative and summative assessments (Practical and theoretical)
eLearning 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 eLearning course development timelines.
- Blended eLearning course development costs.
- A 2021 timetable indicating course presentation dates and locations.
- Blended eLearning 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 communication 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.
Would you like to be part of a federation that is recognised as the official mouthpiece of the South African printing, packaging, branding, creative design, advertising and communications industry?
PIFSA is a federation that is consulted by government and all other important national bodies. Membership grants you access to information, advice, advocacy and a forum for the exchange of views
Join Printing SA! Follow this link for the membership form, and feel free to contact us for any more information you may require.