The Ministry of Ecology and Environment recently issued the Notice on Strengthening the Environmental Impact Assessment and Pollutant Discharge Permits for Construction Projects Involving New Pollutants in Key Industries (Draft for Comments) (hereinafter referred to as the "Draft for Comments"), which intends to strengthen the environmental impact assessment of construction projects involving new pollutants, prohibit the approval of environmental impact assessments of construction projects in some industries involving new pollutants, and incorporate the control requirements of new pollutants into the management of pollutant discharge permits in accordance with the law. Experts pointed out that the control of new pollutants and the management of environmental impact assessment are a new and complex task for local ecological and environmental authorities, and that all localities should strengthen capacity building and technical support, and at the same time build a strong line of defense for new pollutants to enter the recycling system.
Promote the concrete implementation of the Action Plan for the Treatment of New Pollutants
In May 2022, the General Office of the State Council issued the Action Plan for the Treatment of New Pollutants, which put forward requirements such as "strengthening the management of environmental impact assessment, strictly managing the access of construction projects involving new pollutants" and "applying for a pollutant discharge permit or filling in the pollutant discharge registration form in accordance with the relevant requirements of pollutant discharge permit management". According to Wang Bin, secretary-general of the Persistent Organic Pollutants (POPs) Committee of the Chinese Society for Environmental Sciences and an associate researcher at the School of Environment at Tsinghua University, the release of the draft is a concrete measure to further implement the above requirements and will become an important starting point for new pollution control.
"In the current situation that the laws and regulations on the treatment of new pollutants have not yet been perfected, in accordance with the existing laws and regulations such as the Environmental Impact Assessment Law and the Measures for the Management of Pollutant Discharge Permits, the treatment of new pollutants will be incorporated into the existing normalized environmental management system, which will help to play the role of source prevention and control of the environmental impact assessment system, strengthen the emission supervision requirements of the pollutant discharge permit system, and implement the normalized control of new pollutants." Wang Bin said.
From the perspective of the action plan for new pollutants and the list of key control new pollutants, POPs are the most important new pollutants. "In the past, when we talked about POPs, we were more in terms of implementing the Stockholm Convention. After the promulgation of the Action Plan for the Treatment of New Pollutants, the organic integration of domestic control and international compliance of POPs has been promoted, and mutual promotion has been promoted. ”
In the Draft for Comments, POPs substances in the annex to the Stockholm Convention are also the focus of attention. For example, the Consultation Paper emphasizes that when the ecological and environmental authorities at all levels accept and approve the EIA documents for construction projects in key industries, they will not approve new construction, reconstruction and expansion projects with a number of key controlled new pollutants as products or raw and auxiliary materials, including perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA), decabromodiphenyl ether, short-chain chlorinated paraffins and other POPs.
"This regulation will better support the treatment of new pollutants and the compliance of POPs in the mainland, and more effectively supervise new pollutants such as POPs in related industries." Wang Bin analyzed.
The reporter noted that the key industries emphasized in the "Draft for Comments" include petrochemicals, coatings, textile printing and dyeing, rubber, pesticides, medicine, electroplating, tanning, etc.
"If it is implemented, it will promote the strengthening of the source prevention, process control and end-to-end treatment of new pollutants in the above-mentioned industries. For relevant enterprises, they may face challenges in capacity building, green substitution, cleaner production, industrial upgrading and transformation, technology and capital investment, etc. However, solving these problems in accordance with the requirements is also an opportunity for the industry and enterprises to enhance product competitiveness, break through green trade barriers, and achieve green and sustainable development. Wang Bin said.
All localities should strengthen capacity building and technical support
It is worth mentioning that the current control of new pollutants in the mainland is in its infancy.
According to the Consultation Paper, the scope of control of new pollutants in mainland China is not clear, the relevant environmental standard system to support the assessment of new pollutants is not yet perfect, there are large gaps in environmental quality standards, pollutant discharge standards and environmental monitoring standards, and there is a lack of evaluation basis in the environmental impact assessment.
However, at the same time, it also put forward the requirements for the local ecological environment department to "actively explore and improve the EIA management of construction projects involving new pollutants", and made it clear that the local ecological environment department should timely include the list of construction projects involving new pollutants that are not approved into the ecological environment access list for ecological environment zoning control, and update and continuously improve the EIA management requirements for construction projects in a timely manner according to the relevant lists and documents.
Previously, the reporter learned that before September 30 this year, all provinces should submit their implementation plans for the "National Implementation Plan" on POPs control to the Ministry of Ecology and Environment, and there are only 3 months left before the submission of the file. In the future, the control of POPs and the management of environmental impact assessment of new pollutants will become a key task of local ecological and environmental departments. "It's a new and complex job for a lot of places. Local ecological and environmental departments should explore and learn in the process of implementing new pollutant treatment plans, gain experience in practice, and improve their own capabilities. Wang Bin said.
Wang Bin analyzed, first of all, in accordance with the principle of national overall planning, provinces (autonomous regions and municipalities directly under the central government) taking overall responsibility, and cities and counties implementing, local governments should strengthen the organization and leadership of new pollutant governance, establish and improve the coordinated control mechanism of various departments, and effectively promote the treatment of new pollutants. Secondly, it is necessary to strengthen capacity building, on the one hand, to improve the management capacity of local ecological and environmental departments, and on the other hand, to strengthen the capacity and platform construction of local technical support units.
The Draft for Comments points out that local governments can select typical projects in key industries on a pilot basis, and explore methods for accounting for the source strength of new pollutants in construction projects, methods for assessing the impact of the ecological environment and population health, and control measures for new pollutants according to the latest management requirements and research progress of new pollutants.
"At the same time, it is a feasible path to actively seek the guidance and support of the country's superior technical units. According to the actual situation, the local ecological environment department should work with technical support units and enterprises to actively explore the management methods and practices of environmental impact assessment of construction projects involving new pollutants with the idea of reform and the power of technology, summarize lessons and lessons in practice, form good practical experience, provide demonstration for the control of new pollutants and the management of environmental impact assessment, and gradually form and improve relevant guidelines and norms. Wang Bin said.
Build a strong line of defense for new pollutants to enter the recycling system
Although the Consultation Paper proposes that the construction projects of some industries involving new pollutants will no longer be approved, the management and harmless disposal of new pollutants already existing in the environment should not be ignored.
The reporter noted that the State Administration for Market Regulation recently issued the "Guidelines for the Recycling and Reuse of Plastic Waste", which provides guidance on source recovery and reuse, material standards and product specifications in the process of recycling and reusing plastic waste. The European Parliament also recently agreed on new rules to reduce, reuse and recycle packaging. In recent years, plastic recycling has gradually become an international consensus.
However, Wang Bin told reporters that plastics usually contain many chemical additives. Failure to scientifically evaluate and recycle means that plastic chemical additives are also recycled in the plastic recycling chain, including banned chemicals.
In May 2023, the United Nations Environment Programme (UNEP) released the "Chemicals in Plastics: Technical Report", which pointed out that there are more than 13,000 known or detected chemicals in plastics, of which more than 7,000 have been analyzed and more than 3,200 are of concern.
"These substances are used as stabilizers, plasticizers, antioxidants, light stabilizers, flame retardants, etc., to make plastic products meet performance requirements. Many of these are POPs and endocrine disruptors that we need to focus on. At the same time, due to the low environmental standards of plastics in the early days, the content of toxic and harmful substances may be relatively high, and they may also contain chemicals that have been banned from production and use. Wang Bin said.
For example, many plastic and rubber products contain short-chain chlorinated paraffins (SCCPs), which have been included in the Annex A controlled list of the Stockholm Convention and the list of new pollutants under priority control on the mainland, and the mainland has completely banned their production and use by the end of 2023.
In September 2023, the Global Plastics Pact "Zero Draft" was released, which calls for the elimination or reduction of chemicals and polymers of concern in plastic production. However, the current recycling of plastic-containing waste is not ideal, and the rate of formal harmless recycling and disposal is not high, which may lead to toxic and harmful chemicals entering the environment.
How to carry out risk-controlled, scientific and effective plastic waste recycling? In Wang Bin's view, this requires separation and classification in the recycling process, understanding the information of polymers and non-polymeric chemicals in recycled plastic waste, screening and identification of toxic and harmful additives if necessary, and safe treatment and disposal of toxic and hazardous waste released in the recycling and disposal process. It is necessary to build a strong line of defense through scientific assessment and control, and prevent the toxic and harmful chemicals that have been banned in plastic waste from entering the recycling of recycled plastic products from the source.
Industry insiders told reporters that it is necessary to appropriately determine the content limit of POPs in plastics. When the POPs content in the corresponding waste is below the limit, the conditions for waste recycling are met and can enter the recycling system, which is a new requirement that needs to be considered when the current POPs waste management guidelines are formulated. In the next step, the management and harmless disposal of POPs waste should continue to improve the identification standards for the content, and form special detection methods and technical specifications.
Source: China Environment
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