{
  "url": "https://openlegislation.uk/eu-decision-2020-2009/annex/division-1/division-1.1/division-1.1.1/division-BAT",
  "json_url": "https://openlegislation.uk/eu-decision-2020-2009/annex/division-1/division-1.1/division-1.1.1/division-BAT.json",
  "legislation": "eudn/2020/2009",
  "legislation_title": "Commission Implementing Decision (EU) 2020/2009 of 22 June 2020 establishing the best available techniques (BAT) conclusions, under Directive 2010/75/EU of the European Parliament and of the Council on industrial emissions, for surface treatment using organic solvents including preservation of wood and wood products with chemicals (notified under document C(2020) 4050) (Text with EEA relevance)",
  "legislation_url": "https://openlegislation.uk/eu-decision-2020-2009",
  "path": "annex/division/1/division/1.1/division/1.1.1/division/BAT",
  "kind": "division",
  "number": "BAT 1",
  "heading": "In order to improve the overall environmental performance, BAT is to elaborate and implement an Environmental Management System (EMS) that incorporates all of the following features:",
  "text": "(i) commitment, leadership, and accountability of the management, including senior management, for the implementation of an effective EMS;\n(ii) an analysis that includes the determination of the organisation’s context, the identification of the needs and expectations of interested parties, the identification of characteristics of the installation that are associated with possible risks for the environment (or human health) as well as of the applicable legal requirements relating to the environment;\n(iii) development of an environmental policy that includes the continuous improvement of the environmental performance of the installation;\n(iv) establishing objectives and performance indicators in relation to significant environmental aspects, including safeguarding compliance with applicable legal requirements;\n(v) planning and implementing the necessary procedures and actions (including corrective and preventive actions where needed), to achieve the environmental objectives and avoid environmental risks;\n(vi) determination of structures, roles and responsibilities in relation to environmental aspects and objectives and provision of the financial and human resources needed;\n(vii) ensuring the necessary competence and awareness of staff whose work may affect the environmental performance of the installation (e.g. by providing information and training);\n(viii) internal and external communication;\n(ix) fostering employee involvement in good environmental management practices;\n(x) establishing and maintaining a management manual and written procedures to control activities with significant environmental impact as well as relevant records;\n(xi) effective operational planning and process control;\n(xii) implementation of appropriate maintenance programmes;\n(xiii) emergency preparedness and response protocols, including the prevention and/or mitigation of the adverse (environmental) impacts of emergency situations;\n(xiv) when (re)designing a (new) installation or a part thereof, consideration of its environmental impacts throughout its life, which includes construction, maintenance, operation and decommissioning;\n(xv) implementation of a monitoring and measurement programme; if necessary, information can be found in the Reference Report on Monitoring of Emissions to Air and Water from IED Installations;\n(xvi) application of sectoral benchmarking on a regular basis;\n(xvii) periodic independent (as far as practicable) internal auditing and periodic independent external auditing in order to assess the environmental performance and to determine whether or not the EMS conforms to planned arrangements and has been properly implemented and maintained;\n(xviii) evaluation of causes of nonconformities, implementation of corrective actions in response to nonconformities, review of the effectiveness of corrective actions, and determination of whether similar nonconformities exist or could potentially occur;\n(xix) periodic review, by senior management, of the EMS and its continuing suitability, adequacy and effectiveness;\n(xx) following and taking into account the development of cleaner techniques.\nSpecifically for surface treatment using organic solvents, BAT is also to incorporate the following features in the EMS:\n(i) Interaction with quality control and assurance as well as health and safety considerations.\n(ii) Planning to reduce the environmental footprint of an installation. In particular, this involves the following:\n(a) assessing the overall environmental performance of the plant (see BAT 2);\n(b) taking into account cross-media considerations, especially the maintenance of a proper balance between solvent emissions reduction and consumption of energy (see BAT 19), water (see BAT 20) and raw materials (see BAT 6);\n(c) reducing VOC emissions from cleaning processes (see BAT 9).\n(iii) The inclusion of:\n(a) a plan for the prevention and control of leaks and spillages (see BAT 5 (a));\n(b) a raw material evaluation system to use raw materials with low environmental impact and a plan to optimise the use of solvents in the process (see BAT 3);\n(c) a solvent mass balance (see BAT 10);\n(d) a maintenance programme to reduce the frequency and environmental consequences of OTNOC (see BAT 13);\n(e) an energy efficiency plan (see BAT 19 (a));\n(f) a water management plan (see BAT 20 (a));\n(g) a waste management plan (see BAT 22 (a));\n(h) an odour management plan (see BAT 23).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/eudn/2020/2009/annex/division/1/division/1.1/division/1.1.1/division/BAT",
    "retrieved_at": "2026-11-01T15:12:03.527850+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}