Slayt 1

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Impact of the Directive on the Turkish SMEs
according to their Industrial Scale and in
particular on those (operating) in chemical
sector and their position in the framework of the
IPPC directive.
Mustafa Bagan Assembly Member of Chemical
Sector Assembly of TOBB and General Secretary of
Turkish Chemical Manufacturers Association
06 November 2009 Ankara
2D picture of a 3D art work of Hittite Sun Disk
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• TCMA was established in 1986

Turkish Chemical Manufacturers AssociationTürkiye
Kimya Sanayicileri Dernegi

• Representing approx. 60 of the Turkish chemical
  sector turnover.

• Full member of CEFIC (European Chemical Industry
  Council)

• TOBB and Chambers of Industry
• NGO Platforms
• Public/Media Relations

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.A breef history of Turkish Chemical Industry
In 1970s Private sector began to invest in the
chemical industry .
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Today Turkish Chemical Industry

• Approximately 3.000 goods and commodity groups
• subject to production in the Turkish
  Manufacturing
• Industry

Raw materials Petrochemicals, Cromates, Soda
ash, Saltz, Borax
Commodities Fertiliser, Pesticides, Veterinary
products,
Consumers products Soaps, Detergents, Household
Products, Personel Care, Paints and Varnishes,
Glues, Pharmaceuticals,
Auxiliary Products for textiles, leather,
pharmaceuticals, Construction, Soap and
Detergents, Cosmetics, Papers,Otomotive, Paint
and Varnishes industries
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Turkey 20 billion Euros 1,1
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Imported Chemicals
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Exported Chemicals
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Entreprises and Employments in Turkish
Manufacturing Industry
Source Turkish Statistical Institute-TUIK
According to TUIK in 2005 there were 13.392
entreprises and 168.435 peoples were employed in
the chemical industry.
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Distribution of Employment in the Chemical
Industry ()
? 80 SMEs
() Source Turkish Statistic Enstitute
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Environmental Management Institutionalisation in
Turkey
Un.Secretariat of Environment 12/08/1978 -16 376
Waste Water Air
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Distribution of Regulations
Law No. 2872
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Internal and external barriers to implement EMS
among SMEs (Hillary, 1999)
Internal Barriers
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Internal and external barriers to implement EMS
among SMEs (Hillary, 1999)
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How Green is My Firm
Aims
1- Chemical sector awarness and implementation of
Turkish environmental legislation.

• Industrial solid wastes
• Emissions to air
• Waste water treatment

24.Basic chemicals 25.Misc. Chemicals 26.Coating
industry (paint and warnishes) 27.Soaps and
cosmetics industry 28.Pharmaceuticals and
medicinal products
2- The out-puts of questionnaires
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(No Transcript)
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Total Responses
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Nos
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Dont Knowing
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EU Directives
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ANNEX I CATEGORIES OF INDUSTRIAL ACTIVITIES
REFERRED TO IN ARTICLE 1
1. Energy industries .. 4. Chemical
industry Production within the meaning of the
categories of activities contained in this
section means the production on an industrial
scale by chemical processing of substances or
groups of substances listed in points 4.1 to
4.6. 4.1. Chemical installations for the
production of basic organic chemicals, such
as 4.2. Chemical installations for the
production of basic inorganic chemicals, such
as 4.3. Chemical installations for the
production of phosphorous-, nitrogen- or
potassium-based fertilisers (simple or compound
fertilisers). 4.4. Chemical installations for the
production of basic plant health products and of
biocides. 4.5. Installations using a chemical or
biological process for the production of basic
pharmaceutical products. 4.6. Chemical
installations for the production of explosives.
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PPC is expensive and time-consuming
Example !

• Agency application fees are tip of the iceberg !
• Typical chemical industry application 1 person
  1 year to produce
• Specialist help with site report, emissions
  modelling etc
• Annual EP-OPRA charges !
• Surrender charges !

EP-OPRA Environmental Protection Operator
Pollution and Risk Appraisal
IPPC Management in SMEs Janet Murfin
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PPC hits smaller companies harder
Example !

• Charges are higher proportion of profits
• Less/no spare manpower for application
• Less in-house technical knowledge (eg no
  environmental manager)
• May affect profitability
• May put businesses off growing into areas of work
  covered by PPC regulations

IPPC Management in SMEs Janet Murfin
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Graph showing impact of annual PPC charges alone
on SME profits
Example !
IPPC Management in SMEs Janet Murfin
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Company DM PPC lifetime costs
Example !

• EA fees per year currently 4 k
• Lifetime costs
• Application fees 8k
• Maintenance fees (three years) 12k
• Surrender fees 12k
• Consultancy fees (2 site reports) 16k
• Total cost 48k
• True cost per year 16k

IPPC Management in SMEs Janet Murfin
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TÜRKIYE KIMYA SANAYICILERI DERNEGI Turkish
Chemical Manufacturers Association
Thank you for your Attention ! Questions ?
www.tksd.org.tr