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International standards

QCVN, EHS Guidelines, WHO and US EPA: choosing reference standards and methods in environmental assessment

Internationally financed projects often need to check Vietnamese technical regulations, the EHS Guidelines, the WHO Air Quality Guidelines and US Environmental Protection Agency (US EPA) methods side by side. This note summarises the role of each.

In environmental and social assessment for internationally financed projects, a recurring question is which standard applies and which method demonstrates compliance. It helps to separate compliance limits (what the project must meet) from technical methods (how emissions and impacts are estimated and predicted).

Compliance limits

  • National technical regulations (QCVN) are legally binding in Viet Nam. For example, QCVN 05:2023/BTNMT on ambient air quality, issued with Circular 01/2023/TT-BTNMT, replaced QCVN 05:2013/BTNMT and QCVN 06:2009/BTNMT; its annual PM2.5 limit is 25 µg/m³.
  • World Bank Group EHS Guidelines apply to projects financed by IFC, Equator Principles banks and many other lenders. Where QCVN and the EHS Guidelines differ, the project is expected to meet the more stringent level unless a justification is accepted by lenders.
  • WHO Global Air Quality Guidelines, released on 23 September 2021, lowered the annual PM2.5 guideline from 10 to 5 µg/m³ and the 24-hour guideline from 25 to 15 µg/m³. The General EHS Guidelines refer to the current WHO Air Quality Guidelines where the host country has no standard.

The gap between QCVN and WHO is substantial (annual PM2.5: 25 versus 5 µg/m³). Background concentrations in many parts of Viet Nam already exceed WHO guideline levels; in such degraded airsheds, the General EHS Guidelines expect any increase from the project to be as small as feasible and only a fraction of the applicable standards, and assessments should clearly present background levels, the project's contribution and the resulting total.

US EPA technical methods

The US EPA has no jurisdiction in Viet Nam, but several of its tools are widely used in international environmental assessment:

  • AERMOD: the dispersion model adopted by the US EPA as a preferred model in its Guideline on Air Quality Models (Appendix W to 40 CFR Part 51), under a rule published on 9 November 2005 and effective on 9 December 2005; the Guideline was updated in 2017.
  • AP-42: the US EPA compilation of air pollutant emission factors, published since 1972, with the fifth edition issued in 1995 and updated chapter by chapter, covering more than 200 source categories. Emission factors support estimates where measured data are not available; their reliability depends on the quality of the underlying data for each factor.

When these tools are used, the report should state the model version, meteorological inputs, emission factors and their reliability, so that both national reviewers and lenders' experts can verify the results.

Sources

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