Comply with me
Compliance with the Integrated Pollution Prevention and Control regime needn't be as painful as you think. Peter McCrum finds out how to avoid the pitfalls
Pained looks and a furrowed brow are the reaction you’ll get if you mention IPPC within earshot of a major manufacturer. For many, compliance with the Integrated Pollution Prevention and Control permitting regime is the regulatory equivalent of undergoing extensive root canal surgery – painful and expensive. But comply they must, and fortunately there are some experienced people out there whose job it is to soothe the bewildered and exasperated along the path towards full compliance and a clean bill of regulatory health.
One of those people is Susan Parr, principal environmental scientist at consultancy White Young Green. Parr has worked on IPPC permit applications with a range of organisations, from bakeries, millers, distillers and other manufacturers from the food and drink sector to producers of non-ferrous metals and organic chemicals. Parr is currently working with a major Scottish distillery, and is implementing an environmental management system alongside its IPPC application.
There are considerable advantages to this – it will save the client money and help them manage the environmental baseline data they are generating for IPPC in a way that will help with the permit in the future.
IPPC requires information on a whole range of environmental issues and an integrated environment management system provides the kind of data gathering control that will considerably facilitate this task. Applicants also score points for the application if there is environment management system in place. The Environment Agency uses a system called the Environmental Protection Operator Performance and Risk Appraisal System (EP OPRA) to calculate fees and charges for IPPC applicants. Management systems and techniques are one of the key areas used to calculate costs. The more effective the management system, the lower the costs, so there is a direct relationship between the EMS and the cost of the IPPC application.
A typical application from the food and drink sector would cost around £15,000, with an ongoing subsistence charge of about £8,000. It would generally take around 12 months to process.
Parr is finding that the food and drink sector is experiencing a culture shock – it has never been under direct regulation in the way that other industries that come under IPPC are used to. “Companies are having to get to grips with a whole raft of environmental issues that they have never really faced before, so there has never been the need to use environment management systems,” Parr says.
“But we have found that our clients, particularly some of the bigger organisations, are already very focused on resource management and efficiency. However, many struggle with the amount of work that is required and the volume of guidance that has to be read and understood to put an application together.
“The Environment Agency produces application templates on CD-ROM which tend to change quite frequently. You might start an application with one template, then four weeks later they will issue another. The Agency has been moving the goalposts, which can be very frustrating and absolutely horrendous to deal with. Consultants agree that there could be a little more forethought and clarity from the regulator.”
Right first time
Consultants take a lot of the pain out of a long, complicated and frustrating process. However, they will add a significant cost to what is already an expensive business.
But if companies want to get the application right first time and reap the financial and managerial benefit of having an environmental management system in place, taking this simultaneous approach with the application and the installation of the EMS system would seem to make sound business sense.
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