Green issues with a taste of the commercial
The task of the environmental manager in the food industry is heavily garnished with issues fundamentally commercial in nature, and which bite if mismanaged. Richard Poynton, founding director of specialist environmental consultancy Business Benefits Ltd, samples environmental liability in the food sector.
At first sight, the task of managing environmental liability in the food
industry may look similar to corresponding liability management in any
process sector which uses natural raw materials and large amounts of energy
To add a further frisson to the challenges of managing environmental
liability in the food sector, the profile of these issues can be raised or
lowered dramatically by the media focus of the day. A supplier’s telephones
will start ringing very quickly if his spillage is reported as ‘X COMPANY
POLLUTES RIVER’, where ‘X’, the name of a well known supermarket, happens to
be one of his big customers. If the supplier makes products for the
supermarket’s ‘own-label’, the allegation may be even sharper, i.e. ‘X
POLLUTES RIVER’. So what sort of liabilities does the food sector
environmental manager have to manage?
In processing, interactions with the water medium present the biggest set of
issues. Water is used as a product ingredient, for washing produce, and as a
heat transfer medium for heating, cooking and cooling. Yet more water is
needed for cleaning and sanitising equipment, to maintain product quality
and safety as well as plant efficiency. The resulting water management
issues are on a large scale and are matched by those of waste water
management, be this discharged directly to sewer, or indirectly via on-site
pre-treatment. Some rurally based plants, e.g. dairies, may discharge to the
local river post pre-treatment, for want of an available sewerage
connection. This adds further issues, especially in hot summers, when the
site’s discharge may contribute a major proportion of the river flow.
Do not assume that all the effluent from a food processing operation is
environmentally benign. Produce washing can result in high levels of
suspended solids. Plant juices and animal proteins can lead to high levels
of biochemical oxygen demand and some processes, e.g. beetroot or onion
washing result in strongly coloured or smelly effluents. Looking at
chemicals, strong caustic and/or acidic solutions, often complemented by
searching detergents, are used to clean food residues from process
equipment. Sanitisers are powerful biocides, deliberately designed to be
effective at low concentrations. Discharges from cleaning cycles come in
‘slugs’, with the risks of big swings in both the pH value (acidity) and temperature of
the resulting effluent. Robust procedures and constant vigilance are required, to achieve satisfactory compliance with discharge consents.
To add to the liability management task, food processing plants are commonly
sited close to ‘controlled waters, or in rural areas above important
aquifers. The potential liabilities arising from the bulk storage and
handling of pollutants such as fuel and edible oils, milk, vinegar, sugar,
flour, mineral and organic acids, cleaning fluids, biocides and enzyme
preparations in these locations are considerable. Again, if a big spillage
occurs, the media focus will be on the retailer rather than the processor,
switching on immediately the commercial dimension of the incident.
Brewing, baking, frying and freezing all generate process emissions to air,
to which can be added dusts from drying and ingredients-handling operations.
Refrigeration, which is used on a large scale, presents the risk of
releasing ammonia, a ‘prescribed substance’ and/or compounds which are
either ozone depleters or greenhouse gases. Materials such as spices, which
in small quantities add delight to the product, can easily cause an odour
nuisance if poorly handled in bulk. Raw materials such as onions and vinegar
can also be strong smelling. Putrescible wastes require careful management,
particularly in hot weather, to avoid nuisance liabilities.
Noise is another important food sector issue meriting careful management.
Refrigeration equipment operates round the clock, seven days per week, even
if the site as a whole works more social hours. Loading operations involving
fork-lift trucks and HGVs with refrigeration units are extended over ever
longer periods to meet the retailers¹ needs for seven-day opening. Traffic
movements themselves can be a significant issue, especially for large plants
in small towns. High speed equipment such as centrifuges and/or heavy
equipment such as mills, generate low-frequency noise which can be
disturbing several kilometres from the plant. Quite reasonably, as quality
of life becomes more valued, the old arguments which
portrayed these impacts as part of the price of local employment, are no
longer accepted by local communities.
Disposals to land include waste from produce handling which may be taken by
local farms as an animal feed supplement and soil from produce washing which
may be returned to land. Again, careful control is needed, supported by the
requisite documentation. Compared to other sectors, there may be larger
amounts of packaging waste which have to be dealt with in compliance with
the new regulatory concept of ‘producer responsibility’. In this context,
practices must be robust enough to handle one-off packaging wastes, such as
those generated by ‘opportunity’ business scheduled at short notice e.g. a heap
of sharp, slippery cans without triggering liabilities from staff injury, or from the infringement of regulations.
Waste management can present particular headaches for the food sector
environmental manager. Natural instinct, endorsed by good food hygiene
practice, results in wastes being stored as far away as possible from food
production and handling areas. Inevitably, there is a temptation to hold
waste by the site boundary and/or in parts of the site which are remote and
difficult to monitor. This raises liabilities with respect to the ‘duty of
care’ aspects of waste management, particularly as regards the escape of
waste and also to odour nuisance. If, as was noted earlier, the boundary is
close to a controlled water, there will be additional liabilities to manage.
Similar considerations arise in relation to on-site waste water treatment
In managing these liabilities, the food sector manager must grapple not only
with costs, but also with the need to maintain high standards of food
safety, hygiene and product quality. Sometimes there are conflicts, as when
the most effective dust emissions control system generates product traps
harbouring food spoilage organisms and the risk of impaired product quality.
Cutting energy usage may conflict with the need to ensure adequate
time/temperature processing conditions and tough targets for reducing water
usage may challenge the requirements for adequate plant cleaning. In these
circumstances, there is a need for good judgement today and for better methods tomorrow, if the food sector is to deliver high quality, affordable products with diminishing environmental impacts and liabilities.
The arrival of the Integrated Pollution Prevention and Control (IPPC) regime
presents the food sector with permit-based regulation of emissions and of
resource usage, for the first time. In the author¹s view, this is to be
welcomed. IPPC should clarify what is to be managed within one permit;
policed by one regulator. Once the groundwork of writing the IPPC permit application has been completed, compliance and liability management should become easier. Not the least reason why the food sector currently suffers a relatively high rate of
prosecutions for environmental offences compared to other manufacturing
sectors, is the complexity of the task of complying with the existing, fragmented legislation, policed by different regulators. Making compliance simpler, IPPC will bring a momentum for better management practice and for the development of better tools with which to manage resources, emissions and their associated liabilities.
Eat your greens
Given the high public profile of both food related and environmental issues, it is inevitable that the management of environmental liability in the food sector is a
sensitive and demanding task. Food sector businesses have much to gain by investing
in sound environmental management, if this can be used to establish a
performance record which builds confidence amongst customers, investors and insurers, and builds business opportunity. By the same rule, there is a lot
to lose, from poor management resulting in pollution, liability and the attendant risk of loss of business. The keys to effective environmental liability management
in the food sector are, first, a clear and constantly updated understanding of the issues and impacts which present these liabilities, and second, the adroitness to
deploy the right expertise in a way which delivers a record of sound risk management
performance. The third key is achieving the consistency in performance
despite the shifting media focus and the ever present commercial
consequences of error. Food businesses which get this right should savour a
bigger bite of the ‘cake’ which is their marketplace.
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