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.
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 plants.
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.