How has business behaved?
Darcy Products' John Proctor on environmental performance in 2002Referred to in Environment Agency (EA) chief executive Barbara Young's introduction as "a regular fixture in the environmental calendar" Spotlight on Business Environmental Performance 2002 aims to document environmental performance of business in England and Wales for 2002.
Given that it runs to only 35 pages, this is perhaps a touch ambitious but despite the inevitable generalities there has been welcome progress and the report contains much to interest those whose day-to-day involvement is in environmental protection. General river quality continued to improve in 2002 and air pollution continued to fall.
There were 1,468 serious (category one and two) pollution incidents in 2002, 21% fewer than 2001 but 14% up on 2000. Of these, more than 50% were from sectors not regulated by the agency.
The report shows for the first time the extent to which water companies have complied with consents to discharge. Overall, compliance is high - Wessex Water Services and Yorkshire Water Services achieving 100% compliance, the latter for the fourth time in five years. Apart from South West Water, all other major companies achieved 99% compliance. Although there has been improvement, the water industry was responsible for one in six category one and two pollution incidents affecting water. Thames Water Utilities accounted for the most with 32 and Wessex Water Services only eight.
Adjusted for size of population, South West Water was the highest with 7.33 and United Utilities Water the lowest with 1.01. The latter, however, led the table both for the number of prosecutions (29) and total fines (£327,500). In all, water companies were fined almost £1M in 2002. The industrial sector with the largest number of regulated operators, the chemical industry, continued to improve with reduced emissions of most substances and a low number of significant fines.APPRECIATION
Although a few companies are singled out for outstanding performance, writing from the perspective of a company currently devoting much of its time and resources to assisting industry in meeting environmental obligations, one would have liked to have seen evidence of greater appreciation of the efforts being made by businesses across all sectors.
No right-thinking person would dispute Young's call for higher fines, "environmental crime should not pay", to balance environmental concerns with those of financial directors, shareholders, etc, while continuing to concentrate on the overriding task of remaining in business and making a profit is to walk a difficult, often dangerous, tightrope.
Some recognition of the difficulties, not least in seeing off less strictly regulated overseas competition, would have been welcome. First among five of the report's key findings is that poor waste management is an increasing concern. It seems destined to remain so.WASTE SECTOR
The report identifies the waste sector as being responsible for more pollution incidents than any other industrial sector.
In this context, the waste sector includes incinerators (regulated under EA applied Integrated Pollution Control), landfills, transfer stations and treatment facilities (regulated as licensed waste management facilities). Only 41% of IPC sites, for example incinerators, are classified as 'well managed', 18% improved, 4% got worse. Of waste management facilities, 38% were fully compliant with their licence conditions and 49% performed well. Landfill sites had the best compliance record (46%) and a 31% improvement in overall operator performance since 2001, but also the highest % of poorly managed sites.
This 31% improvement in landfill sites compares with 17% improvement at waste transfer facilities and negligible improvement at treatment sites. Of the ten worst performing, licensed waste management facilities named in the report, half improved during 2002 and the EA's declared aim is a 10% improvement in the 730 worst performing sites.
This could prove over-ambitious. The new landfill regulations due to come into force in July 2004, following implementation of the Landfill Directive, do not figure in the report but it is difficult to see how they can fail to inhibit any significant improvement in the coming year.
With new definitions, hazardous waste is estimated as likely to increase from 5M tonnes (EA figures) to as much as 7.5M, all of which, if landfilled, can only be disposed of at the currently very small number of licensed sites. Cost to industry of hazardous waste disposal is currently £150M. From July 2004 this figure could, according to recent estimates, more than treble. With agricultural waste classified from mid-2004 and recycling continuing to lag behind much of Europe, this will surely mean, if past experience is a reliable guide, more fly-tipping. At least in the short-term. According to Spotlight, fly-tipping accounted for 14% of all serious pollution incidents during 2002, rising from 166 in 2001, to 200 in 2002. Although harsher penalties might help to check the trend, more licensed sites, particularly in the south of England, would seem to be a number one priority. Although according to EA statistics, oil and oil/water mixtures currently account for 20% of hazardous waste, oil pollution gets only a brief mention in the report. This is, however, one sector where improvement can be expected in the wake of implementation of the second stage of the Control of Pollution (oil storage) Regulations.GROWING INTEREST
This at least would seem to be the case, judging by the greater environmental awareness evident across all sectors of industry. As the implications of the regulations become clearer, there is fast growing interest, not only in equipment - emergency spill kits, drain sealing equipment, containment systems, etc - but in associated services such as risk assessment, bund and tank surveys and pollution control training courses.
There is only a single reference in the report to ISO 14001 accreditation. Apparently, as a matter of policy, the EA does not actively promote 14001, considering it of no proven benefit to environmental performance. Nevertheless, in the case of the clinical waste incinerator operator singled out for improving its operator performance appraisal (OPA) score by two bands, the company's success is said to have come "through its efforts to gain full ISO 14001 accreditation". Many of us involved at the sharp end of pollution control will welcome this recognition. With maintenance budgets often stretched to the limit, there is a widespread view that without the systems introduced to obtain ISO 14001 accreditation, industrial pollution would increase rather than decline.
Although many companies are striving to reach its standards, ISO 14001 has its problems. Accreditation is both difficult to achieve and expensive. There is no central register of accredited companies, which detracts somewhat from the commercial advantages.
We do not even know how many UK companies are accr-edited. EA scepticism notwithstanding, encouragement from central government - grant aid perhaps - could only benefit the environment.