IPPC in the food and drink industry
Co-founder of Partners in the Environment (PIE) International, Dr Stephen Etheridge, examines how the impending IPPC legislation will affect an industry as diverse as food and drink processing.
The IPPC Directive has its roots in IPC, the process based industrial permitting system which targeted major potentially polluting processes. IPPC is crucially different. It is effectively a permit to operate an industrial plant or factory (unhelpfully known as an ‘installation’ and open to its own range of interpretations) and covers all emissions to the environment and their potential impacts. Although there are production thresholds given which make it possible for some smaller installations to be exempt, these are usually so low that they are rarely applicable to economically viable industries in most developed European Countries. Supposedly all targeted industrial sectors across Europe must comply at the same time with the same level of enforcement.
There are murmurs that this may not be the case, however, and that the ‘playing field’ is not as level as it might be. Interestingly, many countries struggling for European accession are in the throes of implementing IPPC strategies at this moment, although often on the basis of extended timetables. One can only wonder at the wisdom of forcing IPPC on industries in countries which have grossly polluted rivers and cities, few sewage works and even fewer landfills.
Food & drink sector
The key difference between the food & drink sector and other sectors which have been subject to IPPC to date, is the diversity of the industry. The UK regulation specifies different sectors within each industry and while these have so far been relatively focused (Paper, Textile, Minerals) the food & drink industry covers aspects as diverse as food preparation, baking, brewing and animal slaughter.
How can a Directive of less than 20 pages address all these aspects? As ‘horizontal legislation’ it incorporates a range of previously defined practices such as Environmental Management, Waste Minimisation, Environmental Assessment etc. And for the new Best Available Technology (BAT) requirements, it defers to special recommendations tailored to the needs of each sector. These are developed centrally by the EU and in this case Seville has been selected as the location for this activity.
Representatives from the EU countries, including the UK Environment Agency have been making visits to Seville to develop guidelines applicable to each particular sector and subsector. The resulting BREFs provide an interesting insight to the state of European industry, not least because of the industrial benchmarks given to test if a particular installation is operating within industrial norms.
Guidelines are just that, however, and not easy to enforce. BATs have already been subject to different interpretations and more comprehensive lists are increasingly available which describe in detail which technologies might be used in each sector and in each part of the process. If one new technological breakthrough occurs in, say, Finland, companies would be reasonably expected to deploy that system in a short period of time. This is an important point, and there are concerns that this will constrain processing innovation and flexibility.
The deadline for IPPC applications and the inevitable conditions which result may be 18 months away, but equipment being purchased now, both in-process and for the dreaded end-of-pipe will be expected to last much longer. It is worth checking now if the equipment/systems under consideration for purchase in the next 18 months are a Best Available Technology or not.
18 months seems like a long time. Fill in a form and be done with it? Not so. What is required is a series of site assessments and that systems are put in place and are up and running long before then. Remember the pain of ISO 9000, Efsys , HACCP and other food industry requirements? Two key iterative systems are needed. Environmental Management and Waste Minimisation.
Arguably, the first Environmental Management System was BS7570, which morphed into ISO14000 series and has since been slightly extended with voluntary reporting as the EU EMAS scheme. Is this really required under IPPC? The EU says that ISO14000/EMAS is not mandated under IPPC. The UK EA says, “is there another Environmental Management System?”. Perhaps there is some scope for an intermediate stage?
Many companies seem to accept that ISO14000 will be all pervasive at some point but are sceptical about the costs of implementing it now. One popular solution seems to be to implement ISO14000 but not certify the process. This then, becomes a relatively simple step at a later stage. It is also easy to let the environmental discipline lapse, however. Its extension to include the voluntary reporting required under the European EMS system is not mandated, but interestingly where EU Laws such as IPPC are being transposed in pre-accession countries, no other standard than EU EMAS is being referred to (where European money is paying for implementation).
Waste Minimisation is another live process and should result in many of the improved materials and energy efficiencies needed under IPPC (including data needed to justify Climate Change Levy rebates, if these have been applicable). The authors were involved in the UK’s first single sector (food & drink industry) waste minimisation programme and this took 18 months to get established.
Still there is more though, Site Assessments, Risk Assessments, Environmental Impact Assessments also form part of this complex process.
New installations are obliged to implement these regulations immediately and the authors have already one client who has been successfully awarded a Permit in the food & drink industry. As a result of this wake-up call he is getting the rest of the installations in his group ready now.