First, the new Integrated Pollution Prevention and Control (IPPC) regime will, for those regulated under it, require the management of the total emissions and usages relating to the entire installation. Regulation will be via permits to operate, which will set control limits for emissions and materials and utilities usage, but which will be designed to ensure that best practice, as expressed by the principles of “Best Available Techniques” (BAT), is applied.

Initially, this will demand measurement and management sufficient to control the emissions and usages of the whole installation. Over time, because the emphasis of IPPC is on prevention, it will require process and product management to be designed as an integrated whole. This will require a new approach, in which minimising environmental impact will be a design criterion of equivalent significance to operating cost and functional effectiveness.

Second, the outlines of ‘sustainable operation’ are now beginning to emerge from the uncertainties surrounding the concept. What is becoming clear, is that manufacturers will carry much more responsibility for the stewardship of the materials which they bring into the commercial cycle. This means going several steps further than looking holistically at your own plant, to looking at the whole life impact of a product, from raw material production/extraction, through the supply chain, manufacturing stages, product distribution and on to final disposal.

There should be no ‘wastes’ as such – only secondary materials, for which the business which generated them will have an obligation, under Producer Responsibility, to find an acceptably productive use. Such materials stewardship obligations are a natural development of regimes such as that of packaging waste – the first of an intended series forming the stepping stones towards sustainable operation.


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