Green issues with a taste of the commercial

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

and water.

Further frisson

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.

Ingredients handling

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.

IPPC

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.