Winds of change in the right direction

Chris McDonald, associate and manufacturing sector leader with Golder Associates, discusses the issues and benefits surrounding the new Pollution Prevention and Control regulations due to impact the food & drink industry.

The Pollution Prevention and Control (PPC) regulations are here. Some food manufacturers have been here before under Integrated Pollution Control (IPC) and Local Air Pollution Control (LAPC) and others are preparing themselves well, although perhaps struggling with the remaining regulatory uncertainty. For others, regulation under PPC will be new and, to be perfectly honest, seems to many an unnecessary intrusion into their business – all pain and no gain. So can the experiences of other industry sectors entering PPC reveal what it will mean to the food and drink sector and are there any positive experiences to be gained?

In answering this, it is important to look at the evolving sustainable, legislative and fiscal context within which IPPC is set. The environmental sustainability agenda is currently running ahead of the legislative process and is being pulled by consumers and pushed by manufacturers, their suppliers, customers and employees. Value chains that link manufacturers to their raw material suppliers and to their customers are being increasingly bonded by strategic partnerships. Manufacturers, and indeed retail outlets, are seeking to oversee the whole of their value chain so as to protect their brand or reputation. Better communications and particularly the internet have created transparency throughout the value chain and in the marketplace, such that consumers are making informed choices about the value chains competing for their attention.

Environmental aspects

For many food and drink manufacturing businesses that fall under the new PPC regulations, preparing a permit application will be their first opportunity to consider the environmental aspects of their business. Although IPPC does not specifically promote sustainability per se, it is engaging many manufacturers who would have otherwise ignored this societal change or actively resisted it and is providing many food manufacturers with their first experiences of the sustainability agenda.

IPPC can afford several opportunities to the food manufacturer. Operation under a PPC permit implies a certain seriousness about operations and willingness to identify, deal with, monitor and report environmental impacts. It leads to transparency that can be shown to and appreciated by customers, consumers and stakeholders. Operation under a PPC permit has also been used as a market differentiator by demonstrating environmental credentials. Secondly, with the stakes of non-compliance so high, the preparation of a PPC application will require a level of introspection and senior management support that is unlikely to be motivated by any other than regulatory drivers. This has the effect of reducing environmental liabilities.

Manufacturers are increasingly in competition for good staff and individuals who are seeking to work with companies and in value chains that reflect their own personnel values. Key individuals informed about the environment are seeking to influence senior managers and Boards and are finding that IPPC is giving them the first opportunity to be heard. IPPC promotes the use of environmental management systems (EMS). Although this may be put in place, without third party accreditation, an EMS accredited to ISO 14001 or EMAS will satisfy most management requirements of IPPC and can be a very public statement to customers and consumers. It is interesting to consider whether environmental requirements may eventually achieve parity with health and safety requirements and an EMS may be required for manufacturing businesses of all sizes. Within some industries, supply chain pressures are increasing the need for EMS. Could this happen within the food and drink sector?

IPPC considers each installation as a ‘black box’ with not so much interest in the internal machinations of the factory but more on the inputs to that box and the outputs (or emissions) from it. Inputs certainly include raw materials but also energy, air and water. Outputs will include waste, emissions to air, energy (heat) loss. Brainstorming the inputs and outputs is often the first stage in preparing any application and often is usefully facilitated by an outsider to take a fresh look at something that appears so familiar. To those industrial sectors that have already commenced making a PPC application, this can be an edifying experience bringing various levels of management together to consider a common goal.

To many, their operations will not have been looked at in this way before and it can be a very stimulating exercise. IPPC will force fundamental questions to be asked about matters that would otherwise carry on regardless. Why do we still use that chemical? Why don’t we recover that material? How much waste do we send away for disposal? Can we recover that heat? Can we recover that waste material and turn it into a saleable product? Preparing a permit application will provide a window onto the outside manufacturing world through interactions with regulators, consultants and sector trade associations. Manufacturers will benchmark themselves against their competition with respect to techniques, processes and emissions.

Manufacturing waste

The requirements of the Landfill Directive are also being implemented through IPPC and are having a fundamental impact on the disposal of manufacturing waste. The continued operation of in-house landfills and particularly lagoons for permanent filling is becoming increasingly unattractive and many food manufacturers have declared their intention to close their landfills. This leaves manufacturers to send their waste for off-site disposal. However, the introduction of waste acceptance criteria, the expected dramatic fall in the number of hazardous waste sites on July 17, 2004, increased transport landfill, the expected hike in landfill tax and gate prices sharply focuses attention on waste issues. Consequently, all food manufacturers are re-examining their processes to increase recovery and reduce waste disposal. The innovative dewatering and recovery of soil from crops to generate a soil conditioner product can be hailed as a prime example.

IPPC requires site characterisation to identify existing pollution in or under the land. For many long existing industrial sites, the prospect of investigating the state of the underlying ground is hardly an attractive proposition and there are genuine fears about the implementation of the contaminated land regime. However, the drivers for doing this extend beyond IPPC into protection of the permit holder and into risk and liability management.

Manufacturing is changing. Maintaining brand or reputation is by far the most powerful influence on that change, more so than regulatory drivers or fiscal incentives. Regulation is providing prescriptive requirements to many manufacturing processes but it is admittedly in danger of stifling a lot of the technology and innovation that manufacturing needs. So some observers are anticipating a long term trend away from regulation to the use of fiscal incentives. However, within the sustainable agenda, the carrot and the stick will continue to play an increasingly
influential role over the next twenty years.

Most businesses (probably wrongly) consider that they do not have an impact on the environment. But sustainability is spreading throughout society and manufacturers are seeking to meet requirements of international and national legislation, set themselves and meet environmental targets, and then turn sustainable characteristics into competitive differentiators. Such introspection and probable realisation of environmental aspects can then realise real rewards in saving costs, process efficiencies, staff loyalty and perception of customers, consumers and stakeholders.

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