IPPC Management in SMEs

1. IPPC Management in SMEs Janet Murfin

2. Contents • Impact of PPC regulations on SMEs • Does PPC apply to your business? • Changing your business • If PPC, are you low-impact? • Getting help for full PPC

3. PPC impact on SMEs

4. PPC is expensive and time-consuming • Agency application fees are tip of the iceberg • Typical chemical industry application = 1 person 1 year to produce • Specialist help with site report, emissions modelling etc • Annual EP-OPRA charges • Surrender charges

5. PPC hits smaller companies harder • Charges are higher proportion of profits • Less/ no spare manpower for application • Less in-house technical knowledge (eg no environmental manager) • May affect profitability • May put businesses off growing into areas of work covered by PPC regulations

6. Graph showing impact of annual PPC charges alone on SME profits

7. Company DM: PPC lifetime costs EA fees per year currently £4 k Lifetime costs: • Application fees 8k • Maintenance fees (three years) 12k • Surrender fees 12k • Consultancy fees (2 site reports) 16k • Total cost 48k True cost per year£16k

8. Does PPC apply to your business?

9. Your operations and PPC: Definitely under PPC Main criteria Other parameters include Chemical synthesis • Hazardous nature of substances used • Amounts of substances in use • Need for abatement Formulations Including dilution with minor pH adjustments Repacking Warehousing, resale, distribution Not under PPC

10. How to tell if you’re in PPC • Don’t assume you’re under PPC – it pays to read the small print • Example – Company G • Key documents are PPC Regulations, and RGS 4, Interpretation of Regulations, Chapters 4 (Chemicals) and 5 (Waste)

11. Every chemical SME should know • Where they stand under PPC, whether in the regulations or out of them • If under PPC, exactly what circumstances are responsible - if outside, what changes would bring them into PPC • Example – Company S - would be in PPC if had ETP (waste treatment)

12. Changing your business

13. What the EA can’t tell you • If you stop PPC operations before the application deadline, or change what you do so you’re not under PPC, you can avoid coming under the regulations • Altering operations is a business decision for owners/ senior managers • Have to think about effects of going into/ staying out of PPC on long-term business viability

14. Company U – using toll manufacturers • Diluting HCl was in PPC because of potential releases to air • Company U were only in PPC because of this, so asked a competitor to do the work • The regulations have been amended, dilution of HCl now not under PPC • Company U can still carry on, but only because of regulatory change

15. Company A - alter operations • Would have gone into PPC for manufacturing resin • On costing, found that products couldn’t support PPC charges • Stopped those products immediately, now getting them toll manufactured • Rest of non-PPC products are profitable, the business is in good shape

16. The least preferable option: closure • Larger businesses/ low profitability are being closed prior to entering PPC: • Hodgsons, Beverley • Rhodia, Staveley (sold, then being closed) • Coalite Chemicals (PPC seems to have been the last straw) • However, I haven’t heard of any SME who has closed because of PPC

17. If PPC, are you low-impact?

18. Reduced costs for SMEs: “low impact installation” • Must meet certain criteria on emissions and production volume • Standard charges: application – £2,599 maintenance – £403, surrender £319 • Application cheaper – only need to demonstrate how you meet the low-impact criteria (but you do need H7 site report, adds to application cost)

19. Examples of low-impact installations • Company H – esterification in a 20 litre glass vessel, over 100kgs / year so in PPC as low-impact • Company V – 400 - 1000 litre vessels, low environmental impact (low/no air emissions, no abatement on vessels, little wash water). Products with reactions are in PPC.

20. Getting help: full PPC

21. Grant funding • You can’t get grant funding if you are using it to comply with regulations • But you CAN get money for environmental improvements which may help you comply with PPC (eg implement ISO 14001) • Find out what’s in your area: contact Business Link, Envirolink, BITC, your local environment forum

22. Use consultants sensibly • You can use a consultant to project manage the application, or act as a sounding board, or help with a bit of the project. • Consultants can help you liaise with the EA, and stick up for you in meetings • it may be cost-effective to ask them for help early on, they should know the regulations

23. Help from the EA • CD contains all the information you should need for your application • Information also available on EA website • 15 hours discussions with your Inspector free as part of your application • Your relationship with Inspector is vital • The EA want to help, so each application goes through as smoothly as possible

24. There are benefits from PPC permit • Immediate benefits to the business (although these must be set against PPC costs) • Make changes which improve efficiency, reduce costs; ongoing improvements • Marketplace changes • If fewer businesses in your sector, extra work available, reduced competition within UK • Closures can release skilled workforce to you

25. Summary • SMEs are hit harder than large companies by PPC application costs and time • They should consider the business case for PPC • whether to alter operations (reduce impact) • will there be new business opportunities which a PPC permit will open up • Other companies are going through similar decisions

26. Thank you very much • Any questions? • Presentation available at www.ttenvironmental.co.uk/hcf.html • Contact tel: 01274 870306 • Email: janet@ttenvironmental.co.uk