What plant managers need to know

Changes to laws governing waste, energy consumption and emissions are forcing plants to alter their methods of operation. Big food manufacturers may be tuned in to the changes, but what of smaller enterprises at the margin? According to Martin Brocklehurst, head of waste management at the UK's Environment Agency, clarity on these important pieces of legislation is vital.

"The food industry in the UK has traditionally only been covered by water emissions regulations, packaging requirements and Duty of Care waste management regulations,"​ he told FoodProductionDaily.com. "But this is all changing with the passage of EU-level Pollution Prevention control (PPC) legislation."​

PPC regulations apply to manufacturing enterprises that operate above set thresholds. These differ for each sector of the food industry. If you are a plant manager, says Brocklehurst, the first thing you need to know about PPC is whether your enterprise is caught by the thresholds.

"Thresholds are low, and differ from industry to industry. For animal processing for example, the regulations cover enterprises that are capable of producing above 75 tons a day of finished product. For vegetable-based products, the regulations cover operations that produce over 300 tons of finished product."​

Things get a bit more complicated when you consider enterprises that manufacture a mix of products. "What about a plant that produces pea and ham soup, for example?"​ asks Brocklehurst. "We've had unbelievably long debates about this sort of thing. However we managed to reach a manageable proposition - if your processing involves more than 10 per cent animal products, and you are above the threshold for that licensing group, then you are an animal manufacturer."​

As soon as you find that your operation is above the threshold level and that you are therefore covered by the legislation, you are obliged to get a licence to operate. The next thing a plant manager needs to do, says Brocklehurst, is be aware of the timetables. As with the thresholds, these differ depending on the type of industry. If you operate beyond the deadlines without a licence, you will be operating illegally.

Another important area to consider is changes in waste management. According to the Environment Agency, the UK's food and drink sector produces between seven and eight million tonnes of waste per year, second only to the construction industry and consumes approximately 900 megalitres of water each day, enough to supply almost three-quarters of all customers' needs in London daily. Processors must now abide by amended laws that will see less scope for waste in the industry.

"New animal by-products regulations prohibit the disposal of animal waste to landfill. In the past you could do this, but you can't now. So manufacturers need to know how to treat animal by-products before they are disposed of, things like that."​

To complicate this issue further, landfill operations in UK are currently going through something of a revolution. There is a drive to take organic waste out of landfill, largely because 25 per cent of methane emissions - a major factor in global warming - come from landfill.

This change in waste management is having a knock-on effect on the food production industry. Although commercial landfills are not covered, there are now targets in municipal landfills to reduce organic matter. This means there is less space for waste coming from food processing operations.

This is also affecting the packaging industry. There is a growing move away from the use of plastic and towards starch and other biodegradable materials. But with organic matter being taken out of landfill in the UK, both the food processing and packaging industries need to think carefully about waste management. As Brocklehurst suggests, these issues need to be linked up.

"The final issue in this field that requires understanding is the new Duty of Care regulation. If your waste leaves your site and is illegally disposed of, you need to show that all precautions were taken. If you are not able to do this, then you will be taken to court."​

There is no doubt that PPC represents a significant tightening of environmental regulations. Issued at EU level, it covers every processing aspect of a factory. It means therefore that plant managers must understand every aspect of their operation and take a balanced approach.

"This is no bad thing,"​ said Brocklehurst. " It will drive resource efficiency. The dairy industry for example uses lots of water, and an old plant will use vastly more water than a new plant. New technology means that savings can be made."​

The Environment Agency is working with food manufacturers across the UK to clarify the legal situation of plants operating in the food and drink industry. Brocklehurst says that the aim of the agency is to provide pragmatic guidance where the laws are not clear.

To aid the agency in achieving this, NetRegs​, an information website, has been set up to provide essential reading for all SMEs involved in the processing and preserving of all types of food and drink, from the receipt of raw materials to storage of the final product. The site covers everything from the production, processing and preserving of meat and poultry and the manufacture of dairy products and beverages to fish and shellfish processing and the manufacture of prepared animal feeds.

As well as mandatory requirements, the site offers good practice advice and includes links to other sources of information.

"NetRegs provides clear advice,"​ said Brocklehurst. "It is a huge step forward. It gives plant managers an overarching view of the legislation and gets into specifics.​

There has already been a lot of dialogue, to help food processors understand the legislation and for us to understand their problems. We have worked these discussions through into a consistent approach, so that when the regulations are applied, they are applied in a consistent way."​