Whilst UK legislation that affects water and wastewater treatment operations doesn’t change that often, more significant updates can require investment and long-term planning. These changes normally come with a reasonable amount of forewarning, for example, the introduction of BREF (Best available techniques REFerence) which sets new standards for different industries to comply with as part of the Industrial Emissions Directive (IED).
Changes to discharge consents and restrictions may occur on a local basis to address local issues and challenges. It is important to stay up to date and have processes in place to react to such changes to remain compliant. In this article, we highlight how we can help your business with compliance, and give a brief summary of what the BREFs are and how they impact the Food and Beverage, Dairy, Chemical and Pharmaceutical industries.
With extensive expertise gained over more than three decades running water treatment sites and Anaerobic Digestion plants across a wide range of sectors, we can provide advice, guidance and support on complying with regulations now, and in the future, such as:
Through our Operations and Maintenance service, we can provide compliance assurance, with the added benefit of improving efficiency, increasing asset lifespan and reducing operating costs at your treatment plant.
The IED aims to lower emissions from industrial production through an integrated approach. The legislation is written on the assumption that installations using Best Available Techniques (BAT) processes will be able to meet Associated Emission Levels (BATAELs). The plan allows for flexibility, as exemptions can be granted under certain circumstances.
The Directive sets out environmental responsibilities and updated emissions targets that producers must comply with. The IED was enacted into UK law prior to Brexit, so these updates still apply and the UK government has plans to roll out new BAT regulations.
The BREFs (Best available techniques REFerence) are a series of documents to regulate industrial processes under the IED. These documents outline acceptable working practices for different types of manufacturers and producers while regulating industrial processes and specifying emissions limits for discharges to the environment. BREFs are finalised for some industrial processes and are in progress for others, you can view the status, and copies, of these documents on the European Commission website (in the future, you will be able to view UK versions on the gov.uk website).
The regulatory updates may require you to adopt new processes or invest in new technologies to ensure your production activities are compliant. You can also expect regulators to be more interested in your manufacturing processes rather than just your output.
Chlor-alkali and large-volume organic chemical installations should already be compliant with BREF limits. Sectors such as oil refining, the petrochemical industry, manufacturing of non-ferrous materials, paper, plastic and more have their own BREF documents and should already be making plans for compliance.
Pharmaceutical, fine chemical manufacturing, and any other chemical process not already covered by other BREFs will be impacted by the introduction of the Common Waste Gas (WGC), expected in early 2024, which covers various industries that generate waste gases, but also acts as a trigger for the CWW BREF. Read more in our guide to BAT for the Chemical and Pharmaceutical sectors*, or contact us for advice on how we can help you prepare for compliance.
The BREF for the Food, Drink and Milk Industries covers the following sectors in the Food and Beverage industry. These were published in 2019, so all installations in the sector should already be compliant:
The BREF applies to large beverage manufacturers who produce more than one million hectolitres per year. However, medium-sized producers could realise significant cost-saving benefits by adopting the BREF benchmarks. Our expert team can advise where performance can be improved and cost savings can be made by adopting the Best Available Techniques (BAT) and technology. Read more in our BAT guide for the brewing and drinks sector*.
The BREF document affects food producers in different ways and the guidelines are dependent on the meat content of your products. In general terms, those who produce foodstuffs with animal-sourced ingredients have lower emissions thresholds than non-meat food producers. We summarised the key points in our BAT guide for the food and dairy sector*.
In short, we can determine whether or not your current processes will be compliant.
For any non-compliant processes, we can demonstrate how to bring them into compliance in the most cost-effective way.
We also go beyond compliance and can address how to fulfil your regulatory obligations while trimming your bottom line and operational costs.
Finally, we can liaise with regulators and help you take steps to apply for a new permit or variation of your existing permit conditions.
* Please note that these guides were written in 2019.