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 k
Maintenance fees (three years) 12k
Surrender fees 12k
Consultancy fees (2 site reports) 16k
Total cost k
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 – 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
Grotech thought they were under PPC regulations, but couldn’t spare the time to wade through the guidance. I worked out they weren’t, as long as they didn’t allow pesticides handled on site into foul sewer (which they don’t). We had a meeting with EA, wrote a letter explaining our position which inspector replied to and Grotech are now clear what actions would take them into the regulations.

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?
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