hcf, comah & ippc, grimsby, 5 th may 2005 ippc management in smes janet murfin

HCF, COMAH & IPPC, Grimsby, 5th May 2005

IPPC Management in SMEs

Janet Murfin


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


PPC impact on SMEs


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


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


Graph showing impact of annual PPC charges alone on SME profits

assuming 10% gross profits

010203040506070

0.5M 1 M 1.5M 2M

Turnover per annum

% o

f p

rofi

t ta

ken

by

IPP

C f

ees

7.5k EPOPRAfees

15k EPOPRAfees

22.5k EPOPRAfees

30k EPOPRAfees


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


Does PPC apply to your business?


Your operations and PPC:

Not under PPC

Definitely under PPC

Repacking

Warehousing, resale, distribution

Formulations

Chemical synthesis•Hazardous nature of substances used•Amounts of substances in use•Need for abatement

Including dilution with minor pH adjustments

Main criteria Other parametersinclude


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)


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)


Changing your business


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


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


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


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


If PPC, are you low-impact?


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)


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.


Getting help: full PPC


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


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


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


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


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


Thank you very much

• Any questions?

• Presentation available at www.ttenvironmental.co.uk/hcf.html

• Contact tel: 01274 870306

• Email: [email protected]

hcf, comah & ippc, grimsby, 5 th may 2005 ippc management in smes janet murfin

Documents

ppc slide

ppc impact

ppc operations

comah ippc

ppc dont

ppc company u

business slide

ppc repacking warehousing