Cost or benefit?

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IPPC Management in SMEs
Janet Murfin
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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

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PPC impact on SMEs
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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

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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

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Graph showing impact of annual PPC charges alone
on SME profits
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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

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Does PPC apply to your business?
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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
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How to tell if youre in PPC

• Dont assume youre 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)

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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)

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Changing your business
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What the EA cant tell you

• If you stop PPC operations before the application
  deadline, or change what you do so youre 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

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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

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Company A - alter operations

• Would have gone into PPC for manufacturing resin
• On costing, found that products couldnt 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

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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 havent heard of any SME who has
  closed because of PPC

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If PPC, are you low-impact?
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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)

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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.

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Getting help full PPC
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Grant funding

• You cant 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 whats in your area contact Business
  Link, Envirolink, BITC, your local environment
  forum

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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

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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

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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

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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

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Thank you very much

• Any questions?
• Presentation available at www.ttenvironmental.co.u
  k/hcf.html
• Contact tel [phone]
• Email janet_at_ttenvironmental.co.uk