IPPC Applications

Regulations

On 1st August 2000 the Integrated Pollution Prevention and Control (IPPC) regime came into force under the Pollution Prevention and Control (England and Wales) Regulations 2000, SI 2000/1973 (as amended). Prior to the PPC Regulations many industrial sectors were regulated under Part I of the EPA 1990, which consisted of two systems: Integrated Pollution Control (IPC) and Local Air Pollution Control (LAPC).

Through the introduction of the PPC Regulations a coherent framework has been established to prevent and control pollution. This framework contains two parallel systems similar to the previous regimes of IPC and LAPC being ‘Part A’ and ‘Part B’, of which the main provisions apply equally to the ex-IPC processes and the other sectors new to integrated permitting. Therefore this regulatory system applies to industry sectors for energy, metals, minerals, chemicals, waste management and a group of other activities such as textile treatment, food production and intensive farming of pigs and poultry.

The Environmental Permitting (England and Wales) Regulations 2007 (SI 3538) pull together IPPC and waste operations under one permit.

What’s Involved?

In order to gain an Environmental Permit, Operators have to illustrate how they are applying the “Best Available Techniques” (BAT) and meeting other sector specific requirements, taking account of relevant local factors. A new installation cannot operate under the IPPC regime until a permit has been granted.

The Regulator has been very proactive in delivering direction and advice for the application process, but the sheer volume of information, and the difficulty in keeping up to date with the frequent amendments, can be bewildering, particularly for new entrants not previously regulated under IPC. The IPPC application process can be complex and time consuming. Worse still, it can stretch the resources of even the largest in-house departments, many of which are already struggling to meet day-to-day demands of the business. Therefore finding time is probably the single biggest issue facing those captured by the regulations.

Gap Analysis Studies

If the client is not fully conversant with IPPC, this initial stage should take the form of an interactive study, providing the client with a real understanding of the application process, the issues at stake and what is required of them.

The gap analysis is based on a review of the information that is currently available at the site, which will include management systems, standards and procedures relating to the design and operation of the facilities. This information is captured to form an assessment record, which will show just how and where the existing documentation fulfils the requirements of the regulations.

The assessment record is then processed to form a gap analysis report, which provides detailed information about any new work required. The report also includes an execution plan for the preparation of the application itself.

Preparing Applications

HFL Risk Services can provide different levels of support towards the preparation of an IPPC application. Service levels range from the acquisition of data to the successful presentation of the application to the Regulator.

We also support our clients, if necessary, in any presentations and discussions required by the Regulator in the lead up to and following the issue of the Permit.