Introduction

The 1996 Directive on Integrated Pollution Prevention and Control (IPCC) sets forth a European framework for multi-media (water, air, soil) pollution control within the Member States. This all-embracing policy offers the prospect of environmental improvements and helps curb the possibility of switching pollution from one medium such as air, to another such as water. Industrial installations which fall within the scope of the Directive must obtain a permit from the competent authority at national level. The integrated permit will set out the basic conditions under which the installation can operate, based on Best Available Techniques ("BATs").

The main focus of this Directive is on heavy processing industries. However, some food manufacturing operations are also covered according to certain daily production tonnage thresholds.

National governments should have translated the Directive into national law by 31 October 1999. However, many details which will determine how it works in practice still have to be resolved. The biggest on-going challenge for the European Commission and national authorities is to strike the right balance in drawing up the guidelines on Best Available Techniques for each industrial sector.

Europe's food and drink manufacturers fully endorse the principles underpinning the IPPC Directive. They support a strict control of pollutant discharges into the environment. However, emissions from the food and drink industry are relatively benign and local, mostly readily biodegradable organic matter which easily break down in the natural environment. The industry is voluntarily and in response to previous EU directives, taking steps to continuously minimise the impact of emissions into the environment. With regard to IPPC, the CIAA is co-operating with the Commission in drawing up a reference list of the best available pollution control techniques in the sector so that adequate guidelines for inspections will exist.

Ensuring a flexible approach from BATs

The CIAA believes that there should be flexibility in pollution control techniques applied to take into account the wide range of activities used within the food and drink industry. These activities range from the basic washing of fruit and vegetables to the processing of ready-to- eat meals, and often the same plant can be used to carry out a number of different activities. The Directive itself clearly states that authorities should avoid specifying one single technique or technology and should take into account the characteristics of individual installations.
Proper consideration must also be given to the geographical location and local environmental conditions of industrial plants. Clearly, the conditions in Finland might call for different water treatment techniques from those in Spain. The problem of noise and odours from a plant in a built-up area demands a different approach from one that would be located in the countryside.

An environmental and economically efficient approach

Adequate guarantees should be given that reliance on Best Available Techniques does not result in industry providing a blank cheque for the investment of any equipment. To ensure the competitiveness of the food and drink industry, BATs should be carefully costed with the environmental benefits weighed against the economic cost.

Reasonable inspections

The onus for regular monitoring of emissions is placed by the Directive on the plant operator with national inspectors given wide powers to carry out spot checks or take samples. Here, the CIAA calls for monitory demands on industry to be kept simple with the existing environmental management and quality measures where possible. The frequency of checks should be based on the potential environmental impact of the plant.