Improving IPPC performance could save time and money, as Rhian Price reports.

The poultry sector has got a great track record when it comes to meeting the requirements of pollution control regulations.

Speaking at a recent IPPC (Integrated Pollution Prevention and Control) event, Diane Mitchell, chief environment adviser for the NFU, said that in 2011, over 97% of the 923 poultry producers under IPPC were in the top two compliance bands.

But breaches are still being made and, with 2.4% of poultry producers falling into bands C, D and E, producers shouldn’t underestimate the importance of what may seem like minor requirements, warned Alison Holdsworth, technical adviser for the Environment Agency (EA).

Best practice

Among the top reasons for non-conformance last year were producers not providing staff with appropriate training, failing to display a copy of the permit and failing to display an identification notice at the entrance of the property.

The most common breach, however, was producers failing to identify and list point sources in the site plan.

This involves producers listing the emission points on their houses, such as side or roof ventilation where gasses can seep out.

“If you install side vents on a house next door to a habitat such as bog or ancient woodland, which is sensitive to outlets of ammonia, it’s the worst possible place to have them. So it could be better, for example, to have them on the roof,” Mrs Holdsworth advised.

Planning and preparation was key to achieving a successful audit process.

“Sometimes people don’t plan before hand. It’s all about planning ahead and if you are going to put something new in, ask the EA first and we can advise the best place to put it.”

During the event, which was organised by Datapoul training services and held at a broiler unit in Somerset, environment officers gave producers practical advice on the audit process.

Mrs Holdsworth said site security should be a high priority and things like failing to display signs to warn people about unauthorised entry could amount to breaches.

Ensuring producers complete a noise and odour management plan if neighbours are located within 400m of the premises is equally important, she added.

Other advice included ensuring a copy of the permit was available on the site, as well as a site plan.

Emissions accounted for a large proportion of the assessment visit and producers were told they should ensure dirty drains and clean drains were colour-coded.

“Producers should mark their dirty drains red and colour code their clean drains blue.

“Under no circumstances should clean drains become contaminated with slurry,” Mrs Holdsworth dvised.

She said producers could prevent contamination occurring by cleaning up spillages swiftly and keeping yards clean.

Dust from side extraction fans was also highlighted and producers were told dust should be removed regularly to prevent contamination of surface water.

Producers were reminded by EA officials that they should be able to provide information which shows that levels of phosphorus and nitrogen are decreasing over the lifecycle of the bird. This could be assessed by looking at the feed mill dockets detailing the bird’s rations.

“The problem comes when the feed mills don’t update their sheets, so it’s best to check with the feed mill,” Mrs Holdsworth advised.

Rewarding good performance

Mrs Holdsworth admitted that the EA had been on as much as a learning curve as producers when IPPC regulations were first brought in, but she said she was hopeful improvements could be made to simplify the process.

“We are all learning and as time goes on we will try to streamline things a bit better,” she said.

But good performance wouldn’t go unnoticed and she said both time and money could be saved if requirements were met by producers.

“It is good to keep breaches down, because if they aren’t your year’s subsistence fee will go up,” she explained.

Producers were told if they incurred over 10 CCS points (Compliance Classification Scheme) when it came to breaching the permit conditions, they would receive a 10% charge on top of their basic subsistence charge of £2,420, while those who had the highest number of penalties (over 150) would receive an additional 200% charge on top of basic subsistence.

However, producers who received less than 10 CCS points, (those in band A and B), would be rewarded for good performance through the Pig and Poultry assurance scheme and would face lower annual charges, worth £880, and fewer EA inspections.

“If you are a good performer you don’t have as many non-compliance breaches, so if you have less than 10 CCS points you are invited to become a member of the assessment scheme module,” the NFU’s Dr Mitchell explained.

Instead, annual checks are conducted by a certification body through a bolt-on assurance scheme, although the EA still has ultimate control when it comes to assessing if a producer has breached the regulations.

One way of ensuring best practice is by using BAT (Best Available Techniques), Dr Mitchell explained.

“BAT can encompass technologies, practices and techniques. There are a few tests to decide on whether something is BAT – including whether it is widely available, widely practiced and affordable. For example, BAT could include bunding your oil tank to stop leaks, undertaking a water audit or using certain housing designs,” she added.

Hatcheries

Mrs Holdsworth warned producers about the risks of taking extra birds which could see them exceed their threshold.

“It is not common practice, but some producers were being forced to take extra birds, so we sent a letter to all hatcheries alerting them to the fact and now hatcheries must ask how many birds you have on your farm.”

Some producers voiced concerns over still being forced to take extra birds, but Mrs Holdsworth said it was their responsibility to say no.

“Producers shouldn’t be taking them. It is their business, it’s their choice,” she added.


Your questions answered

• Do I need an IPPC permit?

If you stock above the EPR (Environmental Permitting Regulations) threshold of 40,000 birds, then yes, you will need one. You will also need a permit if the farm is changing ownership or if you wish to expand your operation.

• Who conducts the compliance assessment visit?

The first two audit assessments will be completed by the Environment Agency. But providing you have a low number of breaches and you are put into categories A or B you can have your annual assessment completed by a certification body, (although this may be subject to certain conditions). However you will still be subject to an assessment by EA auditors every three years.

• What is the purpose of IPPC?

IPPC ensures producers are using the best technology to eliminate pollution and lower ammonia emissions.

• What happens if I have multiple sites?

Often they are grouped into one, which is good because it means you will only get charged one subsistence fee.

• Will I need an annual review?

Assessments are conducted every year by either the EA or a certification body assessor, depending on which band you are in. The EA has to conduct an assessment every three years even if you are being inspected annually by a certification body assessor. Additionally every four years producers are expected to review their usage of energy, water and raw materials and the management of their waste. It is designed to encourage producers to lower their emissions and help them to save money.

• How much will it cost?

Band  Breaches (CCS points)   Subsistence charge
 A  0  Basic charge of £2,420
 B  0.1-10  Basic charge of £2,420
 C  10.1-30  Basic charge + 10%
 D  30.1-60  Basic charge + 25%
 E  60.1-149  Basic charge + 50%
 F  150+  Basic charge + 200%

• What happens if I don’t have a permit?

You could be taken to court by the EA and prosecuted.

• Who do I need to contact for an application form?

Download a PDF from the Environment Agency or contact your local EA office for more advive


Top tips for IPPC compliance

• Print out an IPPC audit form online and fill it in yourself prior to your compliance assessment visit, then you can improve on any weak areas

• The EA has examples of model permits on their website to help

• It also has a step-by-step guide for each section

• Certification body auditors are not allowed to give you advice, but your local environment officer can provide you with guidance. Find your nearest office

• If you want to make changes to your farm, contact your environment officer for a pre-application discussion. You’re entitled to 15 hours of free advice.