Principle

In the Introduction, the intention was made clear to limit this Guide to matters having a direct bearing on the scientific, technological and organisational aspects affecting the quality, legality and safety of products. For this reason, detailed consideration has not been given to the impact of the factory and its operations on the external environment. It is, however, acknowledged here that the management of any food manufacturing operation has general responsibility and, in most countries, legal obligations (with which it must be familiar) for these aspects.

General

41.1 The premises, equipment, personnel, manufacturing operations, intake of materials, despatch of products and treatment/disposal of unwanted by‐products (waste materials, by‐products unsuitable for human consumption, effluent, emissions of smoke, gases, fumes, dust, noise, light and odours that are offensive or that may cause taint elsewhere) must be controlled and comply with:

1. all the appropriate environmental legislation in the country concerned;
2. any specific legislation in the country in which manufacture takes place relating to the treatment and handling of specific by‐products; and
3. the environmental legislation in the country in which manufacture takes place as well as any additional requirements of the local authority, and should have full regard to the responsibility of industry to take whatever steps are necessary to minimise, and preferably eliminate, any adverse environmental impact of its operations.

41.2 Environmental management is just one element of a business sustainability plan for a manufacturing business. The so‐called ‘triple bottom line’ of a food business includes social (people), environmental (planet) and economic (profit) dimensions. This is discussed more fully in Chapter 40.

41.3 When building food manufacturing premises, consideration should be given to the local environment and the actions that may need to be taken to protect the environment. This is usually addressed by undertaking an environmental risk assessment that once developed and implemented must be routinely reviewed and updated as activities and practices on the site change. The factors to be considered include, but are not limited to:

1. local activities that could impact on food production;
2. chemical storage on‐site and chemical mixing areas;
3. fuel and oil storage on‐site;
4. potential for existing ground contamination or pollution from spillages;
5. design of drainage systems, including storm water and designated waste drains;
6. sources of and conservation of water and energy;
7. waste‐water treatment and the need for effluent treatment;
8. storage areas for packaging awaiting recycling that minimise harbourage for pests; and
9. storage of other wastes awaiting collection, for example in a poultry meat factory the storage of blood, sludge or feathers.

41.4 Formal policies and protocols such as environmental policies, waste management and waste minimisation protocols (including recycling policies; see Chapter 30), and dust, odour and noise management plans need to be developed, implemented and periodically reviewed to ensure that they are still valid, are being complied with and are effective. Resource management procedures should also be developed to effectively manage resources utilised within the manufacturing unit, for example water, energy and materials.

41.5 Manufacturing organisations may seek third‐party certification of their environmental management systems for compliance with standards such as EN ISO 14001:2015.

Environmental Permitting

41.6 Integrated pollution prevention and control (IPPC) was operated under the Pollution Prevention and Control (England and Wales) Regulations 2000, and similar regulations for Scotland and Northern Ireland were made under the Pollution Prevention and Control Act 1999, which implements the European Community (EC) Directive 96/61/EC on IPPC. The IPPC Directive was codified (Directive 2008/1/EC). The IPPC Directive (96/61/EC) was implemented in England and Wales through the Pollution Prevention and Control (England and Wales) Regulations 2000, which have been replaced by the Environmental Permitting Regulations 2007. Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control) superseded previous regulations.¹

The scope of the legislation includes all ‘installations’ treating and processing materials intended for the production of food from:

• operating slaughterhouses with a carcass production capacity greater than 50 tonnes per day;
• animal raw materials (other than exclusively milk) at a plant with a finished product production capacity greater than 75 tonnes per day;
• vegetable raw materials at a plant with a finished product production capacity greater than 300 tonnes per day or 600 tonnes per day where the installation operates for a period of no more than 90 consecutive days in any year;
• animal and vegetable raw materials, in both combined and separate products, with a finished product production capacity in tonnes per day greater than 75 tonnes if A is equal to 10 or more or [300 – (22.5 × A)] in any other case, where A is the portion of animal material (percentage of weight) of the finished product production capacity.

Packaging should not be included in any calculations of the final weight of the product.

Activities in this sector include production and preserving of meat, fish and potatoes, manufacture of fruit and vegetable juice, fruit and vegetable processing, milk processing, cereal processing and production or processing of animal feed, pet food, bread, cakes and biscuits, sugar, chocolate and confectionery, pasta products, tea and coffee, and beverages and brewing.

This legislation requires manufacturing sites to identify their impact on air, soil and water using an integrated approach in order to develop environmental management systems to minimise the impact of the site. This could include the development of documented management systems to meet the needs of EN ISO 14001:2015. Consideration should also be given to the potential for activities and practices undertaken at the manufacturing site impacting on local environments and neighbours, especially those sites that are environmentally sensitive.