Food and Drink BREF - Update

Further to our previous Food and Drink BREF Updates covering the key changes of, and the specific changes to, emissions to water in the updated BREF, we can now advise on the likely plan to be followed by UK Regulators for the necessary permit reviews.

The UK Food and Drink Manufacturing shadow Technical Working Group met at the end of September to discuss how they plan to undertake the permit reviews. While expected to be this month (October), there is still no confirmed date for the publication of the Best Available Technique Conclusions (BATc), timescales for the permit review are still to be finalised.

Summary of likely permit review process:

  • 4-year period from publication of BATc to ensure sites are compliant;
  • Each operator will be written to outlining how the permit review for their site will be undertaken;
  • Phased approach to issuing Information Notices, starting with higher priority sub-sectors;
  • Aiming to issue the first Information Notices 3 months after the publication of the BATc;
  • Operators will have a response deadline to the Information Notice, likely to be 6 months;
  • Higher priority = where BAT associated emission levels (BAT-AELs) will apply and/or there is a need for a derogation;
  • All sites operated by the same company will be reviewed concurrently;
  • Permit reviews will include Directly Associated Activities, i.e. Effluent Treatment Plants;
  • Permit reviews must include a review against associated legislation, e.g. Medium Combustion Plant Directive, Water Framework Directive etc; and
  • Permit review process is likely to have a 3-year timescale; therefore, all permits should be reviewed 1 year before the compliance deadline.

The Information Notices will request operators to provide evidence outlining how their plant(s) will comply with the BATc and associated legislation by the deadline. Demonstrating this will necessitate the provision of supporting information. Operators may also need to request derogations if they are unable to comply with the BATc. Responding to the notices can be resource intensive, particularly for multiple site operators.

SLR are ready to assist Operators in responding to the Information Notices by conducting, but not limited to, BATc gap analysis, responding to the Notices, assisting with derogations and permit variation applications.

You can download a PDF of this update here.

For more information please contact Paul Wright (Technical Director - Environment Management, Permitting & Compliance) at: pwright@slrconsulting.com or Greg Altria (Associate – Environment Management, Permitting & Compliance) at galtria@slrconsulting.com.