Environmental management came of age in the 1990s with a significant number of legal regimes which have imposed control on air emissions, waste management, water and land resources. The coming decade will see the further development of existing regimes together with the implementation of new areas of control.
The Environmental Protection Act 1990 (EPA) has probably had the single greatest impact upon the timber and furniture sectors as it imposes controls on air emissions, waste and nuisance. Part I makes it an offence to operate prescribed processes without an authorisation and relevant processes include:
l Manufacture of timber and wood based products: processing more than 1,000m3 timber or purely sawing more than 10,000m3.
l Wood combustion in boilers rated from 0.4-3.0MW net rated thermal input.
l Wood coating using more than 5 tonnes of organic solvent per year.
Sites operating above these thresholds should have authorisations for each process. These will be issued by local authorities (England and Wales) or the Scottish Environmental Protection Agency. Each authorisation will contain conditions derived from the relevant process guidance note and sites are required to upgrade their processes accordingly.
All of the notes are under review and the greatest changes in early drafts are contained in the wood combustion note PG1/12(95). A key concern with this note has always been the carbon monoxide emission limit. The limit was 100mg/m3 in the 1991 version of the note and was then revised upwards to 400mg/m3 before regulators were advised to agree CO limits on a site specific basis because of the high costs of upgrading.
The current draft of the note seeks to lower the emission limit for “existing” processes to just 150mg/m3. A recent position paper by British Furniture Manufacturers considered CO monitoring results from 30 existing plants which suggested that 87% would be unable to meet such a limit.
There are an estimated 250 “existing” plants, around 217 of which would need to be replaced in the event of a limit of 150 mg/m3. Authorised plants average around 2MW in size, with a replacement cost of around £400,000 – a total of £87m for all 217.
This is money which struggling manufacturers can ill afford. The suggestion that this expenditure should be incurred is made more frustrating by the fact that there is little, if any, scientific basis for CO levels of 150mg/m3. Such limits are typically convenient round numbers plucked out of the air on the basis of what can probably be achieved. The figures are given credibility once they are committed to paper and they are used as a baseline by subsequent reviews.
The lack of scientific basis is reinforced by the fact that the Department for Environment, Food and Rural Affairs (DEFRA) has not produced any figures for the reduction in wood combustion emissions which it expects to achieve through more stringent CO2 emission limits. It has also failed to produce figures for the expected costs which would be incurred.
The lack of joined up thinking by such policy makers is further highlighted by DEFRA’s position on continuous monitoring equipment. Initial drafts of the guidance note expected operators of non-compliant plant without such equipment to install it at a cost of £20,000-30,000. This was despite the fact that, by definition, the plant was known to be non-compliant and would have to be taken out of service in two years!
Another area which continues to change is that of the packaging regulations – the Producer Responsibility Obligations (Packaging Waste) Regulations 1997. Prosecutions continue to mount for non-compliance. An Ipswich timber importer was fined £4,000 with £764 costs for failing to register or provide evidence of compliance. A high profile kitchen furniture manufacturer was fined £16,000 for similar reasons, while a car component business was fined £96,000 for 24 packaging offences dating back to 1998. This fine significantly outweighed the £6,262 that the company had saved through non-registration.
The initial aim of the packaging regulations was to ensure the recovery of 50% of packaging waste each year by 2001, a target which the UK missed by 2%. Europe is now consulting on targets of 65% recycling and 80% recovery by 2006. Consequently, obligated business could be looking at a 90% recovery rate (currently 59%) to secure adequate packaging waste.
The problem with such a high recovery rate is that there are ‘diseconomies’ of scale associated with trying to wring the last pieces of packaging out of the UK waste management system. In 1999, the recovery rate was just 43% so the bulk of obligations could be met by collections from major packaging users such as supermarkets. As this recovery rate increases, packaging waste must be sourced from mushrooming numbers of ever smaller organisations. Finally, packaging from domestic sources must be segregated and recovered. Consequently, the price of a general packaging recovery note (PRN) has risen from £10-15 per tonne in 1999 to around £25. A cost of £50 plus could be expected by 2006 due to the anticipated rise in UK targets.
Companies should also be aware of the spread of producer responsibility to other areas. The ‘success’ of the packaging regime has led to similar regimes for other waste streams such as end-of-life vehicles, tyres, batteries and waste electrical equipment. All regimes are based on the principle of making the manufacturer who designed the product responsible for end-of-life recovery and securing eventual take-back and dismantling. Arguments continue over how the costs of take-back should be met, but they will eventually find their way to the consumer.
Such producer responsibility regimes are expected to spread and will undoubtedly raise difficult questions for timber and furniture companies. For example, how do you secure the take-back of end-of-life decking, fencing, telegraph poles, mattresses and kitchens – and once you have them back, how can you recycle them?
There is also talk of a more generic regime to cover all producers. For example, there is an EC Green Paper on Integrated Product Policy which seeks to encourage eco-design and to stimulate demand for more sustainable products. Elements of the policy may include: product taxes which reflect environmental burden; end-of-life recovery requirements; labelling and standards regarding environmental performance; and public body procurement policy to bring pressure on manufacturers.
Interestingly, there is an element of conflict between the packaging and wood combustion regimes. If the 217 wood combustion plants are forced to close, up to 500,000 tonnes of woodwaste per year may become available. However, this waste is less attractive to reprocessors than packaging waste. For each tonne of the latter which is recycled, a PRN worth £25 can be issued whereas no such premium exists for production waste even though it may be identical in nature. Furthermore, where recycling plants are close to capacity, packaging waste may actively displace production residues.
Therefore, the imposition of tighter emission limits on wood combustion plant is likely to lead to a significant rise in material being sent to landfill with its associated environmental impact and vehicle emissions. Space heating previously generated from carbon neutral timber waste will be provided by fossil fuels, contributing an extra 63,000 tonnes per year of CO2, according to the BFM study.
