Environmental Compliance in
Ireland’s Food and Drinks Industry
Environmental Compliance in Ireland’s Food and Drinks Industry ________________________________________________________________ Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ ENVIRONMENTAL COMPLIANCE IN IRELAND’S FOOD AND DRINKS INDUSTRY Robert Geraghty, Mary Doolan, Tadhg Egan & Peter Prior
For correspondence contact Dr. Robert Geraghty, Senior Analyst, Environment & Green Technologies Department, Enterprise Ireland, Eastpoint Business Park, Dublin 3 Tel: 01 727 2618 email: Robert.geraghty@enterprise‐ireland.com 2
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ 3
Environmental Compliance in Ireland’s Food and Drinks Industry ________________________________________________________________ Executive Summary With an annual turnover of €20 billion and exports worth €7.88 billion in 2010, the food and drinks sector is by far Ireland's most important indigenous industry. Driven by demand from new growth markets such as China and India, food exports are predicted to undergo significant growth in the coming years. Many of Ireland’s key food companies are poised to expand and to take advantage of these opportunities. Because of its overwhelming reliance on exports, often to well‐known international food, retail or fast‐food brands, the sector is committed to building on its green credentials by extending its market reach in the most sustainable way possible with minimal environmental impact. As part of its overall sustainability and pollution prevention policy, Enterprise Ireland regularly conducts environmental assessments of its client companies to ensure that they comply with regulation and good environmental practice. Assessments are conducted on‐site and focus on six main areas of compliance – i.e. wastewater management; atmospheric emissions; waste management; bulk storage; noise; and the general condition of the working environment. For the purposes of this study, the findings of the 471 assessments of 192 food and drinks companies conducted between 1995 and 2011 were reviewed and collated. These 192 companies represent Ireland’s six main food & drinks sub‐sectors as follows:‐ dairy products & ingredients; drinks & beverages; non‐dairy food ingredients; prepared consumer foods; primary meats; and seafood. This report, in conjunction with other studies which have explored resource efficiency in Ireland’s dairy foods and primary meat processing sectors, sets out to measure the environmental performance of Ireland’s food and drinks industry and to compare Ireland’s performance with international benchmarks. The study found that Ireland’s food and drinks industry, due to tightening regulation and customer expectations of continuous improvements, have continued to invest heavily in systems to minimise their environmental footprint. Of the 170 assessments that were conducted since 2008, most companies (>97%) were found to fully comply with regulation/best Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ practice guidelines relating to waste management, atmospheric emissions, noise and the general condition of the site. Of the six criteria which form the basis of the assessments, the only areas where significant levels of non‐compliance remain during the period 2008–2011 were wastewater management and bulk storage of materials. In 170 assessments conducted between January 2008 and May 2011, 18% of the companies assessed were found not to comply with the provision to bund all bulk storage vessels, and 37% were found not to comply with regulation concerning the management of wastewaters (i.e. not having an effluent discharge licence, not adequately monitoring discharges OR exceeding emission limit values). The study found that dairy and meat processing sub‐sectors, primarily large, IPPC‐licensed, export‐driven companies, underwent the most dramatic changes between 1995 and 2011. These sub‐sectors, which exhibited the highest levels of non‐compliance during the period 1995–1998, achieved the lowest levels of non‐compliance during the period 2008‐2011. By comparison, the SME‐dominated sub‐sectors, although starting from a higher level of overall environmental compliance in 1995‐1998, experienced only modest improvements over the course of the study. A possible reason for the observed differences is the emergence of large numbers of small, highly innovative food companies which results in more SMEs being assessed for the first time in any one period, relative to the more stable large companies many of which have been assessed 4 – 5 times over the course of the study and which, therefore, demonstrate steady improvements over time on the same site. 5
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Introduction The food and drinks sector is Ireland's most important indigenous industry with an annual turnover of more than €20 billion. It boasts the highest Gross Value Added (GVA) per employee in the EU and one of the highest turnovers per capita (16% of total industrial sector output)(1). The sector directly employs almost 50,000 with a further 60,000 employed indirectly and consumes 90% of the output of Ireland's 120,000 farmers. Irish food and drinks exports, which were valued at €7.88 billion in 2010(3), account for ~10% of Ireland’s total exports and two thirds of indigenous exports(2). Between January and May 2011, the value of Irish food exports increased by 13%(4). Although Ireland exports to 140 countries worldwide, the UK remains the most important destination for food and drink exports followed by Continental Europe. Two sub‐sectors, dairy processing and primary meat processing, accounted for 57% of Ireland’s total food and drinks exports in 2010 (see Table 1). Value of Exports in 2010 (€ million) Percentage of Exports in 2010 (%) Dairy Products and Dairy Ingredients 2,290 29 Primary Meats (beef, pork, lamb, poultry) 2,200 28 Prepared Consumer Foods 1,400 18 Beverages 1,190 15 Seafood 379 5 Live Animals 245 3 Edible Horticulture 200 3 Food Sub‐sector Table 1 Exports from Ireland’s main food & drinks sub‐sectors (Source: Bord Bia) Food and drink exports are predicted to undergo significant growth in the next decade. Ireland currently produces enough food to feed 36 million people. By 2020, Ireland wants to be in a position to provide enough food to feed 50 million(4). Much of this growth will stem from increased output from both food producers and processors (e.g. dairy & beef) by more efficient use of existing resources and processing capacity. The three main themes of the 2010 Bord Bia report Food 6
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Harvest 2020 are Smart, Green, Growth. Ireland’s Agricultural Minister Simon Coveney recently stated that "Ireland needs to develop a strong, recognisable, national brand for Irish food and food products. Our competitive advantage is based on its pre‐existing global image of a ‘green’ island, as well as a sustainable, grass‐
based, year‐round production system with its associated low‐carbon footprint”(5). A wide range of environmental factors impact on the competitiveness of Ireland’s food and drinks industry such as direct and indirect energy costs, regulatory burden, water & waste costs, consumer expectations, corporate social responsibility, etc. Furthermore, changes to the Common Agricultural Policy, WTO agreements and climate change provisions will also continue to cause significant change to the business environment. The growth potential of the sector is dependent on addressing these challenges and ensuring that the industry remains competitive and innovative. According to the Minister, "Ireland must continue to prioritise environmental protection and should scientifically validate the country’s environmental credentials"(5). Enterprise Ireland Enterprise Ireland provides a wide range of grants and other non‐financial supports to Ireland’s indigenous manufacturing sectors. Financial supports include grants for innovation, expansion, training and overseas market development. Enterprise Ireland also advises companies on legislation and best practice guidelines relating to the environment and supports companies to improve their competitiveness through environmental improvements and accreditation. These supports include the implementation of environmental management systems (EMS), the development of carbon management strategies, carbon foot‐printing and life‐cycle analysis (LCA), the development of environmentally superior products/processes and eco‐labeling. As part of its overall sustainability and pollution prevention policy, Enterprise Ireland conducts environmental assessments of both indigenous and foreign multi‐national companies that are in receipt of grant support. These environmental assessments 7
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ are designed to ensure that the grant recipient complies with current environmental legislation and good environmental practice. Assessments involve an on‐site audit to review practices relating to compliance with licence conditions and best environmental practice. Environmental Assessments Enterprise Ireland’s environmental assessments are conducted on‐site and focus on 6 main areas of compliance with regulation and best practice relating to pollution prevention as follows:‐ 1.
Wastewater management; 2.
Atmospheric emissions and air quality in the workplace; 3.
Hazardous and non‐hazardous waste management; 4.
Bulk materials storage and containment; 5.
Noise; and 6.
The general condition of the working environment. In each case, the company’s performance in relation to each of the above criteria is determined to be either compliant or non‐compliant with international best practice. An assessment report is generated and a summary of the findings with relevant comments is sent to the clients to indicate any areas where improvements are required including advice on how to implement these improvements. For the purposes of this study, the findings of the 471 assessments carried out between 1995 and 2011 are collated in 3‐year periods. This is in order to ensure that there are adequate numbers of assessments in each time‐period to allow for meaningful comparisons. 8
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Sub‐sectors BEVERAGES DAIRY PRODUCTS & INGREDIENTS Representative Food & Drinks Products •
Mineral and spring waters, soft drinks and fruit juices •
Alcoholic beers, spirits and liqueurs •
Yellow products (butter, cheese, spreads) •
Infant nutritional products •
Milk powders (skimmed milk powder, fat‐filled milk powder, buttermilk powder, etc.) •
Whey products (butter, alcohol, powders) •
Others (casein, chocolate crumb, lactose, UHT, etc.) •
Food additives, enzymes, colourings, seasonings, batters NON‐DAIRY FOOD INGREDIENTS •
Vitamin and dietary health supplements, functional ingredients and nutritional mixes •
Margarines and cooking fats •
Chocolates, jams, deserts, soups, sauces, sandwich fillers, salads, coffee, crisps, snacks, sweets, etc. PREPARED CONSUMER FOODS PRIMARY MEAT PROCESSING SEAFOOD PROCESSING •
Frozen ready meals & pizzas •
Secondary processed meats – deli hams, pizza toppings, burgers, catering/retail products •
Breads, biscuits, cakes, scones, muffins, pastries •
Pet food, treats and dental chews •
Beef, pork, lamb, poultry •
Smoked salmon, trout and mackerel •
Fresh and frozen seafood Table 2 Principal sub‐sectors and representative products in the Irish food and drinks sector 9
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Objectives of this study This study sets out to document changes in the levels of environmental compliance in Ireland’s food and drinks industry by reviewing data from 471 environmental assessments of 192 Irish food and drinks companies, comprising 220 operational plants/sites, between 1995 and 2011. These companies can be divided into 6 main categories as shown in Table 2. Many, such as Bulmers, Glanbia, Kerry, Dairygold, Abbott, Danone, Cadbury, Cuisine de France and Dawn, are household names and represent some of Ireland’s most significant exporters accounting for 74% (€5.8 billion) of Ireland’s €7.88 billion food and exports in 2010. A full listing of all companies is provided in Appendix I. The study also aims to clearly identify the activities (e.g. wastewater management) that are responsible for most non‐compliances in Ireland’s food and drinks industry and to ascertain the reasons for such non‐compliances. The report also compares the performance of the mainly IPPC‐licensed sub‐sectors (Dairy Foods and Primary Meat Processing) to the non‐IPPC‐licensed sectors (e.g. Prepared Consumer Foods). Approximately 25% of the 220 processing plants in this study are licensed by the EPA under the IPPC Directive. Under the terms of their licences they must have an Environmental Management Plan and submit an Annual Environmental Report to the EPA. Finally, the report aims to demonstrate Enterprise Ireland’s role in improving environmental compliance in Ireland’s food and drinks client companies by virtue of regular environmental assessments but also through the provision of advice and support, financial and otherwise. The assessments are conducted primarily with a view to assuring that companies in receipt of grant payments comply fully with best practice guidelines. The assessments also serve to highlight key environmental challenges being faced by Enterprise Ireland clients so that the organisation might tailor its supports accordingly. 10
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Figure 1 Assessments carried out in each time period and in each sub‐sector. The frequency of assessments is directly linked to the rate of grant approvals in any period. On average, each company was assessed twice, however, in reality approximately 44% of companies were assessed only once, 25% were assessed twice, 17% were assessed three times and 13% were assessed four or more times. More assessments were conducted between 2008/2011 (i.e. 170) than were carried out in any other time period (see Figure 1). This compares with 76 assessments conducted between 2005/2007 and 51 assessments between 2002/2004. Between January 2008/(May) 2011, 141 plants (64%) were assessed at least once and 21 plants were assessed twice. The level of non‐compliance exhibited by each company in each time period was determined by dividing the number of non‐compliances by the total number of criteria (i.e. 6). Therefore, if a given company was found to comply with 5 of the 6 criteria, it was determined to be 83.3% compliant (or 16.7% non‐compliant). 11
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Results Figure 2 shows that, between 1995 and 2011, there were steady improvements in the levels of environmental compliance relating to wastewater management (effluent treatment), bulk storage of materials, waste management and atmospheric emissions. Noise was never an issue and, since 1999, all of the companies assessed have maintained their sites in a tidy condition and free from litter and/or accumulated occasional waste. Figure 2 Changes in the levels of non‐compliance between 1995 and 2011. Non‐compliance is the proportion (%) of companies assessed in each time period that do not to comply with regulation/best practice guidelines. Wastewater Management Only 42% of all food and drinks companies assessed during the period 1995/1998, complied with regulations and best practice guidelines relating to wastewater management. Since then, there have been steady improvements and, by 2008/2011, 63% of the 170 companies assessed during this period were found to comply (see Figure 2). Issues relating to wastewater management (see Table 3) have 12
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ accounted for over 50% of all non‐compliances since 1995. In at least one third of cases, non‐compliance stemmed from companies not having an Effluent Discharge Licence. The Water Pollution Acts (1977 and 1990) and the Water Services Act (2007), the primary legislation relating to water management, aim to protect and improve the current water quality status. Statutory responsibility for both water provision and water management protection rests with local authorities and the EPA. While a large portion of water regulation relates specifically to the provision of safe drinking water, this legislation also provides that all companies that generate industrial effluent (including cooling water and wash water), regardless of volume, must be licensed to discharge to either a water course or to sewer. Effluent Discharge Licences allow companies to discharge a controlled amount of trade effluent to waters (Section 4) or to a public sewer (Section 16), and are issued by the relevant local authorities. When applying to their relevant local authority for a licence, businesses are usually required to provide details on the characteristics and volume of discharge. Most large scale food and drinks companies in Ireland are licensed by the EPA under the IPPC Directive. Provisions for the management of effluent discharges including the extent to which discharges must be monitored and limit values for volume, pH, temperature, BOD, etc. are key provisions in IPPC licences. By comparison, most SME food and drinks companies fall under local authority control. Local authorities include similar provisions in their licences, however, in some cases, due to the relatively low volumes of effluent generated by many of these SMEs, it is not uncommon for companies to assume that they do not require an effluent discharge licence. Companies that do not have the appropriate licence are encouraged to discuss the matter with their local authorities and pursue an agreed course of action leading to obtainment of the required licence. An effluent discharge licence requires the operator to regularly monitor its effluent discharges to ensure that they comply with the emission limit values (ELVs) set out in their licences. Not adequately monitoring discharges and/or not maintaining accurate records accounts for 30% of 13
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ all wastewater management non‐compliances. Furthermore, exceeding ELVs also accounts for 30% of wastewater management non‐compliances. Reason for non‐compliance with wastewater management regulation Proportion of non‐
compliances No effluent discharge licence 37% Inadequate monitoring of discharge characteristics and/or volumes 30% Exceeding emission limit values (ELVs) 30% Inadequate systems for treatment of wastewater prior to discharge 2% Absence of a nutrient management plan <1% Table 3 Wastewater management non‐compliances in Ireland’s food & drinks sector The assessments have revealed that in the case of certain SME food processors the provisions of their licence (volume, pH, BOD, suspended solids, etc.) are not appropriate to their processing activities. This happens because companies do no adequately characterise discharges (volumes and constituent concentrations) prior to applying for a discharge licence with the result that ELVs may be too low and cannot be met in practice. Securing an effluent licence can take up to 3 months and re‐applying for new a licence with revised ELVs can take significantly longer so correcting inappropriate conditions is often ignored. There are costs involved including application fees and associated paperwork (maps, documentation, etc.) and monitoring and analytical costs to determine the maximum volume and characteristics of the discharges. There may be a requirement to invest substantially in effluent treatment which might include anything from a grease interceptor to a dissolved air flotation system depending on whether the effluent is to be discharged to a foul sewer or receiving water. Where effluent is discharged to a foul sewer, the local authority may require the company to monitor volume, pH, suspended solids, oils/fats/greases and/or BOD and then charge the company accordingly. 14
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Alternatively, the local authority, which already charges a fee per m3 of water consumed (approximately €1.10/ m3), may simply charge for water consumed minus domestic use (usually 100 litres per person per day). Storage Non‐compliance with best practice guidelines relating to the storage of hazardous and non‐hazardous materials (fuel oils, lubricant, chemicals and solvents) accounted for 31% of all non‐compliances recorded since 1995. During the period covered by this study, the level of storage non‐compliances fell by over half from 41% in 1995/1998 to 19% in 2008/2011 almost at the same rate as reductions in wastewater management non‐compliances (see Figure 2). This may in part be due to the fact that effluent discharge licences usually include provisions for secondary containment (i.e. bunding) of storage tanks as a means of preventing ground water pollution in the event of a catastrophic failure of the tank. Inadequate bunding accounted for 99% of all storage non‐compliances. Improper storage of hazardous chemicals such as solvents and paints accounted for the remaining 1% of storage non‐compliances. The overall objective of hazardous materials management is to avoid uncontrolled releases of hazardous materials or accidents (including explosion and fire) during their production, handling, storage and use. Oil water separators and grease traps should be installed and maintained as appropriate at refueling facilities, workshops, parking areas, fuel storage and containment areas. Waste Management Inadequate or improper management of waste accounted for approximately 12% of all non‐compliances recorded since 1995. In the period 1995/1998, 16% of companies assessed failed to comply with regulations and best practice guidelines. This increased to 21% in the period 1999/2001 but was reduced to 2.4% by 2008/2011 (see Figure 2). The absence of appropriate permits to either treat, handle or store waste by either the company or the waste contractor accounted for 60% of all waste non‐compliances (see Table 4). The absence of, or non‐adherence to, a 15
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ waste management plan accounted for 26% of non‐compliances. This was followed by inadequate segregation (5%) and improper disposal (4%). Reason for non‐compliance with waste management regulation Proportion of waste non‐compliances Absence of permit for handling and/or storage of waste by either company or waste contractor 60% Absence of waste‐management plan 26% Inadequate segregation of waste 5% Improper disposal of waste (e.g. open burning) 4% Breach of packaging regulations 3% Inadequate record keeping 2% Table 4 Food & Drinks Sector waste management non‐compliances The Waste Management Act 1996 is the main vehicle by which waste policy is enacted, via the provisions on waste collection, waste planning and regulation. The Waste Management Act divides the responsibility for the regulation of waste between the EPA and local authorities. The EPA, however, are the regulatory body responsible for hazardous waste irrespective of whether or not the facility is licensed by the EPA or the local authority. The Waste Management Act forbids the handling, transportation, recovery or disposal of waste when it is done in a manner which causes environmental pollution. It also forbids the use of an unauthorised waste collector or waste management facility. There is a duty to inform a local authority if there is any loss, spillage or accident involving non‐hazardous waste that may cause environmental pollution to arise. Where hazardous waste is involved, both the local authority and the EPA must be informed. Atmospheric Emissions Failure to comply with regulation and best practice guidelines relating to atmospheric emissions accounted for 6% of all non‐compliances since 1995. In the period 1995/1998, 19% of food and drinks companies assessed were non‐compliant. However, by 1999/2001, this figure had decreased sharply to 4% and, between 2001 16
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ and 2011, the level of non‐compliance oscillated between 1 – 2%. Inadequate stack heights accounted for the vast majority of non‐compliances (97%). Excessive dust levels were responsible for 3% of atmospheric non‐compliances. Most industrial activities generate emissions to atmosphere, whether directly from the process, through operation of support facilities such as boilers or through fugitive emissions (e.g. dust, refrigerants). However, only a small proportion of such emissions are significant enough to warrant specific licensing. It should be noted that most of the processes, which are covered by the Air Pollution Act (1987), are now subject to IPPC licensing under the Protection of the Environment Act 2003. However, in situations where IPPC is not applicable a person operating any process or plant to which the Air Pollution Act applies must have an atmospheric emissions licence. This is obtained from the local authority in a manner similar to the procedure for obtaining an effluent discharge licence and involves similar timescales. In practice, the number of licences issued to companies under the Air Pollution Act is very small. Regardless of whether or not a licence is required, any discharge to atmosphere must be through a stack of adequate height to enable proper dispersion and to prevent excessive ground level concentrations of pollutants Noise Ireland’s food and drinks industry fully complies with regulation and best practice guidelines relating to noise by preventing/mitigating noise impacts where they exceed noise level guidelines at the most sensitive point of reception outside the site boundary. While worker exposure to noise is a matter for Occupational Health and Safety, all companies assessed also comply with the practice of providing ear defenders in high noise areas and clearly signposting their use in designated areas. Some of the methods for preventing/controlling noise emissions routinely employed by the sector include silencers for fans, mufflers on engine exhausts and compressor components, acoustic enclosures for equipment causing radiating noise, sound insulation and vibration isolators. Other methods employed include limiting the hours of operation; and re‐locating noise sources to less sensitive areas. There is a strong commitment across the sector to recording and responding to complaints. 17
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ General Condition of Site Best practice guidelines require that all manufacturing and/or processing facilities should be maintained in a tidy condition and free from litter and/or accumulated occasional waste. Another provision is that all surface and ground waters must be adequately protected from contamination by process materials and/or waste. In all assessments conducted since 1999, Ireland’s food and drinks industry were found to fully comply with best practice guidelines relating to the general condition of the site. Comparison of each sub‐sector’s performance In this study, the level of environmental non‐compliance in six different sub‐sectors was examined (see Figure 3). This graph compares the combined environmental non–compliances (i.e. effluent, storage, waste, atmosphere, noise & site) of each sub‐sector. Figure 3 Changes in the levels of non‐compliance by key food & drinks sub‐sectors between 1995 and 2011 (May). Non‐compliance levels are measured by dividing the number of non‐
compliances by the total number of criteria within which compliance was assessed. 18
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Drinks & Beverages Sector This study reviewed the performance of 13 companies in the drinks industry between 1995 & 2011 which together employ 2,053 workers and turnover €1.67 billion, of which exports account for 52% (€867 million). This compares with published export data (Bord Bia) indicating that the participating companies account for 73% of the Irish beverages sector. These companies were assessed 40 times and, over the course of these assessments, the level of environmental non‐compliances fell from 24% in 1995/1998 to 9.7% in 2008/2011. The beverages sector is currently the 3rd most compliant of Ireland’s food and drinks sub‐sectors behind primary meats in 1st and dairy foods and ingredients in 2nd. The beverages sector has the 3rd highest proportion of large companies to SMEs (i.e. 50:50) behind the primary meat processing sector and the dairy foods & ingredients sector each of which are approximately 40:60 SME:Large. Dairy Products and Ingredients Sector This study evaluated the performance of 22 dairy food and ingredient companies, comprising 33 dairy processing plants, between 1995 & 2011 which together employ 6,688 workers and turnover €3.878 billion, of which exports account for 64% (€2.47 billion). This compares favourably with published data from Bord Bia (see Table 1). These companies were assessed 54 times between 1995 and 2011 and, over the course of these assessments, recorded the second highest level of improved environmental performance as measured by a 73% reduction in non‐compliances from 31% in 1995/1998 to 8.3% in 2008/2011. This sector has a ratio of large companies to SMEs of approximately 60:40. The large companies account for more than 90% of dairy exports. Non‐Dairy Food Ingredients Sector The study evaluated the performance of 15 companies in the non‐dairy food ingredients sector which together employ 496 and turnover €383 million, of which exports account for 26%. These companies produce a wide range of non‐dairy ingredients for human and animal nutrition including colourings, flavourings, dietary supplements, chewing gum intermediates, etc. The majority (82%) are SMEs. These 19
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ companies were assessed 34 times between 1995 and 2011. This sub‐sector has always demonstrated relatively high levels of environmental compliance with levels of non‐compliance oscillating between 5% and 13%. Prepared Consumer Foods Sector This study evaluated the performance of 94 prepared consumer foods companies producing a wide range of consumer products including ready meals, processed meats (burgers, deli hams), pizzas, soups, sauces, salads, chocolates and bakery products (breads, biscuits, etc.). Together in 2010, these companies employed 9,454 workers and generated a turnover of €1.86 billion, of which exports accounted for €950 million. This represented a considerable share of the overall sub‐sector which has exports of €1.4 billion. These companies were assessed 214 times between 1995 and 2011. The most significant improvements occurred between 1999 and 2011 when non‐compliances fell from 22.6% in 1999/2001 to 10.2% in 2008/2011. This sub‐sector is dominated by SMEs which account for 84% of the participating companies. Primary Meat Processing Sector This study evaluated the performance of 24 companies in the primary meats processing sector. Together in 2010, these companies employed 8,299 workers and turned over €2.684 billion, of which exports account for 62% (i.e. €1.653 billion). This represents a large proportion of the total sub‐sector which exported €2.2 billion of product in 2010. These companies were assessed 58 times between 1995 and 2011 and, over the course of these assessments, recorded the highest level of improved environmental performance of any of the sub‐sectors as measured by an 84% reduction in non‐compliances from 33.3% in 1995/1998 to 5.2% in 2008/2011. Large‐scale, multinational companies account for 58% of the participating companies in this sub‐sector. 20
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ Seafood Processing Sector This study evaluated the performance of 24 seafood processing plants. Together in 2010, these companies employed 895 workers and turned over €176 million, of which exports account for 59% (i.e. €103 million). This compares with published data indicating that, in 2010, the seafood sector exported €379 million of product. These companies were assessed 53 times between 1995 and 2011 and, over the course of these assessments, recorded modest improvement in environmental performance from 18% non‐compliance to 14% non‐compliance. SMEs account for 100% of the participating companies in this sub‐sector. Discussion Ireland’s food & drinks industry is expected to undergo significant expansion in the coming years to meet burgeoning international market demand. The dairy industry alone, due to the abolition of the milk quota system, is projected to grow by as much as 40 ‐ 50% with corresponding export growth estimated at between €1 billion and €1.25 billion. This expansion cannot happen at the cost of the environment so companies will still be expected to manage their waste and their effluent discharges to ensure continuing compliance with their licensing limits and to invest correspondingly in renewable energy and energy efficiency, in order to meet their carbon reduction targets where they are in emissions trading. The first part of this report has demonstrated that most food and drinks companies now comply with regulation/best practice guidelines relating to waste management, atmospheric emissions, noise and site. However, despite significant improvements, non‐compliances relating to wastewater management and bulk storage remain a difficulty for many companies. Bulk storage non‐compliances stem almost exclusively from the failure of companies to bund their storage tanks, so this problem could be easily and relatively cheaply addressed. By comparison, all aspects of wastewater management including licensing, monitoring, treatment, etc. can be time‐consuming and costly. Furthermore, failure to manage wastewaters, e.g. in the 21
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ context of an expansion, has the potential to seriously impact on both the company and the environment. When we review the results of the sub‐sectoral analysis, it is clear that the performance of the three sub‐sectors dominated by large companies * (i.e. Dairy Foods (62% Large); Primary Meats (58% Large); and Beverages (50% large) demonstrate higher overall levels of compliance than the three sub‐sectors dominated by SMEs* (i.e. Non‐Dairy Food Ingredients (83% SME); Prepared Consumer Goods (84% SME); and seafood (100% SME). Large companies have by far a greater potential to impact negatively on the environment than SMEs. It is, therefore, encouraging that the dairy, primary meats and beverages industries have demonstrated the most significant improvements in compliance, as well as the highest current levels of compliance. By comparison, the SME‐dominated sub‐
sectors, although starting from a higher level of overall environmental compliance in 1995/1998, experienced only modest improvements over the course of the study. Furthermore, rather than improving steadily, as was the case with dairy and primary meats, compliance levels in the SME‐dominated sub‐sectors tended to fluctuate. A possible reason for the observed differences is the greater turnover of small companies which results in more SMEs being assessed for the first time in any one period, as against the more stable large companies, which can demonstrate steady improvements over time on the same site. References 1.
Census of Industrial Production (2008) 2.
Dept. of Agriculture, Fisheries & Food (2008) 3.
Performance & Prospects – Bord Bia (2011) 4.
Sean MacConnell; Surge in agri‐food exports leads to revised targets for vibrant sector; The Irish Times, 27 June (2011) 5.
Teagasc – Agriculture in Ireland (http://www.teagasc.ie/agrifood/)
’
An SME is defined as an enterprise that has fewer that 249 employees and has either an annual turnover
not exceeding €50m or an annual Balance Sheet total not exceeding €43m. By comparison, a large company
employs >250 and/or has an annual turnover of >€50m.
22
Environmental Compliance in Ireland’s Food and Drinks Industry ________________________________________________________________ Appendix I Participating Companies and Groups (IPPC‐ licensed highlighted in bold) Beverages
Dairy
Food Ingredients
Bulmers Ltd. Arrabawn Co‐op Society Ltd. All in All Ingredients Ltd. Celtic Pure Ltd Bandon Vale Cheese Ltd. Beeline Health Foods Ltd. Prepared Consumer Foods
Primary Meats
Seafood
Apollanio Ltd. Ferrero Ireland Ltd. Linhurst Manufacturing Ltd Anglo Irish Beef Processors (AIBP) Atlanfish Ltd.
Aran Candy Ltd. Flamewood Ltd. Lir Chocolates Ltd Ballon Meats Ltd Atlantis Seafood Ltd.
Cappoquin Poultry Ltd. Bantry Bay Mussels Ltd.
Cooley Distillery Ltd. Cadbury Ireland Ltd. Celtic Sea Minerals Ltd. Ballymaloe Country Relish Freshways Ltd. Lough Allen Foods Ltd. Diageo Ireland Cahill's Farm Cheeses Ltd. D D Williamson Ltd. Ballymooney Food Ltd. Fusco Foods Ltd. Mannings Bakery Ltd Carton Brothers Ltd. Clanawley Kilmore Ltd.
Connemara Seafoods Frozen Ltd
First Ireland Spirits Ltd. Carbery Milk Products Ltd. Euroflavour Ltd. Batchelor's Ltd. Gadera Ltd. Mardi Confectionary Ltd. Co‐operative Poultry Products Ltd. Glenpatrick Spring Water Ltd Compsey Creamery Society Ltd. Ingredient Solutions Ltd. Bewley's Ltd. Gaines Europe Ltd. Mileeven Ltd. Dawn Group Harney Enterprises Ltd. Connacht Gold Co‐op Ltd. JDS Foods Ltd. Blender's Ltd. Galmere Fresh Foods Ltd. Milish Foods Edenmore Farm Meats Ltd. Kilkenny Spring Water Ltd. Dairygold Food Ingredients Ltd. Kerry Bioscience Ltd. Boyne Valley Honey Ltd. Garryvoe Foods Ltd. Milish Foods Ltd Garbally Ltd. Lipton Soft Drinks Ltd. Silver Pail Dairy Ltd. Kilfera Nutrition Ltd. Brogan's Bakery Ltd. Gem Pack Foods Ltd. Nutribio Ltd. Grove Turkeys Ltd. P Mulrine & Sons Glanbia Group National Food Ingredients Ltd. C & D Pet Foods Glenhaven Foods Nutweave Ltd. Hermitage Pedigree Pigs Ltd Robert A Merry Glenisk Ltd. Nutricare Ltd. Callan Bacon Co. Glenside Bacon Co. Ltd. O'Haras of Foxford Ltd. Irish Country Meats Sunshine Juice Ltd. Green Pastures Ltd. Nutrition Supplies & Services Ltd. Carleton Cake Co Ltd Green Farm Foods Olhausens Ltd. Kepak Ltd. Terra Ltd. Irish Yogurts Ltd. Odlum Group Ltd. Celtic Chocolates Ltd. Green Isle Foods Ltd. Oliver Carty Ltd. Shannon Vale Foods Ltd. Irfish Ltd.
Kerry Group Sona Nutrition Ltd. Chivers Ireland Heaney Meats Catering Co. P McCloskey & Sons Ltd. Rangeland Foods Ltd. Island Seafoods Ltd
Spice O'Life Ltd. Clonakilty Food Company Ltd. Heatherfield Ltd. Panelto Foods Ltd. Riverview Meat Products Coghlans Bakery Products Ltd. Hilton Foods ltd. Pasta Concepts Ltd. Kildare Chilling Connemara Fine Foods Ltd Hogan's Turkeys Ltd. Perfect Gifts of Ireland Liffey Meats Coolmore Fresh Foods Ltd. Honey Vale Foods Ltd. Pieco International Ltd M & M Walshe Ltd Country Cooking Co Ltd. IGWT Poultry Services Ltd. Prestige Foods Ltd. Martin Jennings Wholesale Ltd. County Kitchens Cuisine Ltd. Iman Casings & Foods Ltd. Quality Irish Foods Ltd. Rosderra Irish Meats Ltd. Cuisine de France Ina's Kitchen Desserts Ltd. Rose Manufacturing Company Ltd. Silver Hill Food Products Lakeland Dairies Co‐op Ltd. North Cork Co‐op Creameries Ltd. Nutricia Infant Nutrition Ltd. Pfizer Ireland The Different Dairy Company Ltd. Tipperary Co‐op Creamery Ltd. Town of Monaghan Co‐op Ltd. Daly's Seafoods Ltd
Dundalk Bay Seafoods Ltd
Dunns Seafare Ltd.
Fastnet Mussels Ltd.
Fish Distrubutors South East
Glenmar Shellfish Ltd.
Good Fish Processing Ltd.
Kinvara Smoked Salmon
Norfish Ltd.
Ocean Path Ltd.
Sean Ward Fishing Ltd.
Shellfish de la Mer Ltd.
Simro Ltd.
The Burren Smokehouse Ltd.
Wexford Creamery Ltd. Dawn Farm Foods Ltd. International Meat Ingredients Rye Valley Foods Ltd Slaney Meats Ltd. United Fish Industries Ltd.
Dawn Fresh Foods Irish Casing Co. Ltd Sam's Cookies Ltd. Staunton Foods Ltd. William Carr & Sons Ltd.
Deli Cuisine Ltd. Irish Roll Company Ltd. Sean Loughnane Ltd. Western Brand Chicken Wrights of Howth Ltd
Dew Valley Foods Ltd. J M Food Services Ltd. Shalvey's Poultry Ltd. Dolmenview Ltd. Java Republic Ltd. Silvercrest Foods Ltd. Drover Foods Ltd. Kells Wholemeal Ltd. Simply Soups Ltd. Dunhill Cuisine Ltd. Kerry Foods Ltd. Stable Diet Ltd. Dunleavy Meats Ltd. Kosy Shack Europe Ltd STGN LTD (Ribworld) Farney Foods Ltd Largo Food Exports Taravale Foods Ltd. Feldhues Production GMBH Lily's Ltd. The Fresh Soup Company Ltd. Vinkala Ltd. Environmental Compliance in Ireland’s Food and Drinks Industry ________________________________________________________________ Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ 25
Environmental Compliance in Ireland’s Food and Drinks Industry ______________________________________________________ 26
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