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Manchester |
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Bristol |
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At present the Regulation 61 Notice affects any operator in the Food and Drink Sector. You will be required to make a review of sector specific BAT (Best Available Technique). This could be quite a simple undertaking, with very little consequence to your business . . . or it could be a lot of work, both in terms of paper work and real world upgrades.
The Environment Agency is required to review permits, following publication of a revised Best Available Techniques (BAT) Reference Document, and associated BAT Conclusions for Food Drink and Milk, which were published on 4 December 2019 in the Official Journal of the European Union.
The Industrial Emissions Directive (IED) requires EPR permits to be reviewed within four years of publication of the relevant Best Available Techniques Reference Document (BRef) BAT conclusions. The Food, Drink and Milk Industries BRef was published on 4 December 2019.
The old adage "The only two certainties in life are death and taxes" should perhaps be modified to include Regulation 61 Compliance.
"Failure to comply with this notice without reasonable excuse is an offence under Regulation 38(4)(a) of the Environmental Permitting (England and Wales) Regulations 2016, and may lead to legal action being taken against you."
You will have to fill out relevant sections of of the R61 Response Tool. 2 examples, from 4 or 5 dairy based BAT Criteria:
In order to reduce the quantity of waste sent for disposal, BAT is to use one or a combination of the techniques given below.
Techniques related to the use of centrifuges
(a) Optimised operation of centrifuges
Techniques related to butter production
(b) Rinsing of the cream heater with skimmed milk or water
Techniques related to ice cream production
(c) Continuous freezing of ice cream
Techniques related to cheese production
(d) Minimisation of the
generation of acid whey
(e) Recovery and use of whey
In order to increase energy efficiency, BAT is to use an appropriate
combination of the techniques specified in BAT 6 and of the techniques given
below.
(a) Partial milk homogenisation
(b) Energy-efficient homogeniser
(c) Use of
continuous pasteurisers
(d) Regenerative heat exchange in pasteurisation
(e) Ultra-high-temperature (UHT) processing of milk without intermediate
pasteurisation
(f) Multi-stage drying in powder production
(g) Precooling of ice-water
So in conclusion you can see how Regulation 61 could create a significant amount of work, for food processors and dairies that have not received any attention from the Environment Agency for a number of years. Whilst modern sites are unlikely to have had the possibility to fall behind, older sites with little proactive input could have a considerable amount of work to do.