Environmental Compliance in Ireland s Print, Packaging & Labelling Sector

Environmental Compliance in Ireland s Print, Packaging & Labelling Sector Enterprise Ireland is a member of The Print & Package Forum

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Environmental Compliance in Ireland s Print, Packaging & Labelling Sector. Mary Doolan & Tadhg Egan 3

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Table of Contents Executive Summary... 6 Introduction... 8 Enterprise Ireland... 10 Objectives... 11 Results... 11 Wastewater Management... 12 Bulk Storage... 14 Atmospheric Emissions... 15 Waste Management... 16 Noise... 17 General Condition of Site... 18 Discussion... 19 References... 21 5

Executive Summary The print, packaging and labelling sector is long established in Ireland. It serves a wide range of sectors of the economy with an equally wide range of products and services. In 2011, Enterprise Ireland companies in this sector had a turnover of 448 million and exports of 131 million 1. The main market focus for this sector is domestic, while the major export markets currently served include Northern Ireland and Britain with increasing penetration into European markets. At present, the print, packaging and labelling sector is experiencing difficulties. In the print sub-sector issues such as; over capacity in the market, customer driven cost reductions, increased raw material costs, reduced product demand and service demand for quicker product delivery are the main challenges. Whilst in the packaging and labelling sub-sector, there are increased product volumes, but customer driven cost reductions, increased raw material costs and service demand for quicker product delivery are the main concerns. Increasingly the sector needs to grow sales, reduce unit costs and improve profitability through other avenues such as service offers, increasing exports or achieving sales through product differentiation. Enterprise Ireland conducts environmental reviews on client companies in receipt of grant support to ensure they are complying with regulation and best practice. These reviews are carried out at the facility and focus on six main areas: wastewater management, atmospheric emissions, waste management, bulk storage, noise and the general condition of the site. Sixty companies in the print, packaging and labelling sector were reviewed over the period 1995 to 2011 with approximately 100 reviews carried out in all. The findings of these reviews form the basis of this study. In the print, packaging and labelling sector, wastewater management issues accounted for most non-conformances in the six areas assessed. The main 1 Source: Enterprise Ireland internal data. 6

difficulties arose with the Effluent Discharge Licence, for example, monitoring of wastewater characteristics and volumes and/or instances where emission limit values were exceeded. Inadequate storage of chemicals, solvents and fuel oils proved to be the next most frequent cause of non-conformity. This was primarily due to issues with bunding. With regard to atmospheric emissions, issues regarding stack height, insufficient extraction and exceeding emission limit values accounted for the main reasons for non-conformances. Waste management non-conformances were due to improper waste disposal and a lack of waste segregation. Noise abatement and the general condition of the site have given rise to very few issues of concern. The trend in non-conformances in each of the six areas assessed has been decreasing over the duration of the study, thereby indicating significant improvements in environmental performance in the print, packaging and labelling sector. 7

Introduction Ireland s print, packaging and labelling industries are well established serving a wide variety of economic sectors. They provide a wide range of products and services to manufacturing sectors such as pharmaceuticals, medical devices, cosmetics, ICT, food and beverages, financial services, education, sports and media. Printed products range from brochures and lotto tickets to security documentation and periodical magazines. Packaging products include plastic trays, cartons, bags, bottles, corrugated containers, pouches, cases and trays at one end of the scale and sophisticated pharmaceutical (blister packs), laminated trays (gas barrier for long life packaging) and medical (laminated pouches) at the other supplying a wide range of sectors. Labelling products include self adhesive labels, warning labels, security labels, durable nameplates, bar code labels as well as packaging design services primarily serving the pharmaceutical, medical, cosmetic, food, drinks and ICT sectors. In 2011, Enterprise Ireland companies in the print, packaging and labelling sector achieved an annual turnover of 448 million with exports totalling 131 million 2. The most important export markets include Northern Ireland, Britain and Eastern Europe but markets in Central Europe, the US and New Zealand are growing. Although there is a clear domestic market focus, the actual products of the print, packaging and labelling sector are in fact exported as components of goods from such industries as pharmaceuticals and food. Currently Ireland s print industry is challenged by over-capacity relative to market demand. Print volume has decreased due to the on-going move from print to web for traditionally printed items such as reports and forms. Along with this market decline, the economic downturn has led to demands for cost reductions with increased pressure on profit margins. However, an increase in export volumes of pharmaceutical, medical device and food products has provided significant growth opportunities for the labelling and packaging sub- 2 Source: Enterprise Ireland internal data 8

sectors. But, price reductions have had a mitigating effect on the positive volume rises in both of these sub-sectors. Future growth is dependent on addressing these challenges. Traditionally focussed on the domestic market, growth will rely on increased exports. As the largest export market for this sector, the UK is often the first target for new exporters. Enterprise Ireland, through its network of overseas offices, is aiming to tap into the high levels of sustainability and regulatory compliance as a means of promoting Irish products, especially packaging and labelling, to manufacturing sectors where these companies have a track record in Ireland (i.e. medical, pharmaceutical, cosmetics, food, etc.). By branding Irish companies on their green credentials and other relevant sustainability criteria such as the use of recyclable/biodegradable materials, less hazardous raw materials, the development of ecologically safer products, better pollution controls and more energy efficient operations and by emphasising the provision of products and services that are more environmentally sustainable, opportunities for growth may exist in terms of creating a differentiated offer within this sector. Customer Sectors Products & Services Food and Beverages Pharmaceutical and Healthcare Information and Communication Software, High-Tech and Electronics Financial Services Transport and Logistics Design and Advertising I.T. Education Retail Trays, containers, carrier bags, plastic bottles, pouches. Anti-static drum liners, foil barrier bags, litho laminate cartons. Business forms, letterheads insurance certificates, bank statements. Periodical magazines, direct mail inserts, brochures, annual reports, leaflets, flyers, book covers. Corrugated cases, protective packaging Bill boards, bus side images, banners and posters. Typesetting, litho and digital printing, folding and binding. Table 1 Print, packaging and labelling products, services and customer sectors. 9

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 ranging from R&D and expansion, to building a green and sustainable business, to increasing competitiveness, as well as training and overseas market development. Enterprise Ireland also conducts environmental reviews of Irish-based companies that are in receipt of grant support. The environmental reviews are designed to ensure that the grant recipients conform with current environmental legislation and good environmental practice. Reviews are carried out on-site to establish compliance with environmental regulation and best practice relating to pollution prevention. The areas examined were; 1. Wastewater management 2. Atmospheric emissions 3. Waste management, including hazardous and non-hazardous 4. Bulk material storage and containment 5. Noise 6. General condition of the site Once the environmental review is complete, a report is generated to record the company s performance with respect to each area. This report includes a summary of the findings along with any necessary recommendations or advice required to address issues where improvements and rectifications need to be carried out. Fulfilling the recommendations that result from an environmental review can improve the overall sustainability of a company and help them enhance their environmental credentials. 10

Objectives The principal objectives of this study on the print, packaging and labelling sector include the following; to examine the findings of the environmental reviews carried out on companies in this sector throughout the period 1995 to 2011. to show the findings of the reviews in terms of the changes that have occurred in the level of environmental conformance throughout this time frame. to identify which areas companies are having most difficulty in achieving environmental conformance. to identify the reasons why there are difficulties in maintaining conformance. to review the principal recommendations of the environmental reviews regarding non-conformance issues. Results Over the period 1995 to 2011 there have been 100 environmental reviews carried out by Enterprise Ireland on 60 companies in the Irish print, packaging and labelling sector. The findings of these reviews form the basis of this study on environmental conformance within this sector. The reviews are grouped into three year periods, to ensure there are adequate numbers of reviews in each time frame to allow for meaningful comparisons. Approximately 65% of the companies have been assessed once, with a further 20% having had two reviews over the time period. The remaining 15% of companies have been assessed between three and five times throughout the timeframe 1995 to 2011. 11

Figure 1. Trends in the level of non-conformity in each area assessed over the time period 1995 to 2011. Nonconformance is the proportion (%) of companies assessed in each time frame that do not comply with regulation and/or best practice. Variations in the level of environmental compliance in the print, packaging and labelling sector between 1995 and 2011 are represented graphically in figure 1. There have been no non-conformances recorded in relation to the general condition of the site since the reviews began in 1995. Since 1999, there have been no issues of concern regarding noise. Between the years 1995 and 2011 the overall trend in relation to non-conformances in the areas of wastewater management, waste management, atmospheric emissions and bulk storage is downward in all instances. This is a positive outcome for the print, packaging and labelling sector. Wastewater Management The primary pieces of legislation that relate to wastewater management are the Local Government (Water Pollution) Act 1977, the Local Government (Water Pollution) (Amendment) Act 1990 along with the Water Services Act 2007. The public authorities with statutory responsibility in this area, are the Environmental Protection Agency (EPA) and the Local Authorities. In order to allow companies and other bodies discharge controlled amounts of trade effluent to a public sewer, surface water or ground water, they must have a water pollution discharge licence. Section 4 of the Water Pollution Act (1977 12

and 1990) refers to the discharge of trade or sewage effluent to waters, whilst section 16 of the Act refers to the discharge of trade effluent or other matter to a sewer. It is an offence not to comply with the terms and conditions of a Discharge Licence. Large industrial activities require an Integrated Pollution Prevention Control or IPPC licence, which is issued by the EPA. The requirement to have an IPPC licence is determined by Schedule 1 of the EPA Act 1992 as amended by the Protection of the Environment Act 2003. According to the results of the reviews carried out by Enterprise Ireland, nonconformances regarding the issue of wastewater management ranged initially from a level of 29% during the time frame 1995-1998, subsequently this level of non-conformance increased to 37% during 2002-2004. There was a further increase again during the period 2005-2007, whilst during the final phase of the study non-conformances decreased significantly to 15%. This represents an overall decrease of 14% in the level of non-conformance that relates to wastewater management between 1995 and 2011. Wastewater management issues accounted for 39% of all non-conformances recorded throughout the study period. The most recurring reason for nonconformance related to issues with the Effluent Discharge Licence (see Table 2). In some instances the company may not have been in possession of a Licence and would need to determine through the local authority if a Licence was required. Whilst in other cases, no Effluent Discharge Licence was held, there was a need to have a Licence and so the procedure to make an application for a Licence would commence. Inadequate monitoring of discharge parameters or volumes was cited as a reason for non-conformance among some with effluent licences. Whilst in a smaller number of instances, exceeding an emission limit value was the reason cited for the nonconformance. 13

Reasons for non-conformity with wastewater management regulation Proportion of noncompliances Issues with Effluent Discharge Licence. 79 % Inadequate monitoring of discharge characteristics and/or volumes. 18 % Exceeding emission limit values (ELVs). 3 % Table 2 Wastewater Management non-conformances in Ireland s print, packaging and labelling sector. In the print, packaging and labelling sector, the main sources of wastewater arise during cleaning or washing down of equipment such as plates, screens or rollers. The resultant wash water may contain pollutants such as sediments, particles and chemicals. Effluent management should where necessary include the recovery of silver from wastewater as its release into the environment is strictly regulated. Where it is possible to do so, less hazardous alternatives for cleaning should be employed, for example using water based cleaners instead of solvent based ones. Bulk Storage Environmentally hazardous materials such as chemicals, solvents and fuel oils for use on site require special handling and storage. Throughout the duration of the study non-conformances regarding storage in this sector have declined from 41% between 1995 and 1998 to 15% between 2008 and 2011 (see Figure.1). This represents a decrease of 26% in non-conformances regarding storage. Bulk storage and containment issues accounted for 35% of all the non-conformances recorded in this sector throughout the study. The reason for these non-conformances has been documented as inadequate or no bunding. Due to the nature of their business, print, packaging and labelling companies will normally need to store environmentally hazardous material on site. Chemicals, solvents, oils and fuels must be stored in an adequately bunded area. This means that in the event of a spill or leak occurring, it does not reach the storm water system or leach into the ground. The bund itself should 14

befit its purpose, i.e. be constructed of impervious material, have more than sufficient capacity to retain the contents of the vessel and any outdoor storage areas should preferably be roofed to prevent rainwater entering or have sufficient capacity to deal with rainfall amounts. If bunding is to be effective, regular maintenance and appropriate operation is required. The transfer of hazardous materials around or from the site should be carried out in a manner that will prevent accidental spills or lead to unnecessary contamination. Atmospheric Emissions Issues regarding atmospheric emissions accounted for 17% of the total nonconformances recorded since 1995. In the initial period of the study, 1995-1998, the level of non-conformance with Regulation and best practice stood at 41%. This decreased significantly in the subsequent period to 23%, whilst between 2002 and 2004 there were no non-conformances recorded. Nonconformance increased to 5% between 2005 and 2007, but full conformity was achieved again between 2008 and 2011. The primary reasons for nonconformance in this sector were due to inadequate stack height, inadequate process extraction and/or ventilation along with exceeding emission limit values (see Table 3). Reasons for non-conformity with atmospheric emissions Proportion of noncompliances Inadequate stack height. 43% Inadequate process extraction/ventilation. 36% Exceeding emission limit values (ELVs). 21% Table 3. Print, packaging and labelling sector atmospheric emission non-conformances. Atmospheric emissions are primarily legislated for under the conditions of an IPPC Licence issued by the EPA or Schedule 1 and 2 of the Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002 lists activities that must comply with the Regulations. 15

The control of air pollutants can either be achieved by preventing or minimising the generation of pollutant or through the installation of control equipment. Minimisation can be achieved through substitution or use of alternatives, such as the use of water based ink, UV ink or vegetable oil based ink instead of solvent based ink. Further reductions in emissions can be achieved through the use of abatement technologies. Some of these may include, adsorption, incineration, condensation, scrubbing systems or biological treatment. The remaining discharge to atmosphere must be through a stack of adequate height to facilitate proper dispersion through the air. Waste Management The Waste Management Act 1996 is the main legislative item governing the recycling and disposal of waste in Ireland. The primary provisions of the Act allow for the effective organisation of public authority functions in relation to waste management. It specifies measures that improve the prevention and recovery of waste and requires the transfer of waste only to an authorised person. It prohibits the recovery or disposal of waste at an unlicensed facility and sets duties on individuals who carry out certain activities to take steps to prevent or minimise waste production. It also sets out penalties for not complying with the Act. The Waste Management (Packaging) Regulations 2007 places further environmental responsibility on those who supply packaging. The performance of the print, packaging and labelling sector regarding nonconformance on waste management issues has decreased from a level of approximately 12% between 1995 and 1998 to 2.6% between 2008 and 2011 (see Figure.1). Between 2002 and 2007 there were no non-conformances recorded in this sector. For the duration of the study period there has been an overall decrease of approximately 9% in the level of non-conformity. Waste management issues accounted for approximately 7% of all non-conformances and the main reasons recorded were improper waste disposal and a lack of waste segregation. 16

The main types of wastes generated by this sector include waste toner cartridges, compact discs, ink, oils, some of which may be described as hazardous or difficult wastes. Dry wastes include paper, card or other substrates. Whilst incoming packaging, such as cartons, boxes, wrappers, pallets, shrink wrap and plastic straps and bags are also sources of waste. Other wastes ranging from office paper to floor sweepings or fluorescent tubes will occur as per other sectors. With regard to producers of packaging, it is within their interest to work with customers on acceptable minimal packaging, thereby reducing the amount of material placed on the market. When there is a lack of waste segregation, as identified as a reason for nonconformance in this study, it can impact negatively on recycling and re-use of waste, thereby causing an increase in the disposal of waste to landfill. In order to offset this, procedures need to be put in place which will facilitate waste segregation. These should include, storage options for separating waste such as colour coded bins, training and raising employee awareness regarding the need for segregation, followed by inspection to ensure procedures are followed. Noise Companies that are regulated by the EPA may have noise limits imposed on them through the IPPC licensing process. Since 1999 there have been no issues of concern regarding noise in this sector. Issues may arise in relation to vehicle movements, filling or emptying of waste bins, public address systems or machine noise depending on where it is located on site. A management procedure should be put in place to bring noise to an acceptable level if it is above the desired limit. This would require monitoring to establish actual levels, followed by the implementation of noise reduction measures, for instance, shielding or muffling of machinery or equipment, being mindful of issues that are likely to raise noise levels and maintaining good communications with neighbours. 17

Occupational exposure to noise comes under the remit of the Health and Safety Authority and is legislated for under the Safety, Health and Welfare at Work (General Application) (Amendment) Regulations 2007, Chapter 1 of Part 5: Control of Noise at Work. It is the employer s responsibility to ensure that workers are protected from excessive noise levels, primarily through elimination or control of noise at source. If this is not achievable then the use of personal protective equipment supported by appropriate signage will be required. General Condition of Site In all reviews carried out since 1995 the print, packaging and labelling sector has been found to be fully compliant with best practice guidelines relating to the general condition of the site. This means that each facility has been maintained in a clean, orderly state with no accumulation of litter or waste. The best practice guidelines also provide for the adequate protection of all surface and ground waters so as to ensure that contamination by process materials and/or wastes does not occur. 18

Discussion The Irish print, packaging and labelling sector is currently faced with a number of market challenges. These include reduced demand for products and services, changes in technology which negatively affect order volumes along with customer demands for cost reductions. This has made it difficult for companies, particularly those in the printing sector, to operate within this market. Hence, there is a need to increase sales, by way of exporting and entering new markets to increase market share or through product differentiation such as branding or building on green credentials and environmental sustainability of products and services. From the findings of the environmental reviews on the print, packaging and labelling sector, there has been a significant improvement in the level of conformance in each of the six areas assessed. However, there are areas where greater conformance could be achieved, in some instances through relatively simple measures, whilst in other cases the process of achieving conformance may involve greater effort in terms of time and expense. In relation to wastewater management, the primary non-conformances arose out of issues relating to the Effluent Discharge Licence and this may often require contact with the relevant authorities for clarification on how to rectify the situation. Inadequate monitoring of discharge parameters or volumes was the next most frequently cited reason for non-conformance, whilst in a smaller number of cases exceeding emission limits was the cause of the nonconformance. With regard to storage the foremost issue of concern relates to inadequate or no bunding. This is in relation to both fuel sources and chemicals and should be rectified through the provision of an adequately bunded area whereby filling and off-take points are also located within the bund. On the subject of waste management, the main issues for this sector were due to improper waste disposal or inadequate waste segregation. These 19

issues can be addressed through the implementation of appropriate procedures, for instance, preventing solvent contaminated material (e.g. rags) from entering the general refuse. Non-conformances regarding atmospheric emissions have in some cases been due to inadequate stack height. This should be addressed by raising the stack height to the desired level above the roof. Other non-conformances in this area require the provision of appropriate extraction or ventilation systems in order for rectification to be achieved. The sector has performed well concerning compliance on the general condition of the site and noise abatement. Through continued improvement in environmental compliance, it is possible for companies in the print, packaging and labelling sector to use this process to their benefit in terms of building green credentials and branding environmental sustainability into their products and services. 20

References Local Government (Water Pollution) Act, 1977. Local Government (Water Pollution) (Amendment) Act, 1990. Air Pollution Act, 1987. Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002, S.I. No. 543 of 2002. Protection of the Environment Act 2003. Waste Management Act, 1996. Waste Management (Collection Permit) Regulations 2007, S.I. No. 820 of 2007. Waste Management (Collection Permit) (Amendment) Regulations 2008, S.I. No. 87 of 2008. Waste Management (Packaging) Regulations 2007, S.I. No. 798 of 2007. Safety, Health and Welfare at Work (General Application) Regulations 2007, S.I. No. 299 of 2007, Chapter 1 of Part 5. How to obtain an Effluent Discharge Licence, Best Practice Guide BPGCS006, www.envirocentre.ie/includes/documents/bpgeffluentlicence.pdf Best Practice Guidance Document Printing and Packaging Sector, www.envirocentre.ie Department of the Environment, Community and Local Government, www.environ.ie/en/environment/water/waterservices/legislation/ The Future of The European Print industry-in Our Own Hands, What the Industry Says, www.ipex.org/files/futureoftheprintingindustry.pdf Environmental Action for the Printing Industry, NSW Government, www.environment.nsw.gov.au Irish Printing Federation, Looking Back and Looking Forward, www.irishprintingfederation.ie Print & Packaging Ireland (Directory), Enterprise Ireland, www.enterprise-ireland.com Print & Packaging Enterprise Ireland, www.enterprise-ireland.com A Developing Future, A study of the Paper, Print & Packaging Industry, February 2005, www.fas.ie/en/pubdocs/developingfuturereport.pdf Print and Packaging Forum, A Report on the Print Industry s Review of Its Own Performance. Capacity Rationalisation and Exit Barriers in the Irish Printing Industry, Dublin Institute of Technology, School of Marketing. Connecting Ireland, Print & Packaging; Industry sector profiles. 21