The idea of an inventory of releases from the UK's major industries crystallised in the run-up to the Environmental Protection Act 1990. The then Environment Minister David Trippier was impressed by the USA's Toxics Release Inventory (TRI) - and instructed HM Inspectorate of Pollution to set up a similar system, though without legislative backing.
A flurry of activity
It has taken nearly a decade for Mr Trippier's vision to be realised. HMIP complied with the Minister's request in a distinctly half-hearted fashion - and its Chemical Release Inventory (CRI) was plagued by inconsistent data, limited scope and poor dissemination. Some CRI data were published years late, if at all.
The Environment Agency, HMIP's successor, set out plans for a new approach two years ago (ENDS Report 269, pp 19-21 ). It, too, displayed little urgency - appearing to share HMIP's reluctance to invest adequate resources in a project which senior managers regarded as a relatively low priority.
Late last year, however, the issue shot up the Agency's agenda - mainly as a result of pressure from Mr Meacher, who has been a strong advocate of communities' "right to know" about their local environment.
In November, the Agency varied all 2,000 or so IPC authorisations, requiring operators to report their 1998 releases (ENDS Report 287, pp 37-38 ). Companies were instructed to report releases to air, water or land against a list of more than 150 substances, provided they exceeded given thresholds. In contrast, reporting requirements under the CRI varied greatly even between similar processes in the same industry sector.
On 12 May, the Agency published the 1998 data on the Internet. The new Pollution Inventory is a huge improvement on the CRI - and is all the more impressive given the short time available to develop software and data handling procedures. ENDS understands that developing the system cost the Agency more than £100,000.
Mr Meacher congratulated the Agency "on how far it has come from the CRI and in such a short time." The Minister said that: "The Inventory has a key role in focusing attention on polluting emissions and pressing for a reduction of them. The TRI has shown the power of information - that is exactly what we are aiming for, an empowering of local people."
Provision of the data on the Internet is a major step forward in improving dissemination. Friends of the Earth (FoE) showed the way in this field. Since 1995, it has published CRI data, warts and all, on its website (ENDS Report 249, pp 8-9 ).
The Agency has received only 40 or so inquiries per year for CRI data at its regional offices. However, more than 2,700 visitors used the Pollution Inventory website in its first week, despite teething troubles with some of the software.
Moreover, the database can be interrogated in several ways. Like FoE's website, users can search by postcode or map to find the location of IPC-authorised sites and associated releases. Searches by company name, industry sector, and pollutant are also possible - and it is a simple matter to draw up a list of sites with unauthorised releases.
However, the Agency has been shy in highlighting one key aspect of the Inventory - the ability to produce league tables of the main sources of each pollutant. This function is one of the main reasons why environmental groups such as FoE have campaigned for meaningful inventories - and has also been the main reason why many in industry have opposed them.
Pros and cons of league tables
Experience from the USA suggests that the TRI has spurred major emission reductions programmes by turning the spotlight on individual factories or sectors. Mr Meacher endorsed the approach, observing that "where meaningful comparisons can be made, it is proper that they should be."
Paul Leinster, the Agency's Director of Environmental Protection, suggested that league tables could also be useful for regulators. He noted that of the reported releases of lead to air and zinc to controlled waters, more than 90% were accounted for by 19 and 10 processes, respectively. "The Inventory can help us target our resources and develop a risk-based approach to regulation," Mr Leinster said.
Industry's concerns over the use of inventories have mellowed in recent years. Doug Rodger, Executive Director of the Chemical Industries Association, welcomed the move to "publish high quality information which we can use to demonstrate the reduction in emissions that has been achieved." Indeed, some chemical companies see links with environmental reporting - and the potential to use verified and standardised emissions data to benchmark performance.
However, Mr Rodger stressed the familiar concern that Inventory data, "viewed in isolation, can give a very misleading picture" because it deals only with industrial sources covered by IPC. Industry's long-standing call for data to be presented "in context" may be partly answered by plans to bring other industrial sources and, potentially, traffic into the Inventory (see below).
FoE has already ruffled feathers by publishing league tables. In February, it named "Britain's filthiest factories" based on emissions of "recognised" carcinogens in 1996, as reported under the CRI (ENDS Report 289, pp 9-10 ). The CIA complained that the group's "blanket use of the word 'carcinogens'...could raise alarm."
Undaunted, FoE issued a "list of shame" derived from Inventory data in late May. The group listed the main sources of dioxins, "toxic" (or special) waste and acid gases - along with an updated list of sites releasing "cancer-causing chemicals". The table shows significant differences from the 1996 data, not least an apparent 50% increase in emissions from ICI's Runcorn site and the addition of a fourth ICI site, Thornton-Cleveleys, to the top ten (see table ).
Comparison with the CRI
The Agency cautions against comparing Pollution Inventory data with that on the CRI. However, this message has been muddied by the Agency's own proud claim that the Inventory "shows significant reductions in key pollutants."
The first problem in comparing data with previous years is that operators now report total emissions from the whole process, including releases not covered by specific limits. The second is that many significant sources have not previously appeared because of inconsistent reporting requirements under the CRI.
For example, British Steel's works dominate the list of dioxin sources for 1998 (see box ) - but none reported dioxin emissions under the CRI. Similarly, under the new Inventory 51 sites reported emissions of the potent greenhouse gas nitrous oxide (see box ) - compared to just one or two under the CRI.
However, the new reporting procedures have a downside. Under the CRI, many sites reported releases of chemicals which do not appear on the Agency's "core list" of 150-odd substances. In such cases, information on annual discharges has actually decreased - often to an alarming degree.
Take Great Lakes Chemical's site in Newton Aycliffe, County Durham. Under the CRI, the company reported annual releases of two substances to air and six to water, together with waste arisings of brominated organic compounds. The new Inventory only shows figures for releases of three substances to air and total special waste arisings. And incidentally, Great Lakes was not required to report releases of brominated flame retardants under either system - even though the site has been linked to contamination of rivers with the chemicals (ENDS Report 291, pp 7-8 ).
The Agency still requires operators to report releases of "non-core" substances. A spokesman said that it hopes to add these data to the website at some point in the future.
How good are the data?
Other concerns surround the Inventory data. Firstly, the Agency has withheld all release data for 56 of the 2,000 or so IPC processes on the grounds of commercial confidentiality - even if the confidentiality claim applied only to one substance.
Secondly, operators were required to provide release estimates retrospectively and at short notice. The Agency anticipates that "future years' data will be of a higher accuracy as operators improve their methods for reporting."
Thirdly, operators appear to have taken different approaches to reporting. The issue is particularly apparent for sites where toxic chemicals may be present in large-volume discharges to water at or below the threshold of detection (see box ).
Some serious errors also appear to have been introduced by the Agency's data handling procedures. For example, the database suggests that no IPC process exceeded the 100kg annual reporting threshold for hydrofluorocarbons. Yet at least one site - ICI Runcorn - is well known as a major source of these potent greenhouse gases.
In 1998, the Runcorn works released 864 tonnes of HFC-23 - equivalent in global warming terms to nearly 2% of the UK's total carbon dioxide emissions. ICI says it notified the Agency of this release, along with smaller releases of other HFCs and HCFCs which also failed to register on the Inventory. ICI hopes to commission an incinerator to abate most of its HFC releases by the end of this year (ENDS Report 261, pp 4-5 ).
Many of these issues reflect the rush to publish the Inventory, and should be ironed out over time. The Agency has set up an advisory committee, with representatives from industry, pressure groups and Government Departments, to advise on the Inventory's development - including clearer guidance on how to measure or estimate releases.
Extending the Inventory's scope
In future, the Agency hopes to include information on emission limits and breaches, together with details of prosecutions or enforcement action. It also hopes to provide more information on the health impacts of individual pollutants - a topic dealt with only sketchily at present.
The Agency also wants to include data on emissions from other processes it regulates, such as landfill sites and sewage treatment works. Mr Meacher noted that "this would take the number of installations reporting into the Inventory from 2,000 to 13,000," and promised to consider the move "very closely".
The Minister noted that "an obvious candidate for broadening the scope still further is the 13,000 or so installations" regulated by local authorities under LAPC. He hoped "in the near future" to announce a preliminary view on the feasibility of this. One issue will be whether LAPC sites would be required to report releases to water and land.
The Agency also floated the idea of including diffuse sources of pollution such as traffic to form "a truly comprehensive pollution inventory." Mr Meacher agreed that data on traffic congestion and emissions should be included.
All change under IPPC
The evolution of the Pollution Inventory will be closely linked to the implementation of the 1996 EC Directive on integrated pollution prevention and control (IPPC).
The first challenge is that IPPC focuses on "installations" rather than the narrow process-based approach under IPC. In a nod in this direction, the Agency has presented Inventory release data for clusters of processes on the same site. But IPPC is likely to require redrawing of boundaries for reporting - leading to problems in ensuring comparability of data.
Secondly, existing installations will come under IPPC in a phased programme over the next six or seven years. This gradual changeover could repeat one of the CRI's main drawbacks - by making year-to-year comparisons almost meaningless. Moves to extend the Inventory to sewage treatment works, landfills or LAPC processes could exacerbate the problem.
The Pollution Prevention and Control Bill, currently before Parliament, could provide a solution. One clause empowers the Secretary of State to require "persons of any specified description (whether or not they are holders of permits)" to report emissions data. As a result, all operators due to come under IPPC could be required to report annual releases well before they apply for an IPPC permit.
The Agency is keen on this "two-stage" approach to implementing IPPC, and wants all IPPC sites to start reporting releases from 2000. It not yet clear whether the DETR will go along with this approach.
The Agency also wants the Government to amend the Bill to make it clear that reporting of releases may be required for non-IPC/IPPC activities already under its control. Mr Meacher insisted that the Bill "already contains the necessary powers to extend the inventory." However, the existing clause appears to exclude any provision for reporting of energy consumption - which the Agency feels may be needed in the future, possibly as part of the energy tax regime.
The IPPC Directive requires the European Commission to publish a "polluting emissions register" (PER) based on data from Member States. One result is that the Scottish Environment Protection Agency will have to develop its own inventory. The Environment Agency has offered to make its database model available, but ENDS understands that SEPA is working on a less ambitious version.
Indeed, the Pollution Inventory goes far beyond the limited PER which has so far been discussed at EC level (ENDS Report 286, pp 41-42 ). The Agency hopes that the Inventory will influence development of the PER - and has been encouraged by enthusiastic responses from Swedish and German regulators.