For an initiative intended to demonstrate that voluntary initiatives by business can complement - or be more effective than - regulations or taxes in achieving environmental goals, the EBF is some way from its goal. Only some 250 organisations have joined the Forum in more than two years, well below the CBI's target (ENDS Report 230, p 3 ).
John Gibbs, Deputy Technical Director at Pfizer's Sandwich site in Kent, says he is "very disappointed in the impetus of the Forum. People don't appreciate how they can tailor it to their own requirements".
Pfizer was an early EBF signatory, joining in April 1992, but Mr Gibbs understands why much of industry is hanging back. Pfizer itself, he acknowledges, was "a reactive organisation over environmental issues." The company had assumed that it had good relations with the local community, and that the 2,500 staff at its Sandwich site were aware of its existing efforts to protect the environment. In practice, Mr Gibbs says, "we found this to be far from the truth".
Mr Gibbs told a recent EBF meeting that a key factor behind Pfizer's involvement with the Forum was that at the time its parent company in the USA had no environmental policy. Received wisdom suggests that major US firms tend to lead the way in environmental management and reporting and require their overseas arms to follow suit. However, many pharmaceuticals companies have preferred to keep a low environmental profile, seeing no business advantage in goingpublic because doctors do not generally see the environment as a key issue. Following the success of the Sandwich initiative, the US parent has recently published its own environmental policy.
The Sandwich complex is Pfizer's only manufacturing site in the UK. It produces a wide range of active ingredients for medicinal and veterinary use by small-scale organic synthesis or a larger fermentation process, and also processes them into the finished products. A growing number of staff are employed in the site's research laboratories.
Mr Gibbs stresses that Pfizer had been seeking to reduce the site's environmental impact for some years before joining the EBF. Since 1985, it has employed a hazard rating policy to reduce consumption of more hazardous materials, leading to a move away from anhydrous hydrogen chloride and gaseous ammonia. The site's inert waste is disposed of at Pfizer's own nearby landfill, but the company did conduct some auditing of external contractors before the "duty of care" rules came into force in 1991. Its procedures appear to have been similar to, if less rigorous than, those adopted in the mid-1980s by Beecham Pharmaceuticals (ENDS Report 150, pp 13-14).
The decision to sign up to the EBF put these activities into a higher gear. Pfizer was particularly attracted by the scheme's voluntary nature, together with the emphasis on continuous improvement and the freedom to set targets tailored to its own objectives. "We'd have got round to taking the environmental initiative eventually," says Mr Gibbs, "but the EBF has focused our minds on doing it". Intriguingly, Pfizer had already signed up to the Chemical Industries Association's "Responsible Care" programme - but continues to focus its efforts on the EBF.
Pfizer's first step on joining the EBF was to publish a seven-point action plan. Some of the steps were achieved relatively easily. Technical Director Maurice Jones was given responsibility for environmental affairs, and an environmental policy was published and communicated to employees through the staff newsletter.
Other areas of the action plan required more upheaval. Pfizer promised to complete a detailed assessment of its aqueous effluents by the end of 1992 and carry out pilot trials for improved effluent treatment, and to commission a new combined heat and power (CHP) plant. This has been done. However, a commitment to review emissions to atmosphere was not met and disappeared from the second action plan for 1993/94. Pfizer is continuing to study the issue, but Mr Gibbs says that it is proving difficult to develop sampling and analytical procedures for fugitive emissions.
Action on effluent
The most substantive point in the action plans - and the one amounting to the greatest advance beyond legislative requirements - is the commitment to finalise design and begin construction of a new effluent treatment plant. One of the site's main environmental impacts is the projected daily discharge of 3,500m3 of effluent to the river Stour. Currently, the 2,200m3 trade element receives only pH adjustment and settlement before discharge during the ebb tide. However, Mr Gibbs says that the site "is under no immediate pressure from the National Rivers Authority" to reduce its discharge levels, and is "miles below" its consent limits.
Nevertheless, Pfizer was put under the spotlight by Greenpeace's "No legal pollution" campaign in mid-1992 (ENDS Report 212, pp 7-8 ). The group claimed that Pfizer was the seventh biggest industrial discharger in south-east England, that it had breached its consent on four occasions since the start of 1991, and that it had detected ten chemicals in the discharge that were not covered by the consent. Mr Gibbs says that the firm's existing commitment to take action helped it to cope with the campaign: "If we'd not already been proactive, particularly over improving the treatment of our effluent, we'd have been seen to have been pushed into it".
Pfizer has spent some £0.5 million on a pilot effluent treatment plant, and a submission has been made for board approval of a £15-16 million activated sludge unit. Mr Gibbs accepts that progress has been slower than promised because of difficulties in process design, but argues that the firm's public commitment to take action under the EBF is likely to ensure that the project gets the all-clear.
The potential cost of the plant has already been reduced significantly by waste minimisation measures. Pfizer's initial commitment to develop a waste management plan for its effluent soon shifted towards a waste minimisation plan, as studies of individual effluent streams highlighted opportunities for savings. In one typical case, improvements to the processing of aromatic aldehydes allowed the discharge of ammonium salts to be cut by 18 tonnes per year.
But the most important savings have arisen from reductions in water consumption. An internal target to reduce water use by 30% within two years was met within 18 months despite rapid expansion of the site. This represented a direct saving of some £200,000 per year, and indirect savings arising from a reduction of 500m3 in the design capacity of the treatment plant. Most of these reductions were, says Mr Gibbs, "very simple things we could have done years ago". Pfizer is now working towards a target of halving its water consumption, based on 1990 levels, within the next two years.
However, while Pfizer operates towards internal numerical targets on issues such as water use reduction, its action plans and progress reports under the EBF contain little quantitative data. For example, the second action plan is dominated by worthwhile, but arguably peripheral, initiatives such as "support" for car-sharing schemes and local environmental projects with schools, landscaping, the publication of an environmental leaflet, and conversion of its small low-pressure boilers from oil to gas. The major boilers have already been switched to gas. The most important commitment - to install the effluent treatment plant - has not yet been met.
The CBI's guidance to EBF members requires that "targets should be numeric wherever possible", and "are more credible where dates are attached". However, most reports from the EBF membership have been qualitative in nature.
Mr Gibbs argues that Pfizer has seen quantitative targets as an internal management tool rather than as publicly stated objectives. "The Forum is about setting a culture," he says, "and while quantifiable targets are coming quite quickly they are not a natural part of the exercise." Initially, Pfizer "had a lot of broad-brush work to do to get things rolling". However, he expects future plans to include some quantified targets. One likely area is the 10,000 tonnes of mycelium waste produced annually by the fermentation process. The firm has already adopted an internal 15% reduction target over two years, and is looking at the potential of the waste as a peat alternative.
Targets may also emerge for solvent recycling. Pfizer has made some progress in this area, but is hindered by the complexities of drug registration. Because of the need to ensure product safety and quality, any alteration of the manufacturing process may require re-registration, and potentially full safety screening of the material prepared by the new route. Any recovered solvent must therefore be returned to the parent process. HM Inspectorate of Pollution (HMIP) has already run into similar difficulties in applying integrated pollution control (IPC) to the pharmaceuticals industry. Because many existing processes are effectively frozen by drug registration, HMIP has accepted that environmental improvements are likely to be based on end-of-pipe treatment.
However, with new processes, or the regular optimisation reviews of existing processes, there is considerably more scope to incorporate environmental factors. Some pharmaceutical companies such as Smith Kline & French (now Smith Kline Beecham) made early forays into waste minimisation by process selection (ENDS Report 134, pp 9-11). However, Mr Gibbs admits that until recently Pfizer tended to optimise processes "mainly on cost control and product quality...the environmental element wasn't explicit before". As part of its environmental policy, the company is now committed to assessing the environmental impact of any new activity, project or plant decommissioning. Mr Gibbs is keen to integrate environmental factors with the requirements of occupational hygiene, quality and health and safety.
All of these changes have coincided with the application of IPC to the site. Two of Pfizer's IPC authorisations cover its boiler and pilot plants, while a third "envelope" authorisation covers the multi-purpose chemical manufacturing plant. The site's incinerator and pharmaceutical coating plant fall under local authority control.
"When we meet the HMIP inspectors, I'm convinced that our action under the Forum is very beneficial because they feel more comfortable with you," says Mr Gibbs. "But it hasn't altered the rules they have to play by, and nor should it."
Winning staff involvement
Mr Gibbs is convinced that one of the main benefits of the EBF initiative has been to improve environmental awareness among staff. Pfizer has set up an Environment Committee, consisting of 16 staff from all levels and disciplines, "from a janitor to a senior chemist", which reports directly to the management executive, by-passing line managers. Besides its input on in-house issues such as water minimisation and paper and packaging recycling, the committee has supported numerous activities in local schools and the community.
Several task forces have been established to devolve responsibility for individual issues, such as the collection of emissions of volatile organic compounds from tanker filling or unloading. Besides the direct benefits, Mr Gibbs says that this has "involved large numbers of people without encouraging them to think of the environment as a burden".
The result, claims Pfizer, is that it is receiving increasing support from the local community, where it is by far the major employer. "At first, there is a hump to get over," says Mr Gibbs. "The first time you go out and make a statement, people wonder why."
"If I'm honest," Mr Gibbs told the EBF meeting, "when we first joined up it was more to fly the green flag." Since then, Pfizer has been surprised at the range of benefits flowing from its move. Perhaps the biggest surprise came last year when KPMG Peat Marwick, the firm's financial auditors, decided to carry out an environmental audit of the site. Mr Gibbs says that the audit went into the attitudes of the staff, the relationship with the local community, financial risks and the corporate strategy - and observes that "if we'd not been proactive it would have frightened the life out of us".
It may take similar frights to persuade more of British industry to follow Pfizer down the EBF route. In the meantime, the company is aiming to ensure that its internal environmental management systems will reach the BS7750 standard. However, it is holding back from seeking certification because, says Mr Gibbs, "we have more immediate environmental demands on our resources". Any move towards certification under the EC's Eco-management and audit scheme is further down the pipeline.
And while many of the Sandwich initiatives are a laudable first, Pfizer's existing public reports still have some way to go to meet the EC requirement for verified public statements containing quantified release data.