Enforcement suffers as HMIP helps industry with IPC

HM Inspectorate of Pollution (HMIP) came only just over half-way towards meeting its inspection targets last year. A continuing staff shortfall, coupled with the demands on inspectors' time created by efforts to make integrated pollution control (IPC) more "user-friendly" to industry, appear to be behind the failure.

According to MINIS 14, the latest of the Department of the Environment's annual manpower planning documents, HMIP's target for programmed inspections for 1992/93 was 5,900. This covered sites subject to IPC and to the old air pollution control regime (SI 318) which it is gradually replacing, nuclear power stations and other premises subject to the Radioactive Substances Act 1960 (RSA60), and sites discharging "red list" substances to sewer.

Data in MINIS show that only the inspection target for non-nuclear premises regulated under RSA60 was met in 1992/93. For the other control regimes the inspection rates achieved were only about half of the targets, and, in the case of red list dischargers, one-quarter of the target (see table ). Indeed, the total number of programmed inspections carried out was, at 3,515, barely above the total of 3,240 for 1991/92.

"Reactive" visits made in response to incidents or complaints amounted to 999 in 1992/93, slightly down on the total of 1,047 for the previous year.

The largest numbers of visits were devoted to helping firms with applications or pursuing issues raised by them. At 3,605, the number of application-related visits in 1992/93 was 76% up on the previous year's total of 2,040.

Much the highest proportion (73%) of application-related visits was devoted to IPC applications. HMIP received 476 IPC applications during 1992/93, while another 142 were carried forward from 1991/92. This suggests that 4.3 visits at the very minimum were made by inspectors in connection with each application - more than double the average of 2.0 visits anticipated when IPC was first implemented.

The question posed by these figures is whether the abandonment of the "arms' length" approach which characterised the initial phase of IPC, with companies being left to draw up applications without guidance from HMIP, and its replacement by closer working relationships between applicants and inspectors has been at the expense of policing and enforcement work. HMIP's targets for programmed inspections, it should be noted, are well below the inspection rates achieved until the mid-1980s by one of its predecessors, the Industrial Air Pollution Inspectorate.

MINIS 14 certainly suggests that HMIP is aware that it could do better. In his report, HMIP's Director, Dr David Slater, comments that "there is scope to devote considerably greater resources to field operations, especially proactive inspections, if those resources were available."

On the face of it HMIP should not have a serious resource problem. In January 1991, when it had a staff complement of 223, Environment Ministers authorised an expansion to 300-310 by April 1992. Its complement was subsequently raised to 377 for the latter part of 1992/93, and for the current year is 451.

However, recruitment appears to have fallen behind schedule. In February, HMIP was 43 staff short of its complement of 377. And it now has 368 staff, 83 short of its present allocation. It is not clear whether the persistent staff shortfall is connected with any disparity between the pay and conditions offered by HMIP and those available in the private sector.

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