Guidelines on Integrated Pollution Prevention and

Control (IPPC)
 Table of Contents

Acknowledgment

1. Introduction................................................................................................4

2. The Background.........................................................................................5

3. Integrated Approach...................................................................................6

4. Reversing the waste management hierarchy.............................................7

5. The Best Available Technique....................................................................9

6. Emission Limit Values...............................................................................10

7. Key Components of IPPC.........................................................................11

7.1 The permitting process........................................................................11

7.2 The Competent Authorities..................................................................14

7.3 Monitoring (Self-Monitoring), Enforcement and Control......................14

7.4 Public Access......................................................................................14

7.5 BAT Information Support.....................................................................15

8. Potential benefits and Constraints of IPPC...............................................15

a) Potential Benefits.................................................................................16

b) Constraints...........................................................................................16

2
Acknowledgement

The Environment Protection Authority would like to acknowledge the United

Nations Industrial Development Organization and the Royal Dutch Government
for their assistance under the Ecologically Sustainable Industrial Development
(ESID) Project US/ETH/99/068/Ethiopia in the preparation of these policy
Implementation tools and guidelines.

3
1. Introduction

Despite its complexity for pollution control purposes the environment must be
perceived as a single interrelated system. Many institutions are designed
primarily along media lines-air, water and land. Yet the sources of air, water and
land pollutions are inter-related and often interchangeable. The single media
based approach to environmental protection is unable to view the environment in
a holistic manner, but operates rather in a piece meal fashion, constrained by
competing environment related statues. Unless a more integrated approach is
followed, the single media programmes may well shift the pollution from one
media to another or fail to delineate the scope of the problem.

The evolution and development of the pollution prevention at source over the last
few years have led to the development of more proactive environmental
management strategies that has influenced industrial waste management
practices at the industry level. This has led to the development of the Integrated
Pollution Prevention and Control (IPPC). The IPPC approach is beneficial to
countries like Ethiopia for the following reasons;
 The savings to be made through the prevention of industrial waste
generation at the source makes a significant economic contribution to the
country’s development
 As an approach that promotes proactive engagement of industries in the
environmental management exercise, it reduces the financial and
institutional requirements for environmental enforcement.
 As a system based intervention, it promotes the enhancement of the
national industrial technology capacity.
Pollution control programme in Ethiopia is currently in its formation stage, and
thus is high time for the country to start practicing the IPPC approach for
industrial pollution management. The purpose of this guideline is, therefore, to
elaborate the basic principles and procedures that underlay the IPPC approach.

4
It is intended to be used by all competent authorities that will be involved in the
IPPC permitting system.
2. The Background

An integrated approach to industrial pollution prevention and control has

increasingly become the cornerstone of national and regional pollution and waste
management strategies. The reason is that it is recognized that no single part of
the environment is separate from any another, it functions as a whole. When
talking about integration and integrated control systems there are two main
strands to the concept of integration. The first, so-called substantive integration
requires integrated legislation concerning pollution control, design and selection
of technology and methods of production for use in the industry installation. The
second one, procedural integration, that requires integration or at least co-
ordination of procedures e.g. permitting of industries. These requirements have
implications for industry and also for the competent authorities.

Over the last few years, countries have increasingly shifted towards integrated
approach on environmental policy making and management. This is true in the
area of industrial environmental management too, even if it is given slightly
different names in different parts of the world. In some countries this approach is
known as the ‘Integrated Pollution Prevention and Control’ (IPPC) while in others
it is known as the ‘Integrated pollution and Waste Management’ (IPWM).

The adoption of an Integrated Pollution Prevention and Control strategy

constitutes the key component of sustainable industrial development strategy for
any country. The IPPC system will:

 Assist the government in attaining its sustainable development goals

 Ensure that quality, quantity and accessibility of industrial
environmental information are improved

5
  Facilitate strong partnerships between government, private sector,
labor, non-governmental organizations and communities
 Facilitate compliance with environmental laws and reduce the amount
of bureaucratic delays, and
 Build national capacity and public awareness.

3. Integrated Approach

A classic problem with a non-integrated pollution control - controlling emissions

into the air, water and soil separately - is that it may encourage the shifting of
pollution between the various environmental media rather than protecting the
environment as a whole. The idea is to avoid transfer of pollution to less
controlled or regulated sector, which is in some cases possible by technical
means. Another argument, which supports an integrated approach, is, for
example, the reduction of administrative costs, which the implementation of the
piece-meal approach will probably cause. A separate permitting procedure for
every possible emission from a large industry plant will lead to high cost, both for
the industry and the authorities involved into this process.

From the industry point of view, one can therefore, expect that the industrial
community would definitely welcome an integrated approach. This is also
demonstrated by the rising interest of industry itself. Industry has to address itself
only to one single integrated procedure. In this way, plant operators can take into
account not only the risk of transferring their pollution across environmental
media. But they can also employ an efficient calculation of the cost and benefit,
instead of having complicated and costly procedure to apply for three or more
permits before they can start up their activities.

In a nut-shell, when all possible emissions from an industrial plant are integrated
into one decision-making procedure, emission limit values (ELVs) are set by
competent authorities in such a way that (in a balanced manner) the industry
does not have incentives to shift its emissions from one medium to the other. The

6
advantages of procedural integration are reflected not only for permit authorities
and industries, but also for neighbors and other interested groups. Procedural co-
ordination will speed-up the permitting procedure as a whole and may make the
process more transparent for the public participation. Only one competent
authority needs to go into the matter in detail, which will save administrative
resources and prevents contradictory decisions.

The functional approach of the integrated system is conducted at three levels of

prevention, impact management and remediation. The source-based controls are
used to control the generation and discharge of waste. Controlling waste
discharge at source supports the management of the receiving environment. In
some instances, source-based controls can be extended to prevent waste
production altogether. In order to achieve sustainable development, the historical
focus on pollution impact management and remediation should shift to a
management approach, combining pollution and waste prevention and
minimization at source, impact management and, as a last resort, remediation.

4. Reversing the waste management hierarchy

The priority attention given to specific waste management interventions

constitute the basis for the waste management hierarchy. Accordingly, the
conventional waste management hierarchy that has been dominant since the
1970’s gives more focus to the so-called end-of-pipe management practices of
treatment and disposal.

Table 3.1: The Waste Management Hierarchy

The conventional hierarchy The evolving hierarchy

Disposal Prevention
Treatment Reuse
Recycle Recycle
Reuse Treatment

7
 Prevention Disposal

The IPPC approach requires the reversal of this conventional waste

management hierarchy by putting more emphasis on proactive environmental
management practices that includes pollution prevention and recycling/reuse.
The reversal of the waste management hierarchy is mainly driven by the
possibilities that were created by the development of the pollution prevention
(cleaner production) practices over the last decade. The pollution prevention
approach is about the reduction of waste generation at the source through the
combined application of engineering, economics and organizational principles.
As such, it:
 Related to innovation in product design and production
 Encourages cost savings through efficiencies and conservation
 Insists on sound management of persistent, bio-accumulative and toxic
substances and on eliminating their use where necessary.

The shift to pollution prevention leads to a number of socio-economic and socio-

ecological benefits. It specifically helps:

 Minimize and/or avoid the creation of pollutants and waste

 Minimize and/or avoid the transfer of pollutants from one medium to

another

 Accelerate the reduction and/or elimination of pollutants

 Minimize health risks and impact

 Promote the development of pollution prevention technologies

8
  Use energy, materials and resource more efficiently

 Minimize the need for costly enforcement

 Limit future liability with greater certainty

 Limit costly clean-up practices.

5. The Best Available Technique

Best Available Techniques (BAT) is a new concept that has evolved in the
context of IPPC, replacing Best Available Technology. It forms the basis for
setting emission limit values. Under IPPC approach, BAT application is a major
tool for actually protecting the environment as a whole and, therefore, BAT is
becoming another key provision and demanding requirement for a number of
countries in terms of definition, standard setting, enforcement and
implementation of IPPC programs.

Best Available Techniques can be defined as the most effective and advanced
stage in the development of activities and their methods of operation, which
indicate the practical suitability of particular techniques for a given operational
context. BAT in principle provides the basis for emission limit values designed to
prevent and, where that is not practicable, generally to reduce emissions and the
impact on the environment as a whole. BAT is essentially a combination of the
following three concepts: techniques, available and best.

 ‘Techniques’ shall include both the technology used and the way in
which the installation is designed, built, maintained, operated and
decommissioned.

9
  ‘Available’ techniques shall mean those developed on a scale, which
allows implementation in the relevant industrial sector under
economically and technically viable conditions. This takes into
consideration the costs and advantages, whether or not the techniques
are used or produced inside the country in question and if they are
reasonably accessible to the operator,

 ‘Best’ shall mean ‘most-effective’ in terms of achieving a higher

resource efficiency and higher level of protection of the environment as
a whole.

It is important to distinguish the traditional view of BAT as in the ‘Best Available

Technology’ and BAT under IPPC approach that is about the ‘Best Available
Technique’. The traditional view of BAT is about setting a uniform standard
applicable to all facilities carrying out similar industrial processes. In this context,
the definition of BAT under the IPPC approach is closer to the concept of the
‘Best Available Technology Not entailing Excessive Costs (BATNEEC)’ that has
already been adopted in a number of developed countries. Specifically, the “not
entailing excessive cost” refers to the economic marginal cost/benefit test.
According to the BAT definition under IPPC, one can find a clear reference to the
fact that costs and benefits should be taken into account when the “availability” of
the technique has to be considered. So the goal, which is important to know also
for countries with limited resources, is not to put existing plants out of business,
but to achieve improvements at a reasonable cost for particular facility.

6. Emission Limit Values

The IPPC approach introduces a new system of environmental standard setting

called ‘Emission Limit Values” (ELV). ELV or the maximum limit of allowed
emissions, are fixed according to BAT, but it is the matter of industry to decide
how to meet those requirements. In setting ELVs, the characteristics of the

10
plants, its geographical location and the local environment have to be taken into
account. The ELVs are the result of partly a BAT assessment and partly an
assessment of the local conditions. The emission limit values or environmental
quality of the air, water and land, which receives the emission, must be set on the
reference of the environmental quality standards (EQS). Where the
environmental quality requirements are more stringent than those achieved by
the use of BAT, additional requirements must be made.

The IPPC approach does not prescribe the type of technology or any technique
the operator has to use. The operator may use whatever techniques and other
technology he likes, as long as industry can meet the prescribed emission limit
conditions and values. Under the IPPC, the role of the competent authority is not
to prescribe the technology and other techniques to be used in the operation of
an installation. The choice of what is best is left to the individual operator, thereby
keeping operating flexibility with the industrialist. It has been argued that forcing
the operator to use certain production methods may have the disadvantage that
there is no incentive for innovation in industries.

During the implementation of the IPPC and identification of BAT to industry,

emphasis is placed on the introduction of Cleaner Production (CP) applications -
pollution prevention techniques, including cleaner technologies and waste
minimization. This is in preference to more traditional ‘end-of-pipe’ solutions,
which may ameliorate an emission to one medium at the expense of creating
pollution in another medium.

7. Key components of IPPC

7.1 The permitting process

The IPPC approach prescribes permitting as the obligatory instrument to control

emissions from industrial installations. When an installation first comes under

11
IPPC it must obtain a permit to operate. The permitting process under the IPPC
approach is based on specifying certain conditions that need to be fulfilled.

These include:

 Emission Limit Values (ELVs) for certain substances with significant

pollution impact;

 Details of impacts management on air, water, land, noise, energy,

vibration, etc.;

 Use of resources (water, energy, raw materials, chemicals);

 Protection of soil and groundwater and the management of waste (if

needed);
 Prevention of accidents;

 Operation of treatment facilities (maintenance, control, calibration);

 Identify conditions to minimize long distance and transboundary

pollution;

 Self-monitoring and reporting (calculations and measurements).

The permit will be issued based on:

 Assessment of application/technology;

 Comparison with the sector BAT;

12
  Evaluation of local conditions;

 Discussion of adjustments/improvements;

 Agreement on an action plan to reach BAT.

The permitting process should be carried out in close co-operation and

negotiations between industry representatives and competent authorities. This
process (applications of permits) must be available also to the public to enable it
to comment on them before the competent authority makes its decision. The
basic obligations of plant operators are based on the following general principles:

 All appropriate preventive measures shall be taken against pollution, in

particular through application of the BAT;

 No significant pollution is caused;

 To avoid waste generation and recover or safely dispose of the waste

produced;

 Energy is used efficiently;

 The necessary measures are taken to prevent accidents;

 To protect and clean up the site of the industrial activity.

The operator must monitor emissions and inform the authorities as part of
fulfilling its responsibility for self-monitoring. Operators also must inform the
competent authorities of any change in operation.

13
7.2 Competent Authorities

The competent authorities may issue a permit/license only when they are
satisfied that the designer/operator has taken a holistic approach to
environmental protection. They have to ensure that all appropriate measures are
taken against the polluting activities from industry installations, in particular
through applying BAT. At the same time the government must ensure that the
competent authorities are kept informed about the development of the BAT. Only
if authorities are kept abreast of the BAT development they can ensure a
continuous improvement of the level of environmental protection.

7.3 Monitoring (Self-Monitoring), Enforcement and Control

There is an important relationship between integrated emission permitting,

monitoring, and enforcement. The permit conditions are determined by the
environmental quality. Monitoring conditions are related to the emission limits set
in the permits. The monitoring of emissions provides information on how the local
environment is affected by the industry activity. It also provides information for
the enforcement authorities to check industry compliance with permit conditions.

According to the IPPC approach, the monitoring and control are carried out
among other things by way of the operator’s duty of introducing self-monitoring.
This includes disclosure of the results out of his own volition that ensures a
continuously updated knowledge of the environmental load; resources used and
of accidents resulted by its activities. Moreover, the operator is obliged to assist
in the monitoring, supervision and inspections (done by competent authority) of

14
the installation, to take samples and to gather any information necessary for the
performance of their duties.

7.4 Public Access

As already mentioned above, the competent authority should ensure that

applications for IPPC permits are made available for public review and comment
before a decision is done. The decision, the permit, and the results of any
monitoring of emissions also must be made available for public access. In some
cases, these materials may be with held from the public grounds on commercial
confidentiality or some other reasons. This has to be decided by the competent
authority upon the request of the operator or any other party.

7.5 BAT Information Support

Due to several aspects (ecological, technical, managerial, etc.), which are

incorporated into the definition of BAT and which must therefore be considered
when determining this concept, it is important to develop a common
understanding of the term BAT under a given operational context. In this context,
the competent authority needs to organize an exchange of information between
industries concerned on best available techniques, associated monitoring, and
developments of them.

The information exchange is a central issue in implementing IPPC. This is

supposed to help industries by giving the concept of BAT a more practicable
content through concrete requirements for defined industry sectors, installations
and process types.

8. Potential benefits and constraints of IPPC

15
There are a number of potential benefits and constraints that are associated with
the adoption and implementation of the IPPC approach as the core element of
national environmental management strategies, of which the following are the
major ones.

a) Potential benefits

 Cost-benefit

Integrated assessment of risks and impacts of activities helps operators to

identify the most important problems caused by their activities and to
allocate their environmental budget in the best possible way. Integrated
decision-making makes operators and also authorities think about
implementation options and co-ordination of actions. Common
enforcement and validity - leaves possibility for permits to last longer and
the improvement plans to be negotiating.

 Cleaner Production

Low-cost CP measures such as ‘good housekeeping’ and waste

minimization options with a short payback period provide a cost-effective
way of dealing with BAT-based regulations (IPPC) provide a strong
economic dimension for the IPPC approach.

 An integrated environmental management perspective

EMS can help the industry to consider the environmental impacts of its
actions in a more systematic way, firstly in order to meet requirements of
the permit application procedure (self-monitoring), and secondly also with
regard to future strategic options.

b) Constraints

16
 Shortage of knowledge and resources

There is little knowledge about the IPPC and its opportunities. Ethiopian
industries will need to mobilize their limited resources for investments to
comply with the IPPC, while at the same time they might be struggling to
survive in a competitive market.

 Lack of co-operation and supervision

The co-operation between different permitting and enforcement authorities

as well as between authorities and enterprises is minimal.

 Lack of understanding the BAT

The meaning of BAT as well as understanding of the CP concept is largely

non-existent.

 Poor self-monitoring and environmental management

performance

 Companies are not ready to collect, measure, analyze and

report environmental data required by the IPPC.

 Industry's Environmental behavior is reactive and most of the

companies do not have any environmental management in
place.

 Increased bureaucracy and an inappropriate balance between

effectiveness and simplicity increase the workload for
companies.

17
18