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Background Info


Animal rendering in the UK operates in a highly competitive market but seemingly subtle differences in environmental regulation between England and Scotland puts Scottish renderers at a competitive disadvantage.


The differences arise due to the way environmental regulators in England and Scotland apply the legislation. Whilst all rendering plants are regulated under the Pollution Prevention and Control (PPC) regime1, a traditional rendering plant, such as the two plants in Scotland will be regulated by SEPA while the same plant operating in England would be regulated by a local authority.

All plants are required to apply Best Available Techniques (BAT) in their operations but the approach used by the local authorities to determine BAT is different, and in Scottish renderer’s opinion, less onerous than the approach used by SEPA.

The Local Authority regime determines permits on the basis of guidance in:

• Sector Guidance Note IPPC SG8 Secretary of State’s Guidance on the A2 Rendering Sector (December 2008);

• Reference Document on Best Available Techniques in the Slaughterhouses and Animal By-products Industries, European Commission Seville (December 2008).

In the Scottish renderers’ experience, SEPA acknowledges these guidance documents but determines permits using a risk-based approach that does not apply simply the criteria in the documents used in England.

I have been working with Dundas Ltd on this issue and they have supplied me with in depth comparators, some of which are enclosed below, with further information available on request.


The following are highlights of the preliminary comparisons of costs assuming an installation operating one boiler and one oxidiser. If additional combustion plant is operated, the difference in monitoring costs will be higher, possibly significantly higher depending on circumstances.

For the purposes of illustrating the impacts of both one-off and annual costs, an arbitrary ten year period has been chosen.

•  Fees: Over a ten year period, a rendering plant in Scotland might expect to spend £83,700 more on fees than the same plant in England. If variations are sought then this figure rises significantly. For a relatively conservative scenario, Dundas Ltd have estimated total fee differences up to £129,470 over ten years.

•  Periodic Monitoring: On an annual basis, a rendering plant in Scotland might expect to spend £1,750 a year more on periodic monitoring (£17,500 more over ten years) than in England.

•  Continuous Monitoring: A rendering plant in Scotland should expect to pay at least £60,000 for the installation of continuous monitoring equipment with a further £9,000 of on-going annual costs. Over a ten year period the total is approximately £150,000 more than for a plant in England where continuous monitoring is generally not required.

•  Other Monitoring/Reporting: A rendering plant in Scotland should expect to pay between £0 and £5,500 a year more than a similar plant in England, depending on the local authority. Over ten years this amounts to a difference of £0 to £55,000.


I hope that the above information highlights the extent to which Scottish renderers are disadvantaged within the present regulations set by SEPA.

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