Comment from Mark Eggleston, MD of WJ Group.
“Having now gone through the lengthy process of applying for an IED (Industrial Emissions Directive) permit in readiness for the July deadline, my experience leads me to believe that the UK have got this totally wrong, to the detriment of diligent timber treatment companies such as WJ Group.
A meeting with the Medway and East Riding of Yorkshire Council to initially discuss the application identified some stark facts about how Europe appeared to be handling the implementation of this new EU Directive. Countries such as Germany and France confirmed at an EU meeting that only a small handful of timber companies fell into the eligibility criteria of being able to produce 75 cubic metres in a 24 hour period and so the EU commissioner felt that it would be a waste of time and resource to draft a specific BREF (Best Available Techniques Reference Document) for water based timber treatment in their countries. Instead, the process is to be included in SG6 – Surface Treatment using Solvents. One could rightly assume that the resulting BREF would have little relevance to the vacuum pressure process for preservative and fire retardant treatment of timber.
In the same EU meeting, the UK proudly announced that it had hundreds of eligible timber companies from its calculations and so the complex work continued and produced the IED application process as we now know it, costing WJ Group so far £6,436 with a further £4,000 still to come. In contrast, mainland Europe has not incurred this expense at all.
My point is this. Given that we already have the well-established WPA Code of Practice for the Safe Design and Operation of Timber Treatment Installations 2003, does the UK actually need to create a separate process to implement the IED at all? Could it not just take on board the points within the Directive and confirm that they are being covered by existing regulations as other European countries have done? The WPA Code of Practice is clear, succinct and easy to understand whilst most importantly, already in existence. The Code does a good job and would put the UK on a level playing field with mainland Europe in terms of additional costs if UK regulators simply adopted this guidance when issuing an IED permit for timber treatment operators.
Wouldn’t it be fantastic if our UK regulators looked at the impact on business first, before blindly ploughing on and implementing regulation that mainland Europe does not have? My only consolation in all of this is that my timber treatment sites are located in Hull and Rochester – not Scotland, where I understand the application process to be far more complex and costly!”