The gas industry has fewer obvious environmental problems to solve than some parts of the chemical industry but all types of business have some effect on the environment through the natural resources it consumes to make and distribute the products it sells.
Within BCGA, TSC8 is the Technical Sub-Committee that covers this topic. For BCGA members, information on the work of TSC8, including the minutes of the latest meetings, can be viewed within the members' area under 'Meetings'. Members interested in joining TSC8 are entitled to do so and should make contact with the BCGA office.
The national environment Regulators publish their own environmental guidance.
Significant environmental topics under TSC8's view are:-
Climate Change and Carbon Management
Climate Change Levy (CCL)
The UK Climate Change Levy (CCL) is a tax on industrial electricity, gas and oil usage.
BCGA has a Climate Change Agreement (CCA) under the CCL in place since 2005, covering operators of Air Separation Units (ASU's) in the UK.
CCA's are applicable to industry sectors recognised to be 'Energy Intensive' by the Department for Business, Energy and Industrial Strategy (BEIS) that may, by 'negotiated agreement' gain partial relief from the CCL in return for progressively improving their energy efficiency in accordance with closely defined targets.
CCA's are extremely complex and further detail can be found on the BEIS website.
Streamlined Energy and Carbon Reporting (SECR)
Streamlined Energy and Carbon Reporting (SECR) is a new requirement from 2019 under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. This replaces, but is not the same as, the carbon reduction commitment reporting.
This impacts large (large = 2 of: Balance sheet >£18 m, Turnover >£36 m, Employees >250) unquoted companies & Limited Liability Partnerships (LLP) >40 MWh energy use from financial years starting after 1 April 2019 and so the first time a report is due under SECR will be after April 2020. This information needs to be included in the Directors Report and the report may cover a group of companies. Processes are already in place for checking Company Reports via Company's House.
What must you report?
- UK total energy use (at least electricity, gas and transport)
- Scope 1 (fuel used) and 2 (energy bought) emissions including stating methodology
- Greenhouse gas (GHG) intensity (e.g. tCO2/£ turnover)
- Commentary on energy efficiency actions taken. This should be: ‘meaningful, informative and consistent with the size of the business' but if commercially sensitive this can be withheld (but must be explained). There will be no requirement to report specifically on actions identified via the ESOS audit process, but this can be used as the basis of the narrative if the company qualified for and complied with ESOS.
- After the first year the previous year's data must be included
Carbon Footprinting and Carbon Neutrality
An increasingly common practice is to assess and state the carbon consumption of businesses and of individual products. For a general guide to Carbon Footprinting refer to the Department for Environment, Food and Retail Affairs (DEFRA) website.
EU Emissions Trading Scheme (EU ETS)
From the 1 January 2013 hydrogen and carbon monoxide plants producing >25 tonnes/day of hydrogen production come under the EU ETS, more information is available from EIGA.
Industrial Pollution Control - Environmental Permitting Regulations (EPR) and Integrated Emissions Directive (IED)
There are several gas industry processes which are covered by specific environmental permits; these are hydrogen and carbon monoxide production, acetylene, nitrous oxide or electronics gases production.
Air separation units and air gas filling plants, including mixtures, are not subject to the EPR permitting regime. Air separation units do often operate on sites regulated by the Environment Agency under EPR. The BCGA has worked with the Environment Agency to establish that no separate permit is needed for the gas company operation, provided that certain conditions are met. Refer to BCGA GN 21, Environmental Guidelines for Air Separation Plant and Equipment on sites regulated under IPPC.
EIGA has produced Technical Bulletin 01/12, Impact of the Industrial Emissions Directive, to provide information to EIGA member companies on the applicability of the Industrial Emissions Directive (IED) to industrial gases processes and on the changes introduced in the IED.
Gas Cylinders in the Waste Stream
Gas cylinders and other transportable pressure vessels are fully reusable, recyclable and can have a long life time. However gas cylinders do turn up at waste transfer and disposal sites and BCGA has produced guidance to manage the associated risks, refer to BCGA L 2, The safe handling of gas cylinders at waste facilities. Additional information on managing the recovery of cylinders from waste sites or the disposal of cylinders can be found on the Cylinder Recovery & Disposal webpage.
Packaging Producer Responsibility Regulations
Gas suppliers have obligations under the Packaging Producer Responsibility Regulations. The Packaging (Essential Requirements) (Amendment) Regulations 2013 included for the first time, amongst others, 'Refillable steel cylinders used for various kinds of gas, excluding fire extinguishers'. Refer also to the Environment Agency information note. BCGA GN 28, Packaging waste within the industrial gases industry, provides further advice.
Fluorinated Gases (F Gas) and Ozone Depleting Substances (ODS)
Supply and use of F gas and ODS are regulated by EU and UK regulations. The F Gases Regulation was revised and subsequently published (517/2014) in the Official Journal of the European Union in May 2014. This Regulation has applied since 1 January 2015.
From 1 January 2015 the use of all HCFC's as refrigerants for service and maintenance has been prohibited. A number of fluorinated products including refrigerants with a high global warning potential (GWP) are being phased out. From 1 January 2020 no more virgin product above 2500 GWP will be supplied but note that the Regulations are complex and require review by competent persons.
There are a range of replacement refrigerants being supplied. These may have different properties to the existing refrigerant, for example, some are flammable. The changeover from one product to another will require a thorough design review to ensure continued safety and reliable operation.
There are specialist recovery cylinders available from gas suppliers for the return of waste F gases and ODS gases, refer to BCGA TIS 41, Cylinders provided for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia.
Advice and guidance on the F Gas Regulatory framework can be found on the DEFRA website. Comprehensive guidance on the F-Gas regulation has been provided on behalf of DEFRA by Gluckman Consulting. Additional information is published by EIGA - Document 192, Fluorinated gases management.
Energy Savings Opportunity Scheme
The UK Government has established the Energy Savings Opportunity Scheme (ESOS) to implement Article 8 (4-6) of the EU Energy Efficiency Directive (2012/27/EU). The scheme is implemented In the UK by the ESOS Regulations 2014. ESOS is an energy assessment scheme that is mandatory for organisations in the UK that meet the qualification criteria. The Environment Agency is the UK scheme administrator.
Organisations that qualify for ESOS must carry out ESOS assessments every 4 years. These assessments are audits of the energy used by their buildings, industrial processes and transport to identify cost-effective energy saving measures. Organisations must then notify the Environment Agency by a set deadline that they have complied with their ESOS obligations.
The most recent qualification date - the date on which organisations must determine whether they qualify for the scheme in that phase - is the 31st December 2022. By the 5th December 2023, you must notify the Environment Agency (as the scheme administrator) that you have complied with the scheme.
BCGA has prepared a Briefing Note to provide further guidance.
EIGA provide additional information on energy efficiency in their Technical Bulletin 15, Energy Efficiency: compliance with legal requirements and best practices.
Energy Performance of Buildings Directive (EPBD)
The Energy Performance of Buildings Directive makes it a legal requirement that an accredited inspector undertakes a mandatory Energy Efficiency Inspection, at least once every 5 years, on any air conditioning system over 12 kW total capacity.
These inspections are designed to ensure the system is suitable for the intended purpose and is operating correctly and efficiently. The regulations are enforced by Trading Standards and carry fines for non-compliance.
It is not mandatory to act on the recommendations of the Air Conditioning Energy Efficiency Inspection, however the findings often highlight energy saving opportunities which easily outweigh the cost of the inspection and remedial works.
There is a government managed register for TM44 non-domestic accredited energy assessors.
BCGA responds to many Government consultations, many on environmental matters. If you would like to contribute to any current consultations contact the BCGA Office.
BCGA publish several publications providing advice on environment matters. All BCGA publications are accessible via the 'publications' page. The following are of interest.
- BCGA GN 21 - Environmental Guidelines for Air Separation Plant and Equipment on sites regulated under IPPC.
- BCGA GN 28 - Packaging waste within the industrial gases industry, provides further advice.
- BCGA L2 - The safe handling of gas cylinders at waste facilities.
- BCGA TIS 41 - Cylinders provided for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia.
- The Confederation of British Industry (CBI)
- European Industrial Gases Association (EIGA)
- The Environment Agency (EA)
- Scottish Environment Protection Agency (SEPA)
- Natural Resources Wales (NRW)
- Northern Ireland Environment Agency (NIEA)
- The Department for Environment, Food and Rural Affairs (DEFRA)
- The Health and Safety Executive (HSE)
- Department for Business, Energy & Industrial Strategy (BEIS)
- Ireland Environment Protection Agency (EPA)