Response 415400546

Back to Response listing

About You

Are you responding as an individual or an organisation?

Please select one item
(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Syngenta Limited

Part 2: Policy Overview

1. Do you agree with the benefits set out here?

Please select one item
Ticked Yes
No

2. Are there any other comments you would like to make on Part 2?

Are there any other comments you would like to make on Part 2?§
Syngenta has contributed to the consultation response by the Chemical Industries Association (CIA) on behalf of the chemical industry, so this individual company response is not intended to repeat all of the comments made by CIA - only a few specific questions will be responded to by Syngenta.

Part 3: Key features of the new framework for authorisation holders.

13. Do you agree that all regulated activities should have an authorised person responsible for overall compliance and that this person should be named in a permit and registration?

If not why not?
Not quite sure how you decide who the authorised person should be for large corporate bodies, or for sites where those potentially in control are not located at the site (or even in Scotland).

14. Do you think it is proportionate to require the person in control to be the person that notifies an activity in the notification tier?

Please select one item
Yes
Ticked No
Comments:
See above - potential person in control in a large company is very unlikely to be same one as is responsible for tasks such as activity notification.

15. Do you agree that SEPA should include more than one person as the authorised person where appropriate?

Comments:
How far would this be extended - to the whole of a company board? to the HSE team?

17. Question 17 – Do you think the core requirements set out here will deliver the right approach to FPP for the integrated authorisation framework?

Please select one item
Yes
Ticked No
Comments:
We are not clear how a FPP test(s) could be devised which would be appropriate for all PPC activities - for a single sector such as waste, this is doable, but for even e.g. the chemical sector; this covers a wide range of size, scope and type of activities for which a 'reasonable' expectation of knowledge and competency for an FPP may be very different. At large sites the knowledge and competency to safely and successfully manage the site is spread through a large number of people - the only way to assess this would be through something like the current COMAH competency management system inspections.

18. Do you think that the criteria set out above will achieve the stated purpose of the FPP test?

Please select one item
Yes
Ticked No

Part 5: Pollution Prevention and Control

37. Do you consider that the provisions of the universal outcomes contain equivalent protection as BAT in relation to domestic activities?

Please select one item
Yes
Ticked No
If not, why not?
Not clear how the UOs might work/ look in practice to know if they would be equivalent to BAT. Also since BAT = 'best' (i.e. well beyond minimum standard), and is a fundamental compliance requirement of PPC, then for PPC sites, BAT is as good as they can do, so 'beyond compliance' is not possible.