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Manufacturer overload? The heavy impact of legislation
Monday, 02 April 2007 00:00

Moira McMillan tells Finishing that legislation is going to have a heavy impact on British businesses.

Commenting on the extensive burden of forthcoming legislation impacting the UK coatings sector - and the “business unfriendly” way in which it is implemented, British Coatings Federation (BCF) CEO, Moira McMillan, told Finishing; “British coatings manufacturers are working flat out to understand, assimilate and put into action all the requirements of the legislation that is already in the process of being implemented.” 

“Some of this legislation directly affects end-users and consumers, who also need to be made aware of the changes that are in the pipeline, what they mean and how they will affect the products they purchase.”  

As one of its services to members, BCF prepares a Legislative Timetable, the current edition of which includes no less than 28 separate regulatory changes which are already planned to come into force between autumn 2006 and 2013.  These range from the Biocidal Products (Amendment) Regulations 2006, through the Chemicals (Information Packaging for Supply) (Amendment) Regulations 2007 (CHIP 3.2) to the Solvent Emissions Regulations PG6/44 Light coloured painting of tanks, and all this on top of REACH the new chemicals control Regulation.

As part of its activities on behalf of members, the BCF is involved as a member of the Chemicals Regulatory Forum (CRF) which is chaired by the DTI. BCF was a member of the Steering Group of the CRF’s high-level investigation into the cumulative impact of Safety Health and Environmental Regulation on the UK industrial Coatings, Aerosols and Speciality Chemicals Sectors.  Other organisations represented on the Steering Group included Defra, the Cabinet Office and two other trade associations, the British Aerosol Manufacturers’ Association (BAMA) and the British Association for Chemical Specialities (BACS).

The main tasks of the study were: firstly, to estimate the cost of compliance with current SHE regulations in excess of the minimum costs necessary to ensure current levels of protection, and, secondly, to gather suggestions for reductions in the cost of compliance, while maintaining levels of protection.

The study, created for the CRF, by consultants London Economics/RPA , to be published as part of the CRF Forward Work Programme, was launched on 20 November 2006 – and its findings are very much in-line with the experiences of BCF members at “the sharp end” in manufacturing.  Information was gathered through in-person interviews with representatives of 48 firms of different sizes, from companies across the sectors represented in the study.  

The investigations found that compliance costs across firms was roughly constant across firms of all sizes, and the weighted estimated total cost of compliance with SHE regulation for this sector is 1.2% of turnover, with the weighted excess cost being just under 0.4%, or approximately £87m per year.  

Based on the assumptions in the study, therefore, the £87m per year could be saved without negatively impacting the safety of workers or consumers or the environment, through improved design and method of implementing current regulations.  

Despite their reservations regarding some of the implementation of the SHE regulation, participants clearly perceived several significant benefits of SHE regulation, among them improved SHE performance and improved reputation with customers and the general public.  

However, they made several proposals for changes to regulation including the following which are being carried forward by industry, government and the regulators as part of the work of the CRF. This Forward Work Programme was officially launched by DTI Minister Lord Sainsbury, on November 20th at an event attended by BCF and a number of kindred associations

Streamlining of inspections, with regulators working with trade associations to improve consistency of approach.

Following the Hampton Report, to consider the consolidation of regulatory regimes and permits including the Environmental Permitting Programme

Input to the review of “placing on the market” and its definition across a wide range of  “new approach” directives

Development of a viable “Recognition Factor” by the regulators and identification of realistic rewards for good, responsible performance by companies and involving a closer correlation between the regulation and the risk

BCF has been specifically invited by the CRF to review a couple of current practices with a view to better government guidance and simplification

LAPPC process guidance notes on wood finishing and coatings and inks manufacture, and to recommend improvements.

To prepare proposals for removing the requirement for a waste treatment licence for compacting empty paint tins.

Some interviewees also felt that changes to the political process would be necessary to prevent what they saw as an “avalanche of regulation” causing significant problems for their firms and they urged legislators to consider carefully what new regulations would add to existing ones and also the impact of regulations further along the supply chain.

 
 

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