Integrierte Vermeidung und Verminderung der Umweltverschmutzung

7 CONCLUDING REMARKS
7.1 Timing of the work
Chapter 7
The work on this document started with the first plenary meeting of the TWG in January 2001.
The main issues discussed at this meeting were the scope of this document; the key
environmental issues; how to approach the work in such a diverse sector and the identification
of information required. A deadline was agreed for providing the information, i.e. in time to be
included in the first draft.
The discussion about the scope led to the definition of the upstream and downstream
boundaries, based on the activities listed in the Directive and the issues within the scope of other
BREFs in the series. The inclusion or exclusion of sectors in this document does not, however,
infer any interpretation of the Directive. For example, the discussions revealed that in some MS
languages the term “food” includes animal feed and in others it does not. After some discussion,
a decision was made to include the processing of animal feed in this document. Further
discussions with the “Slaughterhouses and animal by-products” TWG, led to the production of
petfood of animal origin being included in the scope of this document. The documents do not
seek to interpret the Directive, so issues related to production capacities and decisions about
where permits are required are not covered.
A first draft was issued to the TWG, for consultation, in April 2002. The consultation period
lasted approximately 8 weeks. A second draft, including the proposed BAT conclusions, was
sent to the TWG in May 2003. The consultation period lasted until August 2003. In September
2003, the original author left the EIPPCB and in November 2003, a new author took over the
work on this document.
During 2004, the work concentrated on taking account of the comments on the second draft;
developing the presentation of the information to the reader and consolidating the BAT
conclusions, ensuring that they were cross-referenced to the supporting information in this
document.
The final plenary meeting of the TWG was held in February 2005. The meeting concentrated on
discussing the BAT conclusions and the information supporting them in this document.
After the final meeting, the BAT chapter was modified to show the changes agreed at the
meeting. The “Concluding remarks” and the “Executive summary” chapters were then drafted,
followed by short consultations, after which the final redrafting took place.
The wide diversity of the FDM sector has presented a special challenge to the TWG. A huge
variety of raw materials are processed. Many similar products are processed in different ways,
sometimes following regional recipes and many dissimilar products are processed in similar
ways. The wide scope of the sector; the ongoing provision of information late in the process and
the change of author all influenced the content and the preparation time of this document.
7.2 Level of consensus, driving forces and issues arising from
the final TWG meeting
The conclusions of the work were agreed at the final plenary meeting, with a high level of
consensus being achieved. Most of the BAT are concerned with the management and operation
of FDM processing. The application of most of the BAT, therefore, requires little or no
investment in equipment. These “in-process BAT” can generally deliver cost savings because of
improved efficiencies and reduced waste production. The emphasis on the prevention of
pollution by the application of “in-process” BAT may result in minimising the amount of
investment required to apply “end-of-pipe” BAT, by, e.g. reducing the scale to which it is
required. For example, minimising the quantity of water used and reducing its contamination
with food particles and detergents, by carrying out dry cleaning, can reduce the requirement for
waste water treatment compared to hosing food from equipment and floors into drains.
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