Polartech® & the Environment

Environmental Statement 2005

Issue Date: February 2006

About The Company

We specialise in the supply of products, additives and technical expertise to lubricant and marketing companies world-wide. An important aspect of Polartech’s operation in that we supply products and services only to other lubricant and marketing companies. Our policy is not to compete directly with our customers, and therefore we do not supply products to end-users and there is no Polartech brand for end-users.

In the UK the Company occupies a single site of just over 4 acres at Trafford Park, Greater Manchester, and employs approximately 50 people. The Company has a total stock capability of around 2,500 tonnes which comprises approximately 30% bulk storage facilities. Our 2,100 or so individual product lines consist of over 600 formulations, and we handle around 300 different raw materials. Level of production in 2005 was nearly 11,000 tonnes.

In addition to its UK manufacturing facility, Polartech is able to offer the flexibility of manufacture in India, and construction of new production facilities in China and USA are planned for 2006. In addition, Polartech has distribution companies in North America and Asia Pacific, and in other markets Polartech’s products are handled by specialised distributors selected for their technical expertise. In calendar year 2005, over 60% of the UK’s production volume was exported.

The Company operates a quality assurance system registered to ISO 9001 by Bureau Veritas Quality International. For over 8 years, we have also operated an environmental management system based on the requirements of ISO 14001.

Our UK manufacturing facility operates under a IPPC (Integrated Pollution Prevention and Control) Permit which means, amongst other things, that we are subject to monitoring and inspection by the regulator, and that we are required to employ ‘best available techniques’ to achieve a high level of protection of the environment. Like ISO 14001, IPPC means we need to have good environmental management procedures. But IPPC goes further in that it requires compliance monitoring, not only in respect of compliance in implementing the procedures, but also compliance in meeting specific environmental performance standards and in regulatory compliance.

Environmental Issues

Emissions to Atmosphere	As already mentioned, we operate under an IPPC Permit which requires us to use best available techniques to minimise emissions and keep them below regulatory levels or any other levels that may be prescribed in the Permit. We are required to report annual emissions data to the regulator. There have been no transgressions of our Permit conditions, and we have never received a complaint or infringement notification from any authority with regard to discharge of emissions to atmosphere.
Effluent Discharges	The Company does not discharge trade effluent to storm drains or to foul sewer, and does not have a consent to discharge trade effluent to these. We have no drainage outlets that connect into the storm water system which connects to the canals which pass through Trafford Park. Storm water from yards and buildings, and domestic waste, is discharged from the site into foul sewer. We have never received a complaint or infringement notification from any authority with regard to discharge of liquid effluent from the site. Contaminated liquid waste generated within our manufacturing facility and tank farms is contained and collected into a bulk holding tank for removal from site for treatment by a licensed waste contractor. All our storage facilities are fully bunded if outdoors or contained within buildings.
Waste Management	In accordance with latest UK regulations, the site is registered as a producer of ‘hazardous waste’. All waste is disposed of in accordance with current regulations. We check that all waste disposal contractors used by us are properly registered and licensed.
Solid Wastes	All solid waste is collected into segregated skips and removed by licensed contractors. Some solid waste (for example, contaminated empty raw material bags) is classified as hazardous waste. Empty drums are collected for potential recycling by a drum reconditoner. In 2005, approximately 85% of our used metal and plastic drums were suitable for reconditioning and re-use.
Chemical and Liquid Wastes	Chemical and liquid wastes generated on site are collected into a bulk holding tank. Procedures are in place to contain and deal with accidental spillages. The liquid waste is removed from site by a licensed waste contractor for off-site treatment.
Noise and Odour	The environmental effect of our activities with respect to noise relates only to our transport requirements. As the neighbours in the immediate vicinity of our site are other industrial facilities, any transport noise does not cause any nuisance effect. Any environmental aspects of our activities with respect to odour will relate to our local exhaust ventilation requirements. This issue is covered by our IPPC Permit which regulates emissions to atmosphere; the requirements of COSHH Regulations are also relevant. We have never received a complaint or infringement notification from any authority with regard to noise or odour emissions from our site.
Contaminated Land	Polartech has owned and occupied the site since 1991. Prior to this, the site had a long history of use as an industrial unit during which the possibility of some land contamination could have occurred. During and since Polartech’s purchase of the site, a series of investigative studies has been carried out and a number of measures have been implemented to prevent further contamination, and to re-mediate and redevelop the main areas which have been identified as being subject to contamination. Our IPPC Permit application also required a detailed geological assessment to be made of the condition of the site at the time of application. These studies have identified that any contamination appears to be localised, limited to surface layers, and there is no evidence that this has affected any areas beyond the site boundaries. The Company is committed to identify and carry out any necessary land re-mediation measures as part of any future site development projects.
Use of Resources	The Company is a relatively small – moderate user of electricity and natural gas. Energy usage is monitored and any period of high consumption can be reviewed and initiatives taken. During its occupancy of the site, the Company achieved considerable success in decreasing gas usage in relation to quantity of material produced during the 1990’s, decreasing consumption by approximately 50% during this period through the use of more energy efficient equipment. With energy efficient processes in place, any foreseeable additional improvement in this area in the future is likely to be modest. Mains Water is used mainly for production of steam, as a component in many of our products, and for washing and flushing process equipment. Water consumption is therefore likely to rise as production increases. Water usage is monitored to identify potential areas for water management techniques. A variety of chemical raw materials are used in the manufacture of our products, and a number of these are either derived from, or contain components derived from, petroleum. None of these are known ozone-depleting materials or are significant in terms of limited global resources.
Incidents and Emergencies	Various abnormal or emergency scenarios have been assessed in the event of which potential release of materials into the environment may occur. These include possible releases in the event of fire, vandalism, major spillage, and explosion. Although these eventualities have not identified a situation that would produce a major environment impact, procedures are in place to deal with any incidents or emergencies that may arise, and to minimise and control the release of materials in the event of such a situation occurring. We have had no environmental incidents or emergencies in 2005 that required notification to, or the involvement of, any external authority or agency.

Environmental Reporting - Performance Monitoring

Polartech monitors aspects of performance with regard to a number of environmental issues. As we operate under an IPPC Permit, we are required to report annual performance indicators to the regulatory Agency. The data presented below relates to calendar year 2005, and includes comparative data for previous periods where this is available.

Gas Consumption