It is the policy of James M Brown Limited to do all it can to protect the environment, realising that measures taken to achieve this end can also have simultaneous beneficial effects on the operating efficiency of the company.

The company's environmental policy will be reviewed and updated, as necessary, in the light of revised environmental requirements.

Compliance with this policy is achieved as follows:-

1. Legislation

A. Environmental Permitting Regulations 2007 ("EPR")
    (replacing Integrated Pollution Prevention and Control)

James M. Brown has an authorisation under EPR which covers, amongst other things :-

• production of cadmium pigments
  
  
• associated blending, conditioning and packaging of pigments
  
  
• production of stearates
  
  
• effluent treatment
  
  
• waste disposal
  
  
• storage and handling of solid and liquid materials
  
  
• site utilities and services

  The authorisation requires :-

• that emissions from the processes to surface water and to air are sampled regularly and tested for compliance with the discharge consents in the authorisation
  
  
• that odorous emissions are prevented or, where that is not practicable, reduced
  
  
• that these emissions are reported regularly to the Environment Agency
  
  
• that in the event of an emission falling outside the set limits, it is reported as soon as possible to the Environment Agency, and that the cause of the abnormal emission is investigated and procedures implemented to prevent recurrence
  
  

• management and control of all operations is maintained as required by the EPR authorisation

D. REACH

JMB has watched the development of REACH since before it actually became law and we can report the following progress in achieving compliance to date :-

• We have pre-registered all the products we manufacture where we have a potential registration obligation eg cadmium pigments and zinc stearate.
  
  
• We have not pre-registered calcium or magnesium stearate, as these two products are now covered by the updated REACH annexes IV & V and no longer have any registration obligation.
  
  
• We pre-registered a number of materials we merchant which we import directly into the the EU eg zinc oxide and ultramarine pigments, as a safety measure while the non-EU manufacturers were sorting out an EU-based "only representative" ("OR"). They have now pre-registered themselves using their "OR" and the material we import will be covered by their eventual registrations.
  
  
• We have ensured that all the critical raw materials we use have been pre-registered - either by the EU manufacturer / importer or by a non-EU manufacturer using an "OR".
  
  
• We have joined the consortium organised by the International Cadmium Association which is preparing the detailed technical dossiers covering a number of cadmium compounds. US Zinc has joined a similar consortium run by the Zinc Development Association covering zinc oxide.

• We have written statements from Heubach, Cabot, Norzinco and CCT confirming that they have completed all necessary pre-registrations.
  
  

• We have so far produced eleven short REACH newsletters to keep our customers advised of developments and we also have up-to-date REACH information posted on our Internet site. Further editions will be produced whenever there are matters of interest to bring to customers' attention.

C. COMAH

Changes in EU legislation and in material classifications have led to the need for us to update our COMAH site registration to "higher tier" in line with new requirements. Compliance with these regulations is laid down in separate documentation.

D. Ozone-depleting substances

None of the company's products contains any chemical which has been classified as an "ozone-depleter", nor are any of these chemicals used in the manufacture of any of the products.

E. Future legislation

The company takes proper steps to review the possible impact of future legislation and, when necessary, takes the opportunities which are available to take part in the consultation process.

2. Energy Utilisation

The company is a signatory to the Climate Change Agreement operated by the Chemical Industries Association. In this agreement, in exchange for a reduction in the Climate Change Levy, the company has agreed to improve energy utilisation efficiency by a fixed amount over the years to 2010. In order to achieve the agreed targets the company is actively involved in monitoring energy usage and in making continuous process improvements to minimise energy wastage.

3. Waste

A. Minimisation of waste creation

The company takes all practicable steps to reduce the production of waste from its processes. Whenever practicable, wastes and end-of-run materials are recovered and recycled in-house.

B. Waste disposal

When it is necessary to dispose of unavoidable wastes, the company takes care to ensure that its responsibilities under the Environmental Protection Act "Duty of Care" are fully met. All such wastes are handled by authorised waste carriers/disposal companies in such a way that the environment is protected. Occasional auditing of the transportation and disposal of waste is carried out to ensure that all "Duty of Care" requirements are being complied with. Our site is registered with the Environment Agency under the Hazardous Waste Regulations 2005.

Annual reviews of the waste produced and its eventual disposal routes are held.

4. Packaging

All legal requirements regarding the packaging, labelling and transportation of products classified as hazardous are fully complied with.

The company aims to reduce the amount of packaging which is used for its products, subject to customer requirements regarding product protection in transit and storage being met.

When practicable, the company encourages the supply of its raw materials and the sale of its products in bulk, leading to a net reduction in packaging volume. It is ready to co-operate with customers in the use of recyclable IBCs using an external valeting service.

Since 1999 we have been registered with Valpak under the "Packaging Regulations". The current compliance certificate is posted on our Internet site.

5. CIA "Responsible Care" scheme

As a member of the Chemical Industries Association, the company supports and complies with its "Responsible Care" scheme. Amongst other aspects, this requires JMB to submit annual statistics to CIA on its environmental performance.