Paper-making takes a lot of water and returns a lot of it, so a mill carries a cluster of environmental duties that go beyond the workplace. Three regimes commonly apply, all overseen by the environmental regulators rather than the HSE: an environmental permit for the installation, a trade effluent consent for what you discharge to the public sewer, and an abstraction licence if you take water from a river, canal or borehole. Work out which apply to your mill, then put each in place.
A. Get your environmental permit for the installation
Pulp and paper installations above the regulated capacity need an environmental permit before they operate. The permit controls emissions to air, water and land, sets discharge and monitoring conditions, and for the larger installations applies best-available-techniques standards. In England the regulator is the Environment Agency and in Wales Natural Resources Wales, under the Environmental Permitting (England and Wales) Regulations 2016; in Scotland it is SEPA and in Northern Ireland the Northern Ireland Environment Agency, under their equivalent pollution prevention and control regimes. Apply for the right permit for your installation and nation, and keep to its conditions.
B. Get a trade effluent consent for discharges to the sewer
If you discharge process effluent to the public sewer, you need the prior consent of your sewerage undertaker — the water company in England and Wales, Scottish Water in Scotland, or NI Water in Northern Ireland — for that trade effluent. The consent sets limits on volume, strength and content and usually attaches charges; discharging trade effluent without consent, or outside its conditions, is an offence. Apply to your sewerage undertaker, characterise your effluent, and operate within the consent.
C. Get a water abstraction licence if you take water
If your mill takes water from a river, canal, reservoir or borehole above the licensing threshold, you need an abstraction licence. The licence sets how much you may take, when, and from where, to protect the water environment and other users. In England the Environment Agency licenses abstraction, with SEPA in Scotland, Natural Resources Wales in Wales and the Department of Agriculture, Environment and Rural Affairs in Northern Ireland. Check whether your abstraction needs a licence and apply before you take water.
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1. Check whether your installation needs an environmental permit
Confirm whether your pulp or paper installation is above the permit threshold, then apply for the right permit (standard rules or bespoke) from the Environment Agency, NRW, SEPA or NIEA and operate to its conditions.
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2. Apply for a trade effluent consent
If you discharge process effluent to the sewer, apply to your sewerage undertaker, characterise the effluent, and discharge only within the consent's volume, strength and content limits.
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3. Check whether you need a water abstraction licence
If you take water from a river, canal or borehole above the threshold, apply for an abstraction licence from the regulator for your nation and keep within its quantities and conditions.
What to do next
With your safe-mill spine and your environmental and water duties in place, deal with the rules for what you sell in Place paper products on the market, then confirm the whole picture with the paper manufacturer compliance checklist. Start from the router if you are not sure which guides apply to you.
Official sources
Authoritative environmental-permitting and water guidance.