Environment Matters

The gas industry has fewer obvious environmental problems to solve than some parts of the chemical industry but all types of business have some effect on the environment through the natural resources it consumes to make and distribute the products it sells.

Within BCGA, TSC8 is the Technical Sub-Committee that covers this topic. For BCGA members, information on the work of TSC8, including the minutes of the latest meetings, can be viewed via the Meetings page. Members interested in joining TSC8 are entitled to do so and should make contact with the BCGA office.

The national environment Regulators publish their own environmental guidance. Click the links below to read more on their respective websites.

Environment Agency
Natural Resouces Wales
Environment Agency (NI)
Scottish Environment Protection Agency (NI)

Significant environmental topics under TSC8’s view

Climate Change and Carbon Management

Climate Change Levy (CCL)

The UK Climate Change Levy (CCL) is a tax on industrial electricity, gas and oil usage. BCGA has a Climate Change Agreement (CCA) under the CCL in place since 2005, covering operators of Air Separation Units (ASU’s) in the UK.

CCA’s are applicable to industry sectors recognised to be ‘Energy Intensive’ by the Department for Business, Energy and Industrial Strategy (BEIS) that may, by ‘negotiated agreement’ gain partial relief from the CCL in return for progressively improving their energy efficiency in accordance with closely defined targets. CCA’s are extremely complex and further detail can be found on the BEIS website.

Streamlined Energy and Carbon Reporting (SECR)

Streamlined Energy and Carbon Reporting (SECR) is a new requirement from 2019 under the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. This replaces, but is not the same as, the carbon reduction commitment reporting.

This impacts large (large = 2 of: Balance sheet >£18 m, Turnover >£36 m, Employees >250) unquoted companies & Limited Liability Partnerships (LLP) >40 MWh energy use from financial years starting after 1 April 2019 and so the first time a report is due under SECR will be after April 2020. This information needs to be included in the Directors Report and the report may cover a group of companies. Processes are already in place for checking Company Reports via Company’s House.

What must you report?

  • UK total energy use (at least electricity, gas and transport)
  • Scope 1 (fuel used) and 2 (energy bought) emissions including stating methodology
  • Greenhouse gas (GHG) intensity (e.g. tCO2/£ turnover)
  • Commentary on energy efficiency actions taken. This should be: ‘meaningful, informative and consistent with the size of the business’ but if commercially sensitive this can be withheld (but must be explained). There will be no requirement to report specifically on actions identified via the ESOS audit process, but this can be used as the basis of the narrative if the company qualified for and complied with ESOS.
  • After the first year the previous year’s data must be included

Find out more on SECR.

Carbon Footprinting and Carbon Neutrality

An increasingly common practice is to assess and state the carbon consumption of businesses and of individual products. For a general guide to Carbon Footprinting refer to the Department for Environment, Food and Retail Affairs (DEFRA) website.

The European Industrial Gases Association (EIGA) has published specific guidance on this for the gases industry. Refer to EIGA – Document 167Methodology to establish a “product carbon footprint”.

EU Emissions Trading Scheme (EU ETS)

From the 1 January 2013 hydrogen and carbon monoxide plants producing >25 tonnes/day of hydrogen production come under the EU ETS, more information is available from EIGA.

Industrial Pollution Control – Environmental Permitting Regulations (EPR) and Integrated Emissions Directive (IED)

There are several gas industry processes which are covered by specific environmental permits; these are hydrogen and carbon monoxide production, acetylene, nitrous oxide or electronics gases production.

Air separation units and air gas filling plants, including mixtures, are not subject to the EPR permitting regime. Air separation units do often operate on sites regulated by the Environment Agency under EPR. The BCGA has worked with the Environment Agency to establish that no separate permit is needed for the gas company operation, provided that certain conditions are met. Refer to BCGA GN 21Environmental Guidelines for Air Separation Plant and Equipment on sites regulated under IPPC.

EIGA has produced Technical Bulletin 01/12Impact of the Industrial Emissions Directive, to provide information to EIGA member companies on the applicability of the Industrial Emissions Directive (IED) to industrial gases processes and on the changes introduced in the IED.

Gas Cylinders in the Waste Stream

Gas cylinders and other transportable pressure vessels are fully reusable, recyclable and can have a long life time. However gas cylinders do turn up at waste transfer and disposal sites and BCGA has produced guidance to manage the associated risks, refer to BCGA L 2The safe handling of gas cylinders at waste facilities. Additional information on managing the recovery of cylinders from waste sites or the disposal of cylinders can be found on the Cylinder Recovery & Disposal webpage.

Packaging Producer Responsibility Regulations

Gas suppliers have obligations under the Packaging Producer Responsibility Regulations. The Packaging (Essential Requirements) (Amendment) Regulations 2013 included for the first time, amongst others, ‘Refillable steel cylinders used for various kinds of gas, excluding fire extinguishers’. Refer also to the Environment Agency information noteBCGA GN 28Packaging waste within the industrial gases industry, provides further advice.

Regulations covering waste can be found on the website of the Environment Agency (or the Environment Agencies within your jurisdiction).

Fluorinated Gases (F Gas) and Ozone Depleting Substances (ODS)

Supply and use of F gas and ODS are regulated by EU and UK regulations. The F Gases Regulation was revised and subsequently published (517/2014) in the Official Journal of the European Union in May 2014. This Regulation has applied since 1 January 2015.

From 1 January 2015 the use of all HCFC’s as refrigerants for service and maintenance has been prohibited. A number of fluorinated products including refrigerants with a high global warning potential (GWP) are being phased out. From 1 January 2020 no more virgin product above 2500 GWP will be supplied but note that the Regulations are complex and require review by competent persons.

There are a range of replacement refrigerants being supplied. These may have different properties to the existing refrigerant, for example, some are flammable. The changeover from one product to another will require a thorough design review to ensure continued safety and reliable operation.

There are specialist recovery cylinders available from gas suppliers for the return of waste F gases and ODS gases, refer to BCGA TIS 41Cylinders provided for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia.

Advice and guidance on the F Gas Regulatory framework can be found on the DEFRA website. Comprehensive guidance on the F-Gas regulation has been provided on behalf of DEFRA by Gluckman Consulting. Additional information is published by EIGA – Document 192Fluorinated gases management.

Energy Efficiency

Energy Savings Opportunity Scheme

The UK Government has established the Energy Savings Opportunity Scheme (ESOS) to implement Article 8 (4-6) of the EU Energy Efficiency Directive (2012/27/EU). The scheme is implemented In the UK by the ESOS Regulations 2014. ESOS is an energy assessment scheme that is mandatory for organisations in the UK that meet the qualification criteria. The Environment Agency is the UK scheme administrator.

Organisations that qualify for ESOS must carry out ESOS assessments every 4 years. These assessments are audits of the energy used by their buildings, industrial processes and transport to identify cost-effective energy saving measures. Organisations must then notify the Environment Agency by a set deadline that they have complied with their ESOS obligations.

The most recent qualification date – the date on which organisations must determine whether they qualify for the scheme in that phase – is the 31st December 2022. By the 5th December 2023, you must notify the Environment Agency (as the scheme administrator) that you have complied with the scheme.

BCGA has prepared a Briefing Note to provide further guidance. EIGA provide additional information on energy efficiency in their Technical Bulletin 15Energy Efficiency: compliance with legal requirements and best practices.

Energy Performance of Buildings Directive (EPBD)

The Energy Performance of Buildings Directive makes it a legal requirement that an accredited inspector undertakes a mandatory Energy Efficiency Inspection, at least once every 5 years, on any air conditioning system over 12 kW total capacity.

These inspections are designed to ensure the system is suitable for the intended purpose and is operating correctly and efficiently. The regulations are enforced by Trading Standards and carry fines for non-compliance.

It is not mandatory to act on the recommendations of the Air Conditioning Energy Efficiency Inspection, however the findings often highlight energy saving opportunities which easily outweigh the cost of the inspection and remedial works.

In the UK, the Chartered Institution of Building Services Engineers (CIBSETM44 is used as the guidance for air conditioning inspections.

There is a government managed register for TM44 non-domestic accredited energy assessors.

Government Consultations

BCGA responds to many Government consultations, many on environmental matters. If you would like to contribute to any current consultations contact the BCGA Office.



GN21 Environmental guidelines for air separation plant and equipment on sites regulated under IPPC. Revision 2: 2016

1883 Guidance Notes GN21

This document provides guidance for BCGA members to assist their customers with compliance on the EC Directive on Integrated Pollution Prevention & Control. The Environmental Permitting (England and Wales) Regulations and the Pollution Prevention and Control (Scotland) Regulations implement the Directive in the UK.

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GN28 Packaging waste within the industrial gases industry. Revision 1: 2015

1904 Guidance Notes GN28

The UK has implemented the Producer Responsibility Obligations (Packaging Waste) Regulations and the Packaging (Essential Requirements) Regulations (as amended). This Guidance Note provides advice on the obligations necessary when procuring refillable steel gas cylinders for companies to comply with these Regulations.

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L2 The safe handling of gas cylinders at waste facilities. Revision 6: 2016

1876 Leaflets L2

Provides guidance on the safe and appropriate actions that should be taken to manage gas cylinders at a waste facility. This includes establishing that a cylinder is in a safe condition, any contents are identified and that there is a legal right to carry out any disposal activity.

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TIS41 Cylinders provided for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia. 2019

2017 Technical Information Sheets TIS41

Provides information on the use of recovery cylinders for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia either for preparation for re-use or for disposal, and identifies the appropriate environmental waste duty of care process.

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BCGA publish several publications providing advice on environment matters. All BCGA publications are accessible via the publications page. The following are of interest as they relate to environment matters..