Guidance Note. Hotels and Restaurant Group

Transcription

1 Guidance Note No. 1 Guidance Note Hotels and Restaurant Group Introduction This note provides an explanation of the environmental conditions applicable to the Hotel, Restaurant and Catering Services Group as set out in GBR No.1. The conditions are aimed at improving the environmental performance of small and medium scale enterprises and are part of a comprehensive new approach to environmental protection based on EU legislation, but with an emphasis on those issues of most relevance to our densely populated island. They should also serve to reduce the amount of local nuisance which may arise from the proximity of commercial activities to residences. If you are uncertain about any of the conditions of a GBR you should seek clarification from the Environmental Permitting & Industry Unit in ERA (phone ). Further advice is available in the ERA General Guidance Note for Small Enterprises. The final section of this note contains a listing of websites where additional information may be obtained. Individual small enterprises do not normally cause a significant environmental impact. As a group however, small enterprises in Malta have a very considerable potential for cumulative adverse impact. This is a consequence of their numbers: in Malta micro and small enterprises employ about 82,000 (in approx. 30,000 enterprises), about 70% of total employment in enterprises in this country. The environmental conditions set out in the GBR represent minimum requirements only and every hotel and restaurant should endeavor to act in a more environmentally sensitive manner so as to be a good neighbour and to contribute to the development of quality based tourism. Improved environmental performance can often be achieved at little cost and can create business advantages. Surveys have repeatedly shown that the modern tourist places a high premium on quality of the environment and that this factor is very important in the selection of a holiday destination. Thus attention to environmental issues by individual enterprises will contribute to an improved economic performance at national level and a better environment for citizens and tourists. 1

2 NOTE: This guidance note does not deal in detail with issues of energy conservation, water use and noise as ERA is not the competent authority for those issues at enterprise level. The guidance in this note is advisory only and is not mandatory. In case of any inconsistency between the advice and a GBR condition, the latter has priority. Compliance with the law, whether with a GBR or other legal requirement, remains the responsibility of the user. Guidance Notes are to be updated from time to time: Make sure you have the latest versions available on the ERA website ( Location a Key Factor It is considered that a combination of proper site location, an appropriate building and the application of the GBR conditions will ensure good environmental performance and minimal local nuisance. Not all local nuisance problems can be resolved by available, affordable technology. Prevention is the best solution and the choice of location for a new or expanding enterprise is critical in this regard. For example, noise from restaurants can be a considerable nuisance to neighbours, particularly in the evenings and at weekends. The location of the premises in terms of the proximity of local residences is the key factor, though some operational issues (e.g. working hours, closing of doors, soundproofing, location/muffling of fans and other outdoor equipment) can also be critical. New commercial activities should be located in zones appropriate to that activity, with similar or compatible enterprises as neighbours, or at such a distance from residences, important natural habitats and landscapes that complaints should not arise. The establishment of new activities in close proximity to residences (even where these are family owned) can result in ongoing disputes with neighbours in respect of issues such as noise, odour and traffic. Apart from legal costs, such local disputes can affect operational activities (e.g. through reduced hours of operation) and drain management energy. It makes business sense to avoid such issues through good initial site selection, even though the capital cost may be somewhat greater. For the same reason, established enterprises which are in such close proximity to residences that disputes have arisen in the past should consider the long term 2

3 business advantages of relocation to a more appropriate site. Be aware that the building you may purchase or construct in a new location should be suitable for the intended purpose and should allow you to meet the requirements of the GBR. Main Environmental Issues The most important environmental issues arising at hotels and restaurants in Malta are as follows: Litter and Waste management Emissions from boilers/ generators Odours from kitchens Sustainable water and energy use Noise Water usage is particularly important in Malta because we continue to withdraw groundwater at a rate greater than its replenishment by rain. The operation of seawater desalination plants utilizes a significant amount of electricity, which makes it both expensive and environmentally critical in terms of Malta s greenhouse gas emissions. As the costs of energy and water are likely to increase in the short to medium term there is a clear economic benefit for enterprises to minimise usage. A number of the larger hotels in Malta have already demonstrated how a commitment to higher standards has resulted in considerable benefits (e.g. cost saving, improved customer perception) through reductions in the use of energy, water and the quantity of waste requiring disposal to landfill. A substantial number (21) of hotels in Malta have recognized the importance of environmental issues by participating in the Eco-Certification scheme based on environmental criteria set by the Malta Tourism Authority (MTA). Tourist accommodation establishments interested in the Eco-Certification scheme must commit themselves to a process of continuous improvement. Further information on this scheme can be obtained from the MTA. Malta has an exceptionally rich biodiversity with a wide variety of plant and animal species, some of which are unique to these islands. However, many rare and important species are in serious decline due to such factors as habitat destruction from over-development in rural areas, spread of invasive alien species (such as Alianthus), intensification of agriculture and exploitation of wildlife (e.g. illegal hunting). Hotels can contribute to the maintenance of Malta s biodiversity through the increased use of native trees and shrubs in landscaping. Plants which are useful for this purpose include the Maltese Rock Centaury, Heather, Rosemary and Thyme. These are attractive in their own right and also help sustain native wildlife. Being native to Malta they are low maintenance and have minimal water requirements. 3

4 Litter and Waste Management Tourists in Malta have repeatedly emphasised their concern with litter and illegal disposal and abandonment of wastes that is widespread throughout the towns and countryside of Malta. Hotels and restaurants can play an important role by segregating waste at source, storing it in labeled containers in secure locations and in ensuring its disposal only at authorized facility. All food retail outlets should provide containers for litter and should undertake the cleaning of the footpath in the immediate area of their premises. Good environmental practices in hotels and restaurants are very visible to the public and high standards in respect of site tidiness, litter and waste management will act as an incentive to the public and other enterprise sectors. Increased attention to site tidiness and waste management will contribute to additional business at enterprise level, an improved economic performance at national level and a better environment for citizens and tourists alike. There are five such centres throughout Malta (Maghtab, Mriehel, Hal Far and Hal Luqa) and Gozo (Xewkija) and these are available for the receipt of small quantities of waste brought to the site. Information on the location of these sites, the types of waste acceptable and other operational details are available from Wasteserv at Freephone , Enterprises with significant quantities of these types of wastes cannot use these civic amenity facilities and must make their own arrangements for recycling or disposal, usually based on the use of registered waste carriers or waste brokers. The names of contractors authorised for collection and/or recycling or disposal of wastes can be found on the National Waste Management section of the ERA website. Because of charges at authorized waste facilities there may be a temptation for some waste carriers/brokers to dispose of waste in an illegal manner. Operators should note that the waste remains the responsibility of the generator until it reaches its final recycling or disposal facility. It is important therefore that you make use of reputable companies that are in possession of the correct permit for the transport and final disposal of the waste. Enforcement initiatives are designed to discourage low standards and to ensure proper use of the new collection, recycling and disposal facilities. Wastes should be disposed of by recycling wherever possible. For this purpose it is important to segregate waste streams at sources as mixed waste can rarely be recycled. Even the presence of small quantities of office or canteen waste in a 4

5 container of construction waste can result in its disposal to landfill rather than by recycling or re-use in the reclamation of old quarries. As it can be expected that the costs associated with the operation of the new facilities will be passed back to the user there will be an increasing cost benefit in reducing at source the quantity of waste arising. All enterprises should examine ways of reducing waste generation and maximizing the proportion of waste to be recycled. Techniques used for waste minimization in hotels and restaurants include the following steps: Undertake a review of the type and quantity of waste that you generate. Look in the bin every day for a number of weeks and record the types and estimate the quantity. Record how you dispose of wastes and note the associated costs. Talk to staff about how waste arises and discuss how it might be reduced Contact other enterprises in a similar business and examine published case studies to learn how others manage waste Enquire about any new collection and waste recycling services available in your area Try to identify individual waste streams (waste oil, containers etc.) that can be segregated for recycling Provide suitable containers for the segregated waste and train staff in their usage. Monitor progress over a 3 month period and praise staff who have participated. Treatment of Odours and Stack Height Local nuisance from kitchen odours is a common type of complaint ERA. Experience has shown that the major factors determining the severity of the nuisance are: The types of food being cooked The location of the exhaust stack or vent The extent of treatment. The frying of food is particularly odorous while the odour from fish restaurants may also be a cause of complaint. Kitchen areas in which frying takes place should always be fitted with an extraction hood incorporating a filter (baffle filter or equivalent) for removal of grease and fat which should be regularly maintained. 5

6 There can be a trade off between treatment and stack emission location, particularly when visual issues from high stacks and noise from fans must also be taken into account. In certain cases such as old buildings with adjacent sensitive residences, a high degree of treatment, incorporating, for instance, carbon adsorption might be necessary. However the equipment available for abatement of kitchen odours can be expensive and difficult to maintain and may not always be efficient enough to prevent a nuisance. Consequently some locations may never be suitable for the preparation of certain types of cooked food. ERA s requirements in respect of the height, location and design of Flue and Fume extraction systems for class 4D activities (Food and Drink) in new buildings are set out in Section 15.5 of the Development Control Policy and Design Guidance of 2015, and are given in Appendix 1. The discharge stack should normally vent at a height of 3 m above roof level, unless special circumstances apply (to be disclosed at development application stage). The height and location of the exhaust vent should be considered in some detail so as to maximize the dispersion of gases and minimise the potential for nuisance. The exhaust from the stack should be unimpeded to allow upward air flow. In existing buildings the stack should preferably discharge at a point at least 3 m above the highest point of the roof or adjoining building. The appropriate height depends on such site-specific factors such as the degree of treatment provided and local site sensitivity. In cases where a roof stack is neither necessary, practical nor sensible, the discharge stack should be located so as to minimise local nuisance. In these circumstances the height and location of the stack shall be agreed in advance with ERA. Other minor sources of odours such as low level exhaust fans and open doors and windows should also receive attention. In situations where there are a number of distinct emissions it is preferable that each emission have its own stack. The joining of emissions with different characteristics (such as from a solid fuel oven and an oil boiler) in a common stack may cause problems in one or both exhaust systems. The selection of the most appropriate hood, filter, extraction fan, source of makeup air and stack exhaust location and design can be complex and warrants detailed attention. Comprehensive but practical advice is available in the booklet Guidance on the Control of Odour and Noise from Commercial Kitchen Exhaust Systems which is available on the website of the U.K. Department for Environment, Food and Rural Affairs How ERA will deal with a Nuisance from Odours Where an emission to air from an existing enterprise is not causing a local odour nuisance, then little or no action is required - even if the stack vents at a height lower than ideal. However, when in the opinion of ERA a significant local nuisance does arise, the operator must 6

7 Identify the source of the odour Examine the options for elimination or minimization of the nuisance Propose an action plan to ERA for minimisation of nuisance The options which must be considered and documented by the operator will depend on the specific local circumstances. In some cases the relocation of the vent to another position may contribute to a solution of the problem. In others, the possibility of an additional treatment step for point source odours must be examined. Where the nuisance arises from the burning of fuels the option of replacement of the fuel should be considered. Other aspects to be examined include operational issues such as more frequent changing of cooking oil, regular cleaning of equipment and food storage areas, proper maintenance of equipment and closing of certain kitchen doors and windows. Consideration should be given to the general exhaust from the kitchen and restaurant which is commonly vented through a low level grill in a side wall. Such vents should normally discharge above head height and be directed upwards. The relocation or elimination of this and other small exhaust vents may help reduce odour nuisance. The storage of waste in covered containers combined with daily removal in hot weather may also prove useful in this regard. On the basis of the examination of these and other aspects, the operator should make a proposal in writing to ERA on its plans for addressing the odour nuisance. It is the responsibility of ERA to decide whether the options considered by the operator and the actions to be undertaken represent the best that can be done under the circumstances. If ERA regards the operator s response as inadequate then it will require the operator to consider further options. In the event of inaction or inadequate proposals by the operator, then a prosecution on nuisance grounds may follow. Discharge of Effluent Malta has constructed 3 modern wastewater treatment facilities which cater for effluent from household, industrial and commercial sources. The upgraded facilities (one each for north and south Malta, the other on Gozo) will ensure that effluent will receive a high level of treatment so that coastal bathing waters will comply with the strictest EU standards. The Water Services Corporation will be responsible for the satisfactory operation of the new treatment facilities. The need to consistently meet the high effluent discharge standards set in EU legislation will necessitate a greater degree of control by the WSC on the nature and characteristics of emissions to sewer from enterprises. The development of a new permitting system to control discharges to sewer is currently under discussion. The permitting system is expected to set out requirements for pretreatment such as screens and traps so that material discharged to sewer does not cause blockages or pose a danger to sewer workers. Enterprises have a role to play by ensuring that: 7

8 All effluent streams are discharged to the foul sewer Rainwater does not reach the foul sewer in significant quantities Raw materials and wastes are stored so as to prevent accidental escape Any pre-treatment steps as required by the Water Services Corporation (such as a grease chamber) are adequately sized and operated Liquid wastes, such as waste oil, are not disposed to drain Apply for a Sewer Discharge Permit with the Water Services Corporation and register any cesspit with the Superintendence of Public Health. The preparation of schematic drawings or site plans showing the layout of drains for your premises will help ensure proper segregation of foul water drains from storm water. The accuracy of the drainage map can be checked by using a running water hose. In some cases the use of a food dye in the water will help. The installation of a grease trap on the drain from the kitchen is necessary to protect the drainage system from blockage. This trap works best at low flow rates so it should be located only to receive wastes from sinks and washing machines. Effluent from toilets and surface drains should not pass through the grease trap. Malta obtains a large percentage of its potable water from groundwater and it is vital that it be fully protected. Unlike many other Member States, Malta has very little depth of soil above the bedrock to provide filtration and purification of contaminated water passing to underground. For this reason, the discharge of effluent and contaminated rainwater onto, or into land, is prohibited and all such effluents should be discharged to the foul sewer. Also for this reason attention must be given to proper storage of wastes so that rainwater does not become contaminated. Storage The proper storage of raw materials and wastes is an important factor in the maintenance of a tidy site and in the prevention of pollution of groundwater. All materials should be stored in a secure area away from sensitive areas and drains. You should never store wastes outside your site, unless it is nonhazardous waste awaiting same day collection. Drums and containers of hazardous chemicals should be stored in a secure, specific area away from public access. If outdoors, the storage area should normally be roofed to avoid contact with rain water. The storage area should be bunded or constructed in such a way that any spilled liquid cannot reach drains or land. All drums should be clearly labeled to avoid accidents and to identify appropriate clean-up methods in the event of a spill. Hazardous materials should 8

9 not be stored near to flammable materials as fire (or the dosing of fire with water) could cause an escape of pollutants. Incompatible materials (e.g. acids and alkalis) should not be within the same storage area as accidental release can lead to hazardous reactions. Any spilled materials should be cleaned up immediately and disposed of in an appropriate manner. Spilled materials should not be hosed away to drains or land. Useful Web Sites A considerable body of information in regard to good environmental practices in the hotels and restaurant sector is available on the following English language websites: Malta Environment and Resources Authority Malta Tourism Authority Department of Environment, Food and Rural Affairs Environment Agency of England and Wales Guiding small business through environmental regulations Queensland Environment Protection Agency 9

10 Annex 1 Policy and Design Guidance Flues and Fume Extraction Cooking smells from restaurants, cafes, snack bars, take-aways and other Class 4D uses can provide a source of nuisance, especially where these uses are located under or adjoining dwellings. Adequate filtering and fume extraction is therefore important, but it must be located and designed so that the fumes are filtered and vented away from overlooking windows. In particular, venting into a shaft shared with dwellings is not acceptable, nor is venting at roof level close to the windows of overlooking dwellings. It may of course be possible to utilise a form of filtering which does not require external venting and the Authority will encourage this. Control on the environmental effects of the development and its operation will also be operated through the (separate but related) environmental permitting process. All proposals for development falling within Class 4D of the Development Planning (Use Classes) Order, 1994 (Legal Notice 74 of 2014), where hot food is prepared and cooked, shall provide for the extraction of cooking fumes and smells, which shall: (a) Not vent to, or terminate in a shaft or yard which serves residential properties; (b) In the case of flues, terminate at least 3 m above the roof of the building to which flue is attached and of any immediately adjacent buildings; (c) Not be so located or positioned on the roof of a building that it terminates within 4 metres of the windows of any residential property overlooking or adjoining the roof; (d) Not be so located that it intrudes into the outlook from any adjoining residential properties; (e) Be fitted with the appropriate filters and of sufficient capacity to deal adequately with the fumes produced; and (f) Be so designed, located, dimensioned and coloured that it does not detract from the visual quality of the area nor from the appearance of the building to which it is attached (so that locations on the front façade of a building or on other facades visible from a public space will not normally be permitted). 10