ANNUAL ENVIRONMENTAL REPORT

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ANNUAL ENVIRONMENTAL REPORT JANUARY 2017 TO DECEMBER 2017 Licence Registration Number: PO357-01 Licensee: Cross Vetpharm Group Ltd Location of Activity: Attention: Airton Close, Tallaght Dublin 24. Office of Environmental Enforcement East/North East Region EPA McCumiskey House Richview Dublin 14

Cross Vetpharm Ltd. Annual Environmental Report 2017 CONTENTS SECTION 1: INTRODUCTION 1.1 Introduction 1.2 Site Description 1.2.1 Description of Activity 1.2.2 Economic Contribution SECTION 2: SUMMARY DATA 2.1 Waste Management Table 2.1 Table 2.2 Table 2.3 Non-Hazardous Waste Disposal / Recovery Record Jan 2017 to Dec 2017 Hazardous Waste Disposal / Recovery Records Jan 2017 to Dec 2017 National Waste Database Report Sheet 2.2 Water Emissions Table 2.2.1 Quarterly Results 2017 Table 2.2.2 Details of reported Non-compliances 2017 Water 2.3 Air Emissions Table 2.3.1 Emissions to Atmosphere 2017 Table 2.3.2 Details of Non-Compliances 2017 - Air 2.4 Noise Emissions 2.5 Energy and Water Usage Table 2.5.1 Energy Usage 2017 Table 2.5.2 Water Usage 2017 Table2.5.3 Gas Oil Usage 2017

Cross Vetpharm Ltd. Annual Environmental Report 2017 2.6 Environmental Incidents and Complaints 2.7 Environmental Spending SECTION 3: ENVIRONMENTAL MANAGEMENT SYSTEM 3.1 Environmental Management System Description 3.2 Environmental Management Organisation 3.4 Environmental Management Programme for 2017 3.4.3 Review of Objectives and Targets (January 2017 - December 2017) 3.4.4 Proposal for Objectives and Targets (January 2018 - December 2018) Appendices Appendix 01 Weekly Visual check of Surface Water Drain - report Appendix 02 Daily Effluent Readings Appendix 03 PRTR Scan

Cross Vetpharm Ltd. Annual Environmental Report 2017 SECTION 1 INTRODUCTION

Cross Vetpharm Ltd. Annual Environmental Report 2017 1.1 INTRODUCTION The following is the Annual Environmental Report (AER) for the period January 2017 to December 2017 at Cross Vetpharm Group Ltd. The company are licensed by means of Integrated Pollution Control Licence Register Number P0357-01, for; - The manufacture of pesticides, pharmaceutical or veterinary products and their intermediates under the First Schedule of the Environmental Protection Agency Act, 1992 to which the activity relates as per Class 5.6. The company was granted an Integrated Pollution Control Licence No. 357 on the 16 th June 1998. This is the 2017 Annual Environmental Report of Cross Vetpharm Group Limited and detailed within is a summary of all activities on-site during this period that has had an influence on the environmental performance of the company. Current (2000) guidance from the Agency requires that the AER is referenced per calendar year. Cross Vetpharm Group Ltd, located at Airton Close, Tallaght, Dublin 24 (Grid Ref. E3091, N2282) are manufacturers of veterinary, pharmaceutical and animal health products. The average number of people employed is 13 Normal operating hours are: The normal operating hours of the facility is 07:00 to 21:00 p.m. Monday to Friday; With some limited operations on Saturday. This AER reflects company s commitment to achieving objectives of a documented ongoing improvement programme at the site.

Cross Vetpharm Ltd. Annual Environmental Report 2017 Environmental Policy

Cross Vetpharm Ltd. Annual Environmental Report 2017 1.2 SITE DESCRIPTION The Cross Vetpharm site is located at Airton Close, Tallaght, Dublin 24. Surrounding land use is primarily industrial in nature, with industrial developments to the north, east and west boundaries. The products formulated at the facility fall into four categories namely: Drenches: These are for oral administration to animals to control internal Parasites. Dairy Hygiene: These are dairy parlour cleaning/hygiene products. Nutritionals: These are vitamin/mineral type supplements for horse and cattle. Ectoparasiticides: These are used for the control of skin parasites on the sheep and cattle. These products are presented as Dips and Pour On s. These products are prepared and packed in dedicated suites and in accordance with the requirements of the Irish Medicines Board.

Cross Vetpharm Group Ltd Annual Environmental Report 2017 1.2.1 DESCRIPTION OF ACTIVITY Production consists of the following steps: Materials are received in the drum store and plant in bags, drums etc, as required (Keeping stocks on-site to a minimum) Raw materials are subjected to quality control before use. The various product ingredients are made up in vessels equipped with stirrers, heating/cooling jackets, etc. Formulated products are then subject to further quality controls. Finished products are packed and dispatched. 1.2.2 ECONOMIC CONTRIBUTION Cross Vetpharm have been specialists in the manufacture of animal health products and are now a leading supplier to major domestic and overseas customers and currently employs a staff of 13. Organisational Chart 2017 Plant EHS Manager Airton Close Production Manager Packaging and Warehouse Operatives Process Operators Production Service Operators

Cross Vetpharm Group Ltd Annual Environmental Report 2017 Section 2 DATA

Cross Vetpharm Group Ltd Annual Environmental Report 2017 2.1 WASTE MANAGEMENT In accordance with Condition 7.4 Waste Management of Integrated Pollution Control Licence Register No. 357, Cross Vetpharm Ltd. are required to maintain a waste management record detailing matters relating to the disposal/recovery of waste from the site. The overall waste summary record for this period is presented in tabular format as follows: Table 2.1: Non-hazardous Waste Disposal / Recovery Records (January 2017 to December 2017) Table 2.2: Hazardous Waste Disposal / Recycling Record (January 2017 to December 2017)

Cross Vetpharm Group Ltd Annual Environmental Report 2017 TABLE 2.1: NON-HAZARDOUS WASTE DISPOSAL RECORD (JANUARY 2017 TO DECEMBER 2017) Waste Type EWC Code Disposal Recovery Codes Name of Waste Disposal / Recovery Contractor Quantity (Tonnes) Location of Disposal / Recovery Plastic 15.01.02 R3 Panda Waste 7.4 Ballymount Cardboard 15.01.01 R3 Panda Waste 18.2 Ballymount Compostable Material 20.03.01 R3 Panda Waste 2.34 Ballymount Best Mixed paper 20.01.01 R3 Panda Waste 0.14 Ballymount Wood 20.01.38 R3 Panda Waste 0 Ballymount General Refuse 20.03.01 D1 Panda Waste Municipal Waste (Canteen) Total Waste Disposed 5.46 Ballymount 20.03.01 D1 Panda Waste Ballymount - - - -

Cross Vetpharm Group Ltd Annual Environmental Report 2017 Table 2.2: Waste Type Contaminated Waste Drums Hazardous Waste disposal record (January 2017 December 2017) EWC Code Disposal Recovery Codes Name of Waste Disposal / Recovery Contractor Quantity Tonnes Location of Disposal / Recovery 150110 R5 Rilta 8.051 Rathcoole Co. Dublin Liquid Waste 180205 R1 Rilta 12 Holland Solid Waste (Cloths) 150202 R1 Rilta 2 Holland The waste drums contain residues of hazardous raw materials. Table 2.3 National Waste Database Report Sheet Industry Sector NACE Code D G Reporting Period 2014 2015 2016 2017 Number of Employees 13 13 13 13 Total quantity of Waste Produced (Tonnes) 60.113 63.838 49.277 55.591 Total quantity of waste disposed of on-site 0 0 0 0 Total quantity of waste disposed of off-site 11 10.9 9.33 5.46 Total quantity of waste recovered of on-site 0 0 0 0 Total quantity of waste recovered of off-site 49.113 52.938 39.947 50.131 Quantity of non-hazardous waste produced (Tonnes) 48.5 45.84 39.467 33.54 Quantity of non-hazardous waste disposed of on-site 0 0 0 0 Quantity of non-hazardous waste disposed of off-site 11 10.9 9.33 5.46 Quantity of non-hazardous waste recovered of on-site 0 0 0 0 Quantity of non-hazardous waste recovered of off-site 37.5 34.94 25.617 28.08 Quantity of Hazardous waste produced (Tonnes) 11.613 17.998 14.33 22.051 Quantity of Hazardous waste disposed of on-site 0 0 0 0 Quantity of Hazardous waste disposed of off-site 0 0 0 0 Quantity of Hazardous waste recovered of on-site 0 0 0 0 Quantity of Hazardous waste recovered of off-site 11.613 17.998 14.33 22.051

Cross Vetpharm Group Ltd Annual Environmental Report 2017 2.2 WATER EMISSIONS In accordance with Condition 6 Emissions to Sewer of Integrated Pollution Control Licence Register No. 357, monitoring and analysis of each emission shall be carried out as specified in Schedule 1 (ii) Monitoring of Emissions to Sewer of licence No. 357. Table 2.2.1 Effluent (SE1) Analysis Results for 2017 Parameter ELV Result Q1 10/3/17 BOD (mg/l) 1000 <2 COD (mg/l) 5000 5 Oils, Fats and Grease (mg/l) 100 <2 ph 6-10 7.4 Suspended Solids (mg/l) 500 2 Detergents (mg/l) 100 <0.05 Phenols (mg/l) 0.5 <0.05 Temperature o C 15 Parameter ELV Result Q2 23/6/17 BOD (mg/l) 1000 3 COD (mg/l) 5000 23 Oils, Fats and Grease (mg/l) 100 <2 ph 6-10 7.4 Suspended Solids (mg/l) 500 4 Detergents (mg/l) 100 <0.05 Phenols (mg/l) 0.5 <0.05 Temperature o C 42 19 Parameter ELV Result Q3 28/09/17 BOD (mg/l) 1000 <2 COD (mg/l) 5000 6 Oils, Fats and Grease (mg/l) 100 9 ph 6-10 7.8 Suspended Solids (mg/l) 500 3 Detergents (mg/l) 100 <0.05 Phenols (ug/l) 500 <100 Temperature o C 42 19 Parameter ELV Result Q4 18/12/16 BOD (mg/l) 1000 <5 COD (mg/l) 5000 32 Oils, Fats and Grease (mg/l) 100 <2 ph 6-10 7.8 Suspended Solids (mg/l) 500 <1 Detergents as MBAS (mg/l) 100 0.09 Phenols (ug/l) 500 <100 Temperature o C 42 13

Cross Vetpharm Group Ltd Annual Environmental Report 2017 Toxicity Results Effluent Sample from the 15/6/17 EC50 toxicity value (180 minutes) - Greater than 50% concentration v/v Toxic Unit Value (180 minuets) - Less than 2 TU Inhibition Treshold (180 minutes) - Greater than 50% concentration v/v Toxicity Results Effluent Sample from the 24/10/17 EC50 toxicity value (180 minutes) - Greater than 50% concentration v/v Toxic Unit Value (180 minuets) - Less than 2 TU Inhibition Treshold (180 minutes) - Greater than 50% concentration v/v Table 2.2.2 Details of Reported Non-compliance 2017 Water Date Non-compliance Cause Corrective Action No Non-compliances reported in 2017.

Cross Vetpharm Group Ltd Annual Environmental Report 2017 2.3 AIR EMISSIONS In accordance with Condition 5 Emissions to Atmosphere of Integrated Pollution Control Licence Register No. 357, no monitoring and analysis of Emissions to Atmosphere is required Table 2.3.2 Details of Non-compliance 2017 Air Date Non-Compliance Failure Details / Cause Corrective Action None to report

Cross Vetpharm Group Ltd Annual Environmental Report 2017 2.4 NOISE EMISSIONS In accordance with Condition 8 Noise of Integrated Pollution Control Licence Register No. 357, Cross Vetpharm are required to carry out a noise assessment of the site on an annual basis. Following a site visit by EPA staff, Cross Vetpharm was informed that no annual noise survey is required.

Cross Vetpharm Group Ltd Annual Environmental Report 2017 2.5 ENERGY AND WATER USAGE The summary details of energy and water usage at the plant for the period January 2017 to December 2017 is detailed in Table 2.10 below. Table 2.5.1 Energy Usage 2017 Energy Used kwh 410000 Table 2.5.2 Water Usage 2017 2017 Total Water Used per Quarter Water Used per Week 5300 1325 101.92 Table 2.5.3 Oil Usage 2017 Oil Usage 35000 L

Cross Vetpharm Group Ltd Annual Environmental Report 2017 2.6 ENVIRONMENTAL INCIDENTS AND COMPLAINTS All environmental incidents and complaints are recorded. In accordance with condition 4.3 - Notifications of IPC licence no. 357, A summary report of reported incidents shall be submitted to the agency as part of the AER. The information in this report shall be prepared in accordance with any relevant guidelines issued by the agency 2.6.1 There were no incidents to report for the period Jan 2017 to Dec 2017. Incident Date / Time Location Persons Contacted Corrective Actions 2.6.2 There were no complaints to report for the period Jan 2017 to Dec 2017.

Cross Vetpharm Ltd Annual Environmental Report 2017 2.7 ENVIRONMENTAL SPENDING The itemised spend on environmental issues at Cross Vetpharm Limited is listed below. January 2017 December 2017 EPA fees 6900 South Dublin County Council Fees 3900 IPC Licence No. 357 Management 10000 Recovery / Disposal of non-hazardous waste 2000 Disposal of hazardous waste 11000 2.8 ENVIRONMNETAL TRAINING The staff of the Airton Close facility undertook a general staff training including SOP training.

Cross Vetpharm Ltd Annual Environmental Report 2017 Environmental Management Programme for 2017. Review of Objectives and Targets for the period January to December 2017 Tables EMP 1.1 to 1.3 reviews the Objectives and Targets set for 2017. A number of the listed Objectives and their subsequent targets are cyclical as the company attempts to achieve continuous environmental improvement. Tables EMP 2.1 to 2.3 set out the Objectives and Targets for 2018. A number of the listed Objectives and their subsequent targets are cyclical as the company attempts to achieve continuous environmental improvement.

Cross Vetpharm Ltd Annual Environmental Report 2017 EMS EOT 1.1 Objective Target Target Date 2017 Review Person Responsible Review licence to ensure all EMS procedures required are available and upto-date. Q2 2017 Complete D.Dempsey Audit site EMS Ensure all environmental SOP's are reviewed and up-to-date. Q3 2017 Complete D.Dempsey Carry out an internal audit to assess compliance to EMS procedures Q4 2017 Move to 2018 D.Dempsey

Cross Vetpharm Ltd Annual Environmental Report 2017 IPC Compliance EOT 1.2 Objective Target Target Date 2017 Review Person Responsible Carry out sampling of emissions to sewer every quarter. Q1, Q2, Q3 and Q4 2017 Complete D.Dempsey Program for insuring compliance to Licence 357 Weekly visual inspection of surface water. Undertake bund testing of bunds in year 3 of testing cycle 2017 Complete D.Dempsey Q2 2017 None Required 2017 D.Dempsey Review and develop new schedule each year Q4 each Year Complete D.Dempsey

Cross Vetpharm Ltd Annual Environmental Report 2017 Site Management EOT 1.3 Objective Target Target Date 2017 Review Set up Environmental Equipment checklist Bund management Prepare a list of equipment on site which has an environmental role Set up a check list for each piece of equipment Prepare details of bund capacities which will be fitted to the exterior of the bunds. Person Responsible Q2 2017 Move to 2018 D.Dempsey Q2 2017 Move to 2018 D.Dempsey Q3 2017 Move to 2018 D.Dempsey

Cross Vetpharm Ltd Annual Environmental Report 2017 EMS, Equipment EOT 2.1 Objective Target Target Date Person Responsible Carry out an internal audit to assess compliance to EMS procedures Q2 2018 D.Dempsey EMS, Equipment Purchase new sampling equipment for SW1 Q3 2018 D.Dempsey Install and commission the new sampling equipment forsw1 Q3 2018 D.Dempsey

Cross Vetpharm Ltd Annual Environmental Report 2017 IPC Compliance EOT 2.2 Objective Target Target Date Person Responsible Carry out sampling of emissions to sewer every quarter. Q1, Q2, Q3 and Q4 2018 D.Dempsey Program for insuring compliance to Licence 357 Weekly visual inspection of surface water. 2018 D.Dempsey Undertake bund testing of bunds in year 3 of testing cycle Q4 2018 D.Dempsey Review and develop new schedule each year Q4 each Year D.Dempsey

Cross Vetpharm Ltd Annual Environmental Report 2017 Site Maintenance EOT 2.3 Objective Target Target Date Person Responsible Set up Environmental Equipment checklist Prepare a list of equipment on site which has an environmental role Q2 2018 D.Dempsey Set up a check list for each piece of equipment Q2 2018 D.Dempsey Bund management Prepare details of bund capacities which will be fitted to the exterior of the bunds. Q3 2018 D.Dempsey

Appendix 1 Weekly Surface Water Check

Appendix 2 Daily Effluent Readings

Appendix 3 PRTR Scan