IPPC: Don't try to fudge it

UK - The Environment Agency believes as many as 200 pig-keepers have failed to apply for an IPPC permit.
calendar icon 10 March 2007
clock icon 5 minute read

It is sending a letter to its list of suspects. This letter is not a casual enquiry and could have serious legal implications for recipients.

It is important to think carefully before responding, as your reply could be used as evidence in law courts.

You are at the IPPC threshold if you have:

  • 750 sows
  • OR 2000 finishers over 30 kilos.
You may be at or near the IPPC threshold if you have:

  • Pig units that are near to each other, or are clearly connected in some other way, and which together exceed 750 sows or 2,000 finishers.
The penalty if convicted of operating without an IPPC permit is:

  • In a magistrates’ court: up to six months in prison and/or a fine of £20,000.
  • In a crown court: up to five years in prison and/or an unlimited fine.

If you SHOULD have an IPPC permit but have failed to apply for one, you WILL be identified and are liable to be prosecuted if you do not act soon.

The Environment Agency has people on the ground who are familiar with every yard of every watercourse, however small.

They know their territory intimately. They know where your pig units are. They have a good idea about the size of your units.

If you receive a letter, or you fear you may be due to receive a letter from the Agency, this is what you should do.

  • Before taking ANY action with regard to the letter, take urgent advice from a pig industry consultant, or from Nigel Penlington at BPEX or from Barney Kay at NPA.
  • On this occasion you do not need to be a member of NPA to receive advice.
  • If one of the above advises you that you MAY need a permit, the wheels can be put in motion with the Environment Agency to try and ensure that your late response to IPPC (the deadline was January 31) does not trigger legal action and that you are given a short period of grace in which to apply.
  • Be aware that speed is of the essence. You will need to act within days rather than weeks.


NPA does not share the Environment Agency’s view that there are as many as 200 pig industry IPPC defaulters.

It is clear, however, that there are SOME pig-keepers who have failed to apply for IPPC and whose decision not to apply is unsafe.

These fall into three categories:

  1. I’m due to retire soon anyway and if I get caught I’ll just quit early.
  2. I have downsized to 1,990 finisher places, so I don’t need to apply.
  3. I have no single unit that reaches the IPPC thresholds and I don’t think my units come under the aggregation rules.

It is becoming clear from feedback from abattoirs that there has been some downsizing and this will probably be apparent when Defra carries out its summer census.

If you have downsized, the advice must be that it should be a genuine reduction and you should have documentary evidence.

For instance, If IPPC was the trigger that prompted you to reduce the herd to improve health status, then ensure your new strategy is outlined in your herd health plan.

You may also need to remove some drinkers and feeders or at least be able to argue that your failure to remove them is a deliberate part of your health plan.

Be aware that unless the Environment Agency pursues each case robustly, the United Kingdom risks infraction proceedings by Brussels.

If you are a producer with fewer than 750 sows, double check how many finishers you produce. Do you exceed the IPPC threshold of 2,000?

What would happen if your sow productivity improved? Would it put you over the 2,000 threshold? If so you are probably too close to the threshold to safely operate without an IPPC permit.

IPPC Applications

The Environment Agency has received 932 pig and poultry IPPC applications. It expected around 1,200.

In round figures it has had applications for 120 pig finisher sites and 21 pig breeding sites. This is well short of the 300-350 pig applications it expected.

It is sending 500 letters to pig and poultry keepers. It will ask integrators to provide information about their finisher network.

  • Do not try and fudge IPPC.
  • Do take professional advice immediately if you have any doubts about whether your position is sufficiently robust.
  • Remember any response you make to the Agency letter could be used in the law courts.
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