ICPE inspection priorities for 2025

Each year, an instruction from the French Ministry of Ecological Transition defines the national actions of the inspection of facilities classified for environmental protection (ICPE).

The instruction of December 3, 2024 defines the priorities for ICPE inspections in 2025.

Firstly, "sustainable" actions:

• Policing of classified facilities (inspection visits, processing of authorization and registration applications, examination of studies submitted by the operator, combating illegal operations, in particular waste management, proposals to the competent authority for updating requirements, examination of applications for cessation of activities submitted after June^1, 2022, etc.);
• Other policing missions, within and outside classified facilities (enforcement of mining and post-mining regulations; control of hazardous equipment and products, other controls: REACH, biocides, hazardous pipes, refrigerants, inspections relating to the implementation of the anti-waste law for a circular economy);
• Integration of technological and health risks (implementation of PPRTs, management of polluted sites and soils, information for operators and stakeholders on regulations and the state of the environment, etc.).

Secondly, thematic actions selected on the basis of ecological planning guidelines and feedback from accidents:

On the one hand, systematic actions :

• Implementation of the "PFAS" interdepartmental action plan :
  • monitoring the implementation of action plans to eliminate or reduce PFAS emissions in aqueous discharges, drawn up following the analysis campaigns required by the Order of June 20, 2023 ;
  • monitoring the application of restrictions on the use of certain PFAS family compounds in emulsifiers under the POP and REACH regulations; request for an action plan to replace emulsifiers;
  • monitoring the quantity of PFAS present in sewage sludge from ICPEs and spread as fertilizer under a spreading plan

• Accident risk management (management of the first few hours following an incident/accident) :
  • loss of utilities" component (targeting SEVESO establishments as a priority): checking the effectiveness and relevance of measures designed to compensate for utility failures in the event of an incident/accident, and in particular, verifying that equipment is maintained and functionally tested, that autonomy is available (in terms of duration and equipment backed up), and that the utilities needed to operate risk control measures are taken into account when assessing their effectiveness.
  • implementation of provisions relating to first environmental sampling in the event of an accident" (action targeting in priority facilities close to populated areas / concerns Seveso sites and warehouses subject to 1510 authorization): check that the internal operations plan (POI) or fire defense plan (PDI) includes the implementation of first environmental sampling in the event of an accident; check and test the effectiveness of agreements, contracts or standby arrangements put in place.

• Chronic risk prevention :
  • Freeing up industrial land by speeding up the processing of applications for cessation of activity/.
    • action over 3 years: identify the files concerned by the release of industrial land, divide these files into different categories, define priorities for action, identify the means to implement the reduction;
    • action in 2025: inventory of files and categorization into action priorities, processing of the highest priority files.
  • Medium-sized combustion plants with a power output of between 5 and 50 MW falling under heading 2910: checks on the type of fuel used in the combustion plant, checks on atmospheric emissions and compliance with inspection frequencies and applicable emission limit values (ELVs), on-site checks on flue gas treatment systems, checks on compliance with on-site declaration of combustion plants simplified procedures.
• Fight against illegal waste trafficking: Targeted actions on end-of-life vehicle (ELV) centers: control of illegal sites under ICPE regulations (no approval in force or not registered under heading 2712), implementation of the obligation to contract with an eco-organization or to set up an individual system, use of Trackdéchets by ELV center operators.

On the other hand, a choice of actions

Each region must implement one action from each of the following lists, as well as one regional initiative:

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