150th anniversary of the establishment of the Alkali Inspectorate
The Alkali Inspectorate was established on 1 January 1864 following parliament’s approval of the Alkali Act (1863) in July 1863. The Inspectorate aimed to control the release of damaging acid gas (hydrogen chloride) from alkali works. The legislation signified a sea change from the existing laissez faire approach to industry.
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By the 1850s, some 250,000 tons of salt were being decomposed annually in alkali works in the UK, resulting in the release of about 115,000 tons of acid gas. Legal proceedings against these works were largely unsuccessful, because it was difficult to attribute damage from the gas to a particular work and to conclusively attribute any damage to acid gas. Serious lobbying began only when the landed gentry and wealthy landowners experienced reductions in their land values and extensive damage to their woodlands. In 1862, the House of Lords set up the Select Committee on Injury from Noxious Vapours, with Lord Derby as chairman. Punch referred to the Select Committee as ‘Derby’s Smells Committee’ (1). During the Select Committee hearings, William Gossage, an alkali manufacturer in Worcestershire, gave details of his acid tower invention in 1836 that could condense the acid gas almost completely. This invention formed the basis of the Alkali Act (1863), with the Inspectorate established to ensure that the condensation limit of 95% was met by all Leblanc alkali works. The Board of Trade, as the responsible government department, appointed Robert Angus Smith as the first Inspector and gave him a blank slate as to how the Inspectorate should monitor the operation of the works to ensure that the condensation limit was achieved.
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Robert-Angus Smith (1817-1884). Reproduced courtesy of the library of the Royal Society of Chemistry
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Monitoring procedures
After a tussle with the Treasury, the Board of Trade was allowed to appoint four sub-inspectors (one for each of the four regions into which Britain was divided) to work alongside Angus Smith. The next stage was to draw up procedures that were consistent and scientific, because the information might form evidence in a court of law should a prosecution prove necessary. Angus Smith tried to avoid such prosecutions wherever possible because of his experience as an expert witness in the Spence court case of 1857 (2).
Angus Smith was adamant that analytical chemistry had to be at the core of the procedures if an objective assessment was to be made on whether an alkali works met the minimum condensation limit. When inspections got under way, another difficulty arose. With the large number of alkali works and the small number of inspectors, each works was only visited intermittently, providing works with opportunities to release acid gas undetected. To combat these digressions, Alfred Fletcher, one of the first sub-inspectors (who took over as Inspector when Angus Smith died in service in 1884), developed the compound self-acting aspirator, which could take samples of air in the flues leading to the chimney over a number of days. These aspirators were placed permanently in the flues and were sealed so that no one could interfere with their operation (3).
Inspectors as peripatetic consultants
Another major challenge for Angus Smith and his inspection team was to develop cooperative relations with the alkali manufacturers, because inspection required access to the works and working plant. During the Select Committee hearings in 1862, manufacturers expressed alarm about government interference in the workings of industry. John Hutchinson, an alkali manufacturer in Widnes, speaking on behalf of some manufacturers, submitted a statement of cooperation. Nevertheless, when inspections got under way there was often an uneasy relationship, and Angus Smith knew he had to win over all manufacturers if the condensation limit was to be met.
Alkali works were not always operated in an effective way that allowed them to meet the limit. Few works had qualified chemists; most proprietors were unqualified entrepreneurs, and processes were carried out in a rote manner using a recipe-type approach. The inspectors found themselves advising manufacturers on the operation of their plant and thereby acting as peripatetic consultants. This was potentially dangerous because the inspectors might be accused of giving one business a commercial advantage over another. The inspector had to focus on achieving the condensation limit.
Another manifestation of this commercial sensitivity was the handling of information gathered about each works during inspections. Angus Smith had to produce an annual report for Parliament on the workings of the legislation. His reports contain a considerable amount of technical information, much of which could be deemed commercially sensitive. The information is listed against a works registration number. The original register is held today by the Environment Agency, and, if the number of a particular works is known, it can unlock a large amount of information about the scale and operation of the works. The manufacturers eventually cooperated when it became clear that meeting the minimum limit enabled them to avoid legal challenge by the Inspectorate or by other parties.
Further legislation
The original 1863 legislation was approved for an initial five-year period; in 1868 it was approved indefinitely. Subsequent changes to the terms of the legislation aimed either to make it operate more effectively or to go beyond the alkali industry to include other chemicals and processes. An Amendment Act in 1874 replaced the difficult-to-assess percentage measure with a volumetric measure: “each cubic foot [28 litres] of air escaping into the atmosphere there is not to contained more than one-fifth part of a grain [0.013 g] of muriatic acid” (4).
The Royal Commission on Noxious Vapours (1876) began a discussion on another important principle for the Inspectorate, namely adoption of the “best practicable means” in controlling a polluting gas. Angus Smith and Alfred Fletcher were adamant that it was no good waiting for the final technical solution but that manufacturers should always make every effort to meet the limit. This would ensure that manufacturers at least attempted to meet the limit; when a better solution arrived, all works could adopt it. Such an approach put an onus on the manufacturers, who by this time had begun to employ qualified chemists to provide the expertise to improve plant rather than relying on the Inspectorate. This principle was incorporated into the Alkali Act (1881) and remains a backbone to pollution control.
The responsibilities of the Inspectorate increased steadily through the 20th century. By 1956 the Inspectorate was responsible for 1,794 processes in 92 works in England and Wales, and for 116 processes in 82 works in Scotland. As W. A. Damon (Chief Inspector from 1929 to 1955) reported in 1956, concerns were still being raised over a number of industries, including sulphuric acid, viscose processes, cement works, coal carbonization works, steel works, and ceramic works (5). As the scale of industrial development grew and chemicals became ever more sophisticated, the vigilance of the Inspectorate has helped to protect air quality in Britain. The Inspectorate has served Britain well during the last 150 years. Today, as HM Inspectorate of Pollution within the Environment Agency, it continues this important role.
References
1.Punch, 24th May 1862, p 204.
2.Peter Reed, Acid Rain and the Rise of the Environmental Chemist in Nineteenth-Century Britain: The Life and Work of Robert Angus Smith, Ashgate Publishing, Farnham, UK, 2014, pp 85-91.
3.Peter Reed, ‘Acid towers and the control of chemical pollution 1823–1876’, Transactions of the Newcomen Society, 78, (2008), pp 118-119.
4.Alkali Act (1863) Amendment Act 1874, P.P. 1874 (99).
5.W. A Damon, ‘The Alkali Act and the Work of the Alkali Inspectors’, Annual Report of the Council. Royal Society of Health (Great Britain), 76(9), (1956), pp 566-575.
After a tussle with the Treasury, the Board of Trade was allowed to appoint four sub-inspectors (one for each of the four regions into which Britain was divided) to work alongside Angus Smith. The next stage was to draw up procedures that were consistent and scientific, because the information might form evidence in a court of law should a prosecution prove necessary. Angus Smith tried to avoid such prosecutions wherever possible because of his experience as an expert witness in the Spence court case of 1857 (2).
Angus Smith was adamant that analytical chemistry had to be at the core of the procedures if an objective assessment was to be made on whether an alkali works met the minimum condensation limit. When inspections got under way, another difficulty arose. With the large number of alkali works and the small number of inspectors, each works was only visited intermittently, providing works with opportunities to release acid gas undetected. To combat these digressions, Alfred Fletcher, one of the first sub-inspectors (who took over as Inspector when Angus Smith died in service in 1884), developed the compound self-acting aspirator, which could take samples of air in the flues leading to the chimney over a number of days. These aspirators were placed permanently in the flues and were sealed so that no one could interfere with their operation (3).
Inspectors as peripatetic consultants
Another major challenge for Angus Smith and his inspection team was to develop cooperative relations with the alkali manufacturers, because inspection required access to the works and working plant. During the Select Committee hearings in 1862, manufacturers expressed alarm about government interference in the workings of industry. John Hutchinson, an alkali manufacturer in Widnes, speaking on behalf of some manufacturers, submitted a statement of cooperation. Nevertheless, when inspections got under way there was often an uneasy relationship, and Angus Smith knew he had to win over all manufacturers if the condensation limit was to be met.
Alkali works were not always operated in an effective way that allowed them to meet the limit. Few works had qualified chemists; most proprietors were unqualified entrepreneurs, and processes were carried out in a rote manner using a recipe-type approach. The inspectors found themselves advising manufacturers on the operation of their plant and thereby acting as peripatetic consultants. This was potentially dangerous because the inspectors might be accused of giving one business a commercial advantage over another. The inspector had to focus on achieving the condensation limit.
Another manifestation of this commercial sensitivity was the handling of information gathered about each works during inspections. Angus Smith had to produce an annual report for Parliament on the workings of the legislation. His reports contain a considerable amount of technical information, much of which could be deemed commercially sensitive. The information is listed against a works registration number. The original register is held today by the Environment Agency, and, if the number of a particular works is known, it can unlock a large amount of information about the scale and operation of the works. The manufacturers eventually cooperated when it became clear that meeting the minimum limit enabled them to avoid legal challenge by the Inspectorate or by other parties.
Further legislation
The original 1863 legislation was approved for an initial five-year period; in 1868 it was approved indefinitely. Subsequent changes to the terms of the legislation aimed either to make it operate more effectively or to go beyond the alkali industry to include other chemicals and processes. An Amendment Act in 1874 replaced the difficult-to-assess percentage measure with a volumetric measure: “each cubic foot [28 litres] of air escaping into the atmosphere there is not to contained more than one-fifth part of a grain [0.013 g] of muriatic acid” (4).
The Royal Commission on Noxious Vapours (1876) began a discussion on another important principle for the Inspectorate, namely adoption of the “best practicable means” in controlling a polluting gas. Angus Smith and Alfred Fletcher were adamant that it was no good waiting for the final technical solution but that manufacturers should always make every effort to meet the limit. This would ensure that manufacturers at least attempted to meet the limit; when a better solution arrived, all works could adopt it. Such an approach put an onus on the manufacturers, who by this time had begun to employ qualified chemists to provide the expertise to improve plant rather than relying on the Inspectorate. This principle was incorporated into the Alkali Act (1881) and remains a backbone to pollution control.
The responsibilities of the Inspectorate increased steadily through the 20th century. By 1956 the Inspectorate was responsible for 1,794 processes in 92 works in England and Wales, and for 116 processes in 82 works in Scotland. As W. A. Damon (Chief Inspector from 1929 to 1955) reported in 1956, concerns were still being raised over a number of industries, including sulphuric acid, viscose processes, cement works, coal carbonization works, steel works, and ceramic works (5). As the scale of industrial development grew and chemicals became ever more sophisticated, the vigilance of the Inspectorate has helped to protect air quality in Britain. The Inspectorate has served Britain well during the last 150 years. Today, as HM Inspectorate of Pollution within the Environment Agency, it continues this important role.
References
1.Punch, 24th May 1862, p 204.
2.Peter Reed, Acid Rain and the Rise of the Environmental Chemist in Nineteenth-Century Britain: The Life and Work of Robert Angus Smith, Ashgate Publishing, Farnham, UK, 2014, pp 85-91.
3.Peter Reed, ‘Acid towers and the control of chemical pollution 1823–1876’, Transactions of the Newcomen Society, 78, (2008), pp 118-119.
4.Alkali Act (1863) Amendment Act 1874, P.P. 1874 (99).
5.W. A Damon, ‘The Alkali Act and the Work of the Alkali Inspectors’, Annual Report of the Council. Royal Society of Health (Great Britain), 76(9), (1956), pp 566-575.
