The assignment consisted of providing an independent technical opinion on the industrial, environmental, and operational status of a group with plants dedicated to the treatment and valorization of animal by-products (SANDACH), in a context especially sensitive due to its potential impact on discharges, emissions, and odors. The objective was not to “opine” but to verify, document, and accredit objectively the actual situation of the facilities, both the inherited and the post-change of control, and convert that reality into defensible technical evidence.
The complexity of the case came from the fact that there were previous reports with divergent conclusions on regulatory compliance and the technical status of the plants. On the one hand, serious deficiencies were described associated with discharges without adequate treatment, atmospheric emissions from deficient oxidation equipment, and episodes of bad odors affecting the environment; on the other hand, it was argued that the facilities were within the authorization framework and with improvements underway. This contradiction generated technical and strategic uncertainty: was there a structural problem of compliance and maintenance, or was it a situation already on track?
From martinsdelima, we approached the work as a comprehensive technical clarification: to identify precisely what was “inherited situation” and what was “current state”, to separate facts from interpretations, and to ground compliance in observable evidence. The report was structured to evaluate
(i) the technical and functional status of processes and infrastructures linked to SANDACH treatment (reception, sterilization, storage, odor purification, emission control, and liquid waste management),
(ii) the alignment with applicable environmental authorizations and permits and
(iii) the integrity and traceability of operational records and control systems, including the detection of incomplete data or practices that could simulate compliance without a real operational basis.
The methodology was deliberately “forensic engineering”: on-site technical visits, direct observation of the state of the facilities, interviews with managers, contrast of documentation with real operations, and collection of photographic, visual, and documentary evidence to support each conclusion. This approach allowed converting the analysis into a map of verifiable facts, minimizing biases and closing the gap between what “the paper says” and what really happens in the plant.
The result was a clear diagnosis by center, with special focus on the critical elements of compliance: water purification (WWTP), emission control, and soil containment/protection. In one of the plants, a very significant technical evolution was observed: a shift from a high-risk scenario to standards close to best practices, with a new WWTP, pretreatment (including grease separation), waterproofing and enclosures, monitoring of the subsoil through piezometers, and a leap in emission control by incorporating measurement connected to supervision systems and renewing key elements that substantially reduced the odor impact and improved operational stability. All this was accompanied by a technical regularization strategy aimed at reducing regulatory risk.
In parallel, the report was also useful for its technical honesty: in the second plant, it was evidenced that, although the modernization process had begun, there were still material and homologation actions to be completed to achieve robust compliance (especially in purification, certification of critical equipment, and management of the liability associated with the subsoil). Precisely there was the “excellent resolution”: martinsdelima delivered a solid, balanced, and actionable opinion, which allowed aligning the parties with facts, prioritizing investments where they really reduced risk, and transforming a discussion based on perceptions into a roadmap supported by evidence.