The Environment Agency took a brave step forward in April 1998 when it launched the Monitoring Certification Scheme (MCERTS) for Continuous Emissions Monitoring Systems (CEMS). Now, it seems, the Agency is considering the expansion of the scheme to all regulatory monitoring, with the possibility of making the use of certified equipment mandatory on new installations. Multiple benefits for British industry? Maybe, but what of certification costs and transferability? Richard Whiteside, Land Instruments International, and Jonathan Kane, chairman of CoGDEM and chief executive of Kane International, give the trade industry view. Opposite, Richard Gould responds for the regulator.
A step further
Germany goes a step further than the USA in that it also requires type-approval of a CEMS before it can be used. The testing is carried out by TüV. Originally created to cope with the problem of steam boiler explosions, TüV is now one the most respected certification agencies in the world. In their laboratories, a sample instrument is tested for accuracy, linearity, and other performance characteristics. Then two identical instruments are installed on a working chimney and operated continuously. The results from the two systems are compared to determine the reproducibility of the measuring technique. If all criteria are met, the equipment receives official German government approval and its details are published in a register.
Any manufacturer of emissions monitoring equipment will find the task of selling his products greatly facilitated if he can produce an approved TüV or USEPA report to back up his claims. In the past, this has given a significant advantage to German and US manufacturers, since the achievement of the relevant approvals is an essential part of doing business in their own countries. By contrast, the UK attitude of telling the plant operator to install whatever equipment is required by his local inspector has not produced a coherent framework for UK manufacturers to work within.
MCERTS is a new opportunity and it is vital that maximum benefit be derived from it. There are many potential beneficiaries. Users of the equipment will benefit from a guaranteed level of performance. The instrument manufacturers will benefit from having a government-backed stamp of approval on their products. The test and certification companies will benefit from the new source of revenue. The Inspectors will benefit from the credibility of monitoring data, and the entire country will benefit from reducing the costs of the Environment Agency.
A major effort is needed to establish MCERTS' global credentials and ensure that MCERTS-approved equipment is acceptable in Germany, throughout Europe and North America. MCERTS will not help anyone if it simply becomes an additional burden on UK manufacturers. Will the Environment Agency make the effort required in Germany and the USA to ensure that MCERTS-approved equipment is valid for use in those markets, or will manufacturers continue to need local approvals to reach these markets? It is our understanding that TüV-approved equipment will automatically meet most of the MCERTS requirements, reducing MCERTS approval costs - will this be reciprocated or are we expected to have our products tested in full by TüV and USEPA if already MCERTS-approved? Bitter experience suggests this is the case, despite a common European Market. Without this, UK manufacturers will feel doubly punished by the cost of doing business in the UK and Europe.
Another problem remains - certification is too expensive. When it is 30% cheaper for a UK manufacturer to obtain approval through TüV (despite having to translate all of his documentation into German), than to have a similar job done to MCERTS standards, something is wrong. Five manufacturers have trodden the MCERTS path so far. At least one was charged double the original estimate for the work. This is intolerable. The basic test procedures should be available at fixed and reasonable prices to allow the cost of the work to be included in the product's business plan, as with all other development expenses.
The success of MCERTS is dependent on the goodwill of the equipment makers. At present, it is seen as a potentially powerful marketing tool to re-establish the position of UK manufacturers in global markets. However, if prices are not reduced soon and if there is no real progress in making MCERTS acceptable to the other certification authorities, then manufacturers will lose interest and the Environment Agency will be unable to justify insisting that all monitoring equipment be certified to the MCERTS standard. A wonderful opportunity for a variety of UK industries will have been lost.
MCERTS has started well and has received encouragement from all directions. CoGDEM believes it is essential that the testing companies, the Environment Agency and the manufacturers co-operate to make the scheme affordable, practical and internationally acceptable. This is a good time to show that "UK plc" is alive and well and knows how to conduct its business.
CoGDEM represents manufacturers of portable and fixed gas analysis and detection systems. www.cogdem.org.uk
Last year, the Environment Agency began to expand MCERTS significantly when it published two consultation documents for future standards covering manual stack emissions monitoring and ambient air monitoring.
The Agency's National Compliance Assessment Service (NCAS), responsible for developing and implementing the MCERTS scheme, is also working on four new sets of performance standards, to cover water monitoring, data recording, portable instruments for emissions monitoring, and operators' on-site arrangements for monitoring. In other words, there will be MCERTS standards for all regulatory monitoring activities. Each of the new developments will be expanded into different sections.
The Agency built MCERTS on proven international standards to ensure high quality monitoring data. As well as encompassing performance standards for monitoring equipment and services, an often forgotten yet key feature of MCERTS is a product and service certification scheme. This scheme is accredited under the EN 45000 series of European Standards, which specify a robust system for testing and third-party certification.
NCAS designed the scheme to promote regulatory and public confidence in monitoring data, providing industry with a proven framework for choosing monitoring systems and services that meet the Agency's performance specifications.
There are two big reasons for the Agency's expansion of MCERTS. First, the European community is developing a large series of standards for monitoring, covering all facets of air and water pollution. EC Directives have triggered the EC's development of many of these standards, which often specify performance characteristics for monitoring equipment. In some cases - such as the standards for monitoring ambient concentrations of NOx, SO2, CO, O3 and particulates - the new standards will become mandatory throughout the EC.
Secondly, the Agency's policy is to require regulated industries and processes to do more monitoring themselves. Monitoring of releases from industrial processes and their impact on the environment is a key element of regulating major industries. "Historically, regulatory authorities in the UK have undertaken monitoring of industrial processes. In recent years, particularly following the implementation of the Environmental Protection Act 1990, industrial process operators have been required to carry out compliance monitoring as specified by their authorisations, and to report their results to the regulatory authorities," explains Stuart Newstead, head of NCAS. This monitoring process has become known as operator self-monitoring, and the Agency's implementation of the European Directive on Integrated Pollution Prevention and Control (IPPC) will extend this approach. Thus, if there is to be more reliance on operator self-monitoring, then both the Agency and the public will need confidence in its quality; the role of MCERTS is to deliver the framework for quality.
The European standards body CEN is forming a working group to look at developing a product certification standard for air pollution monitoring equipment. As well as meeting performance specifications, product certification(in accordance with the requirements of EN 45011) under MCERTS requires an instrument manufacturer to demonstrate that the manufacturing process is controlled under a quality management system, and producing instruments that deliver consistent performance.
Once an instrument is certified the manufacturer also has to inform the scheme of any planned design or manufacturing changes to the instrument. The Scheme then assesses the proposed changes and carries out further tests, if required, to ensure a modified instrument still meets the MCERTS performance standards. Manufacturers are also audited by the Scheme on an annual basis as a further check.
Product certification is critically important to track any changes and provide assurance to potential customers and regulators that instruments manufactured months or maybe years after the original instrument was certified, still meet the MCERTS standards. As an additional safeguard, the MCERTS certificate has a lifetime of five years before an instrument has to be re-submitted for more detailed assessment and re-testing.
The German environmental regulator Umweltbundesamt (UBA) has a similar approval scheme for CEMS. The UBA scheme, sometimes known as the TüV scheme because TüV laboratories perform the testing of instruments, triggers many questions from both process operators and instrument suppliers. Many people want to know if TüV-type approval is the same as MCERTS certification, or if TüV-approved equipment is automatically acceptable for accelerated certification? The short answer is no; the UBA scheme was developed to support German legislation and policy, and not as a transportable certification scheme based on international standards. As it stands, the UBA scheme does not conform with EN 45011.
As the UBA and Agency schemes have much in common, instruments with TšV approval may meet some or all of the MCERTS performance standards, but additional tests may be required. In addition, the instruments would have to be submitted for formal product certification to the MCERTS standards under EN 45011.
The Agency has now completed the consultations for the proposals for ambient air monitoring and manual stack testing, analysed the responses, and is taking things forward. "There were over 850 responses to the proposals for MCERTS for manual stack-testing. Overall respondents were overwhelmingly in favour, with many detailed responses and suggestions," says Newstead. There were also several responses from overseas, reinforcing the growing international interest in MCERTS.
"In partnership with SEPA and the Source Testing Association, we are now about to tender for a contract to write the performance standards and to support us in developing the scheme. The Agency's provisional plan includes three main elements, which are personnel certification, accreditation of monitoring organisations and the MCERTS Register of qualified individuals and organisations," informs Newstead.
Last year, the Agency initiated a project to expand the coverage of MCERTS to include continuous water monitoring instruments (CWM) and wastewater samplers. In the field of CWM, there are not many European or International standards that adequately define performance characteristics and conformance tests, apart from certain flow-meters. Hence the Agency's interest in extending MCERTS to CWM. Regarding other standards, the NCAS will shortly issue a consultation document on MCERTS for portable emissions monitoring equipment. The scope will include sampling and monitoring equipment for stack emissions, fugitive releases and landfill gas. In the middle of the summer, a tender will be issued for the production of a performance standard for data-recording equipment and software. "The standard will take into account provisions for resolution, security and legislative requirements such as those within the Hazardous Waste Incineration Directive," concludes John Tipping from NCAS.
Lastly, there will be a standard for on-site arrangements for monitoring, which will be designed to assure the quality of all data delivered for regulatory purposes, covering instrumentation, calibration and maintenance of instruments. The key driver for this is the work of CEN TC 264, working group 9, which is developing standards for quality assurance in monitoring.