Setting the standard: OMA and MCerts
The past eighteen months has seen wholesale change in the way IPC/PPC stack emissions monitoring is undertaken. The cornerstones to these changes are OMA and the new MCerts standard, but where do these new schemes fit into the current system and what do they mean for site operators and emissions monitoring teams in the future? Integrated Environmental Technology Group (IETG), who carries out technology-based data gathering and information management in the land, water and air sectors, discusses the issues.
It is a common complaint of those in the manual stack monitoring profession that in recent years competition for work has led to price-cutting and the erosion of quality. Industry has felt for some time that the ‘barrier to entry’ needs to be raised to ensure robustness of reported emissions data and to allow stack teams to remain viable businesses.
Under the Environmental Protection Act 1990, larger and more polluting processes are regulated directly by the EA under Integrated Pollution Control (IPC) and Pollution Prevention and Control (PPC). Most sites under IPC/PPC control currently subcontract emissions monitoring to commercial stack emission teams, whereby the EA allows the operator to carry out its own self-assessment. The EA requires data from such testing to be made available to them and in addition may require ‘check monitoring’ to be carried, whereby the EA will directly employ an approved stack emission testing team.
About 35 per cent of all IPC-controlled industries are subject to check monitoring each year, the current value of which is approximately £2.5 million, paid for by industry itself. The EA only award these contracts to teams that can demonstrate the highest levels of quality, performance and know-how, with the traditional issue of cost being a secondary concern. IETG’s Air Division currently holds a number of these highly prized contracts.
The Environment Agency proposes to increase the amount of monitoring carried out under self-assessment, reducing the amount of EA-commissioned check monitoring required and the burden felt by the industries concerned. The immediate feeling of doom and gloom within stack emission testing circles has been replaced by some optimism when the full proposal is considered and the objectives digested.
Even though the EA will rely more upon process operators’ self-assessment, the EA hope that the OMA scheme will lead to more stringent emissions control over a wider number of processes. They believe that this will be achieved by improving the standard of monitoring carried out by stack emissions teams.
Key assessment areas
The six key issues to be assessed by the operator and the EA are:
- the management and training of stack emissions monitoring staff;
- suitability of the monitoring methods provided by the monitoring team;
- maintenance of the equipment used in monitoring emissions;
- regular and correct calibration of this equipment;
- robustness of the data produced by the monitoring team and what Quality Assurance and Quality Control procedures have been put in place by the team;
- performance of the site as compared to the emission limits set by the relevant Authorisation.
Upon auditing the operator, the EA will require information relating to each of the six key assessment areas, therefore the operator must be sure the emissions team they have procured comes up to scratch in each respect. In addition, the site must operate within its Authorised limits and the sampling positions must meet the required technical requirements. A simple scoring system will allow the EA to grade the emissions team and the site, where the higher the score achieved the better the quality of the emissions monitoring scheme.
What is the impact of this to either party? If the site operator chooses a low price and/or a low quality contractor, the Environment Agency will probably give the monitoring team a low scoring. They could surmise that they cannot have complete confidence in the data provided by the team and as a result, the operator could easily be subject to further scrutiny and expensive EA-sanctioned check monitoring. The operator will feel it in their pockets and, eventually, the site will have to bring in a good quality contractor anyway.
Where a site operator chooses a quality emissions testing team, they will gain the benefit of a high OMA score and the extensive experience such a team provides in helping the site operator meet their responsibilities under OMA. This will reduce the likelihood of costly check monitoring and possible unbudgeted process adjustments (like re-positioning of sampling ports) and gain the trust of the Agency who in turn will reduce the regulatory burden placed on the site operator.
The EA expect 25 per cent of all IPC processes to be audited using the OMA scheme by mid-2002, with the remaining 75 per cent of processes completed by 2003. But, the greater need to procure monitoring teams like IETG, who will provide the site operator with a good OMA score, on a background of rapidly changing approved protocols and accreditations, must leave the site operator wondering just what is the industry standard for emissions monitoring?
In February this year, the EA and SIRA (the certification body) launched the MCerts Standard for Manual Stack Emissions Monitoring at the Source Testing Association’s AGM. Although this standard has been met with mixed feelings in other sections of the environmental industry, the industrial air-monitoring sector has been calling for something like this for several years.
The MCerts standard ensures compliance to the required European standards and is the nearest thing to a ‘kite mark’ for stack emissions monitoring. It provides assurance to the site operator and the regulatory authorities that the services provided by the emissions monitoring team are capable of producing robust, repeatable and reliable data. Simply, it is the cement that holds the whole OMA scheme together.
The two key components of the MCerts scheme are that:
- stack emissions companies must be UKAS accredited for the specific analytes required to be tested under the site’s Authorisation; a stack emission company may chose to have the MCerts standard for one specific analyte (particulate by isokinetic sampling, for instance),
- individual stack emission engineers must be certified as having passed a strict syllabus relevant to their status within a monitoring team
Where stack emission testing companies want to obtain the MCerts standard, they must ensure three things:- that MCerts-status staff are used; that the company can give assurances with regards to staff training, the quality of methods and equipment used, reporting, robustness and accuracy of data; and that they take part in national proficiency schemes, like those run by the Source Testing Association.
Stack emission testing companies that meet this criteria can be found on the UKAS website (www.ukas.com) or through the Environment Agency. Individuals certified under the MCerts scheme are defined into three groups, depending on experience and competence:
Trainee :- new entrants with typically less than six months experience; these personnel are only allowed to undertake emissions monitoring on site under the direct supervision of a Level 2 Supervisor;
Level 1 Technician :- at least six months experience; has passed Level 1 basic examination; works in a team under a Level 2 Supervisor. Technicians do NOT undertake on-site risk assessments or authoring reports.
Level 2 Supervisor :- at least six months experience at Level 1 Technician; has passed Level 2 examinations and oral test; has passed at least one of the five Technical Endorsements (TE) available and can lead a team in the area where that TE is held. The Supervisor is responsible for the overall project management, risk assessment and report provision to the client.
It is important to realise that a company listed as having gained the MCerts standard may only be certified for one or two specific analytes. Therefore it is important to check the emission team’s Technical Endorsements (TEs) before giving approval for the team to start monitoring. For instance, at IETG there is an expectation to gain the MCerts standard across the full range of TEs available as this will be essential, not merely to continue servicing current clients who require certification as standard, but as a key to continued business expansion.
As OMA (and MCerts as the thing that backs it up) is the ‘new issue’, there are, as yet, no direct experiences to report on and site operators won’t feel the benefit for at least a year. But now that OMA is upon us, the MCerts standard will give site operators more confidence in whom they are employing to undertake the monitoring and make the procurement process easier. At IETG, the MCerts and OMA scheme is considered to be crucial in creating a level playing field amongst companies doing emissions monitoring. It will also ensure that the barrier to entry is raised and that site operators will see the long term value in choosing quality as a prequalifier rather than basic cost.