Revised TGN M20 V2.2 June 2010
Posted on: June 10, 2010
Version 2.2 of EA Technical Guidance Note (Monitoring) M20 has just been released by the Environmental Agency (England & Wales). Three of the key changes that will affect the initial planning of BS EN 14181 testing regimes are:
- From the beginning of 2011, all test laboratories used for performing BS EN 14181 QAL 2 and AST assessments must be accredited by UKAS to BS EN 14181. Environmental Compliance Ltd have already undergone their assessment and will be in the position to be able to offer this service from the start of 2011 as required;
- Organisations undertaking Functionality Tests, as outlined in Section 3.4 and Annex 1 of the Technical Guidance Note, must be able to provide evidence that they can meet the quality assurance and control requirements as stated in the Technical Guidance Note. This clause stresses the importance of good co-operation between the Test House, the Equipment Suppliers / Instrument Manufacturers (sometimes tasked with the functionality aspects of the standard) and the End Users. Functionality Tests should not be undertaken more than 1 month previous to the parallel measurements, unless the operator can justify the reasons to the regulator (i.e. be able to demonstrate that the Analyser System(s) or processes have remained stable and under control).
- BS EN 15259 requirements and the corresponding MID document have been inserted into the Technical Guidance Note to replace ISO 10396. Under the requirements of BS EN 15259, corresponding Method Implementation Document (MID15259) and as stated in Technical Guidance Note M1, Operators are required to prove that the gaseous species are sufficiently mixed, i.e. no difference in pollutant concentration across the duct. If the pollutants are adequately mixed they are considered “homogenous”.
If a homogeneity test has not been carried out at a location, it will be detailed in the report as a non-conformity and it will be up to the regulatory authority to decide what course of action they will take against the process operator if the work is not performed.
The above are just three of the seventeen changes that have been made to the Technical Guidance Note as an update to version 2.1 issued in September 2008. To download a copy of the revised document, please click here.
Are you controlling workplace noise?
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Workplace Noise: What do companies need to do to comply with the regulations and to defend themselves from claims?
The Control of Noise at Work Regulations 2005 came into force in the UK on April 6th 2006, with the aim of trying to ensure that workers are protected from excessive noise in the workplace. The flow chart below shows how the regulations are designed to work:
Over 1 million workers in the UK are exposed to levels of noise that put their hearing at risk, that is approximately 1 in 30 workers and some 170,000 people have in the UK have suffered deafness, ringing in the ears or other ear conditions as a direct result of excessive noise. It is clear therefore that noise is an issue that industry needs to understand and address.
One of the key misunderstandings when it comes to workplace noise and the Control of Noise at Work Regulations 2005 is in relation to how to both protect workers (as a priority), as well as ensuring that a business is protected against a claim.
Q: If I follow the guidelines illustrated by the diagram above will I satisfy the requirements of the HSE?
A: You will be well on your way to complying with the Regulations and satisfying the HSE as and when they visit your premises.
Q: By following the guidelines will I be able to defend against a claim for noise related deafness?
A: The answer to this is NO. The above flow chart shows what you need to do to assess the risk; the risk assessment process needs to be bolstered by measuring the risk.
Q: How do I protect my workers and protect by business?
A: The best way to ensure that a company protects its workers as a priority and is able to provide actual evidence that a company has endeavored to protect its workers, is by having actual evidence of noise levels at hand (Regulation 4 & 5). Having an independent survey carried out by a competent consultant is one of the best ways of providing this evidence and will bolster the information provided by internal assessments and that provided by health surveillance (Regulation 9).
Q: I have a noise mapping report; does this assess the risks to workers?
A: Having a noise assessment of the site to provide a noise map is a good way of defining boundaries for hearing protection areas, but it does not actually assess the impact on the workers and therefore does not fully comply with the requirements of Regulations 4 & 5. A noise mapping survey provides additional useful information to bolster a personal noise survey, but should not be deemed as something that is done instead.
Q: I provide hearing protection for my workers, surely that is helping me comply?
A: The Regulations do touch on hearing protection and the provision of suitable hearing protection is vital in the workplace if noise cannot be eliminated or controlled, but with all the different types of hearing protection out there are you sure you are providing the correct one? It is vital that if PPE in the form of ear defenders or ear plugs, for example, are chosen as a way of trying to control noise that the correct type of ear protection is selected. You could under protect or over protect, therefore by measuring the noise that the worker is exposed to, a more informed choice of PPE can be made.
Note: Protectors that reduce the level at the ear to below 70 dB should be avoided, since this over-protection may cause difficulties with communication and hearing warning signals. Users may become isolated from their environment, leading to safety risks, and generally may have a tendency to remove the hearing protection and therefore risk damage to their hearing.
Q: What should a noise survey look at?
A: The main priority of a workplace noise survey should be to conduct a true assessment on the worker at their point of work; this is what Regulations 4 & 5 actually ask for. There are several ways that this can be carried out based on the workers task. It can be carried out by a consultant using a hand held noise meter to measure the noise levels at the point of work, this is an acceptable assessment of the working noise where exposure levels are constant. Alternatively the survey can be carried out by attaching a noise dosimeter to the worker (as close to the impact area i.e. the ear as practical whilst avoiding any possible ’shadowing’ caused by the workers head) to assess the noise over the duration of their working day, or during a specific task. The use of a dosimeter is the best way of assessing noise exposure if a worker operates in various locations during their working day.
Whatever method is chosen it is critical that is a true assessment of the noise levels experienced.
A noise survey should look at what the company is doing to eliminate or control exposure (Regulation 6).
The survey should look at both sound pressure levels (dB) and noise frequency (Hz). Frequency (sometimes referred to as “pitch”) or Octave band analysis is critical when looking at situations where PPE is provided. PPE provided should be fit for purpose (Regulation 7). Tones of the same sound pressure level (dB) but different frequencies (Hz) do not sound equally loud to the ear, nor do they have the same potential for causing hearing loss (at high levels). The A-weighting curve approximates to the response of the ear to noise at different frequencies.
Therefore when you are looking at conducting an external assessment of noise at work, look at what you are getting. Anyone can measure noise, but not everybody assesses noise. This is the key to ensuring that you get what you are paying for and that the outcome is actually of benefit to both workers and the business.
For more details on the Health and Safety Executive and noise, or to order/download a copy of the regulations please use the following link www.hse.gov.uk/noise.
Our competent and experienced consultants have assisted companies in the UK and Europe in assessing the risks posed by noise in the workplace, conducting both surveys and training for those people exposed to noise in the workplace. For help and advice and to arrange a no obligation site visit by one of our consultants to discuss how you can protect your workers and your business , please call the head office on 01443 841760 and we will arrange for someone to discuss your requirements in detail.
Note: Flow chart courtesy of the HSE website.
Energy from Waste
Posted on: May 6, 2010
The UK, as a whole, is coming under increasing pressure to develop techniques to achieve its landfill diversion techniques and renewable energy generation targets. Energy recovery from waste is widely used as a way of adding significant value from materials which would otherwise be sent for landfill. Whilst these sorts of developments are potentially contentious ones, they are vital in reducing reliance on landfill and meeting renewable energy targets.
As a result of legislative drivers and government incentives (i.e. the Renewable Obligation Certificates) more and more companies are looking to break into this relatively young market. The Energy Technologies Institute estimates that the UK has the potential to utilise around 100 million tonnes of waste per annum, which in turn could generate up to 4% of its electricity and heating requirements.
With a ready made supply of fuel material and a demand for the outputs, Environmental Compliance’s involvement in planning applications for waste to energy facilities has increased significantly over the last year. We are currently involved in five major applications ranging from 50,000 to 400,000 tonnes per annum facilities.
Our role varies from preparation of individual chapters of an environmental statement, to total project management of the entire planning application. The planning team within the consultancy division is rapidly expanding and now includes chartered town and country planners. In addition to the planning stage, we are also heavily involved in preparing Environmental Permit applications and our UKAS/MCERTS emissions monitoring team are also assisting with commissioning and ongoing support of such facilities.
For more information on this article, please contact Sarah Burley (s.burley@envirocompli.com)
HSE look into the Waste & Recycling Industry
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The waste and recycling sector has increased dramatically over the last few years. With this in mind, the Health and Safety Executive (HSE) has tried to identify the key challenges faced by the waste and recycling industry, in view of the often competing demands in terms of health, safety and environmental considerations (e.g. meeting recycling targets), and the political sensitivities involved. The HSE view this industry sector as one that needs special attention in terms of advice and in extreme cases, enforcement.
The HSE is in the process of trying to establish the effectiveness of health and safety management within the waste and recycling industry, by focusing on certain key operational topics and activities. This approach is part of a wider programme of work targeting the waste management and recycling industry and is being carried out in conjunction with various large companies/operators throughout the UK to try and establish best practice. This will mean an increase in the number of HSE inspections at Waste & Recycling facilities, either local authority or commercial enterprises, and will no doubt lead to more enforcement notices being issued for non compliance with such regulations as:
- Control of Substances Hazardous to Health Regulations 2002 (COSHH)
- Control of Lead at Work Regulations 2002
- Control of Noise at Work Regulations 2005
- Control of Vibration at Work Regulations 2005
- Regulation for the registration, evaluation, restriction and authorisation of chemicals (REACH)
- The Restriction of Hazardous Substances (RoHS)
- Solvent Emissions Regulations (England & Wales) 2004, Solvent Emissions Regulations (Scotland) 2004
Environmental Compliance has worked closely with companies in this varied sector in helping them achieve and maintain compliance with health & safety, planning and environmental legislation. For help and advice and to arrange a no obligation site visit from one of our consultants, please call the head office on 01443 841760 and we will arrange for someone to discuss your requirements in detail.
For more details on the Health and Safety Executive and the Waste & Recycling Industry, please visit www.hse.gov.uk/waste.
BS EN 14181 calibration at ALSTOM Aghada
Posted on: April 29, 2010
As part of commissioning the new 430MW Combined Cycle Gas Turbine (CCGT) at Aghada, Ireland, Environmental Compliance was awarded the contract to perform the calibration of the newly installed MCERTS SICK MAIHAK MCS 100 E HW multi-gas analyser in accordance with BS EN 14181.
The project comprised of 2 stages, as prescribed in BS EN 14181, the first being a Functional Test audit, the second being parallel measurements using standard reference methods utilising Environmental Compliance’s MCERTS accredited FTIR analyser. The parallel measurements, spread evenly over 4 days, allowed a calibration function to be established for all determinands.
BS EN 14181 stipulates that standby fuels would require either a QAL2 or Annual Surveillance Test (AST), depending upon their usage over the year. As the site is expected to operate on the standby fuel oil for <10% of the time during the year, an AST was undertaken to verify that the calibration function, derived during the QAL2, is also valid for oil firing.
M1 Changes / Requirements
Posted on: April 20, 2010
The have been several changes to the Environment Agency’s (EA) Technical Guidance Note M1 “sampling requirements for stack emissions monitoring” (Version 6, January 2010) which MCERTS contractors and process operators need to be aware of when looking to plan a monitoring exercise, assessing OMA compliance in relation to sampling locations and sampling facilities, or looking to install an MCERTS CEMS system. The correct sampling locations and provision of suitable sampling facilities are key fundamental elements in ensuring good quality test data for use by process operators and associated regulators.
Sampling Locations
EA TGN M1 now has more emphasis on the requirements of the standard “BS EN 15259: 2007 Requirements for Measurement Sections and Sites for the Measurement Objective, Plan & Report”, with further information on its application being provided by an additional EA Method Implementation Document (MID 15259) published in February 2010. One of the key elements, is the assessment of the sampling location for manual sampling as well as for the positioning of CEMs and the requirement to undertake a homogeneity assessment. If a sampling location is not suitable, then the quality of the data produced will have increased levels of measurement uncertainty than that associated with compliant locations.
Note 1: All deviations from standard methods, no matter what the impact on the measurement result, have to be reported as part of the final MCERTS report and as part of the Site Specific Protocol (SSP) / site review document (See EA TGN M2 Version 6, Section 4.10.6).
Sampling Locations - Homogeneity Test
The homogeneity test is applicable mainly to combustion processes. This includes, but is not restricted to, those regulated under the Waste Incineration Directive (2000/76/EC) and the Large Combustion Plant Directive (2001/80/EC).
Note 2: It should be noted though that if Permit requirements dictate, non combustion processes also need to be assessed.
The homogeneity test is usually carried out at a measurement location once only. This must be done at conditions that are representative of the normal operation of the process. However, it may have to be repeated if there is a significant operational change in the process, such as a long term change in load, fuel, abatement technology or ductwork. This is especially critical when looking to install a CEMS system as the results of the test could impact on the type of technology suitable for that location and associated process conditions (e.g. is in-stack or out-stack the best option?)
Note 3: The test is not usually required for stacks with sampling plane areas of <1 m2 (i.e. below 1.13 m in diameter for circular ducts).
Note 4: The homogeneity test is not usually required if the emissions of a pollutant are less than 30% of the ELV (seek approval from the regulator authority to ensure permit compliance)
Note 5: The test should be carried out by an MCERTS contractor at least once.
Sampling Facilities
The Annex 1 section of TGN M1 provides a very useful checklist of “sample facility requirements for plant designers and operators”. This checklist highlights some of the requirements that MCERTS contractors look for as part of the Site Review and will also be documented in the SSP document issued prior to any manual stack emissions monitoring exercise. These requirements are just some of those that the Environment Agency will look for when conducting an OMA Audit. These requirements are re-enforced by the publishing of the new “Applications under the Environmental Permitting Regulations - Assessment of Monitoring Arrangements: Emissions to Air - Version 3, January 2010″ which is the underpinning document that the Environment Agency will use as part of OMA Section 2, element A “Sampling facilities”, one of the key “fundamental elements” of the OMA Version 3 Guidance Document issued by the Environment Agency in April 2009.
The CRC Energy Efficiency Scheme - Will it affect your organisation?
Posted on: March 31, 2010
The UK’s new carbon emissions trading scheme kicks off on the 1st April 2010 and will require action from around 20 000 large public and private sector organisations. The CRC Energy Efficiency Scheme (CRC) is a new regulatory incentive to improve energy efficiency in large organisations which aims to help hit the UK’s target of cutting greenhouse gas emissions by at least 80% by 2050.
All organisations that had at least one half-hourly meter settled on the half-hourly market within 2008 will be required to take some form of action. All organisations fulfilling the above criterion will need to make an information disclosure. Further to this, organisations will qualify as a full participant if the annual electricity supply through all their half-hourly meters was at least 6000 MWh. Full participants will then need to purchase allowances (initially sold by the government) for each tonne of carbon dioxide they emit.
If your organisation is unsure as to whether it is obligated or would like assistance in complying with this scheme then please contact s.burley@envirocompli.com. For more information about the scheme, please visit our CRC Energy Efficiency Scheme webpage.
Book your place on one of our FREE technical seminars
Posted on: March 1, 2010
Environmental Compliance, together with ABB and the Durag Group, will be hosting three FREE seminars across the country over the coming months:
- 23rd March at Murrayfield Stadium, Scotland
- 27th April at the Riverside Stadium, Middlesbrough
- 8th June at Bowood Golf Resort, Wiltshire.
The presentations, aimed at planners, developers, technical providers and operators of Energy from Waste (EfW) plants, large combustion plants and biomass plants, will benefit operators regulated by the Environment Agency and those who use Continuous Emission Monitoring Systems (CEMS).
The seminars will provide an overview on the various stages of the planning and permit application process, together with a synopsis of proven CEMS equipment and the important role they play in ensuring regulatory compliance, specifically in achieving conformity with BS EN 14181.
For further details, please download a copy of our conference flyer. If you would like to attend one of these seminars then please contact us.
David Graham joins Environmental Compliance Ltd
Posted on: January 27, 2010
David Graham joined Environmental Compliance as Principle Occupational Hygiene Consultant in January 2010 working alongside Antony Sumner and Darren Storey in expanding the company’s Occupational Hygiene Services.
David has over 25 years experience in occupational hygiene and environmental fields, both in industry and in consultancy. This includes a wide range of monitoring for:
- Chemical and physical parameters particularly welding fume, paints and solvents, respirable and inhalable dusts
- Noise (Workplace and Environmental)
- Hand-arm and whole body vibration
- Stack Emissions
- Auditing and testing of Local Exhaust Ventilation Systems
David is a Member within the Faculty of Occupational Hygiene (British Occupational Hygiene Society) and a Chartered Member of the Institute of Occupational Safety and Health. He will be mentoring Catherine Wright who has recently been awarded the Certificate of Operational Competence in Occupational Hygiene.
BOHS Exam Success
Posted on: January 4, 2010
Mrs Catherine Wright, Senior Occupational Hygiene Consultant within our Cardiff branch, has recently been awarded the British Occupational Hygiene Society’s (BOHS’s) Certificate of Operational Competence in Occupational Hygiene and Licentiate within the Faculty of Occupational Hygiene. Catherine successfully passed the core exams as early as 1999 but after a five year career break, to raise two children, and various changes to the BOHS admissions procedure, Catherine was required to re-sit one exam. Catherine will now be listed in the BOHS annual ‘Directory of Occupational Hygiene Consultants’.
The BOHS is the currently the largest hygiene society in Europe, with over 1200 members. Its Faculty of Occupational Hygiene plays a vital role in developing and maintaining the professional standards of hygienists, and is recognised internationally as a major professional examination and qualification body.