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Safety Requirements for Emissions Monitoring

The EPA has published the Guidance Note on Site Safety Requirements for Air Emissions Monitoring (AG1). This guidance describes the facilities and work practices that must be in place for the safe and effective monitoring of air emissions. It is a requirement of all IE, IPC and Waste licences to provide safe and permanent access to all sampling and monitoring points. The guidance is aimed at licensed operators, the service providers of environmental monitoring and any relevant EPA staff. Guidance is provided on:

  • The selection of a suitable sampling/monitoring location;
  • Access, facilities and services required;
  • Safety considerations.

This guidance concentrates on the provisions that licensees should have in place when the EPA or its contractors carry out monitoring at the site. The guidance is also useful for licensee’s staff or its contractors when self-monitoring.

This guidance is a revision of the 2010 publication ‘Guidance Note No. 1 Air Emissions Sampling Facilities’. The changes from the previous version include:

  • The order of the chapters has been changed to reflect the sequence in which air emissions monitoring would be carried out;
  • The relevant Health and Safety legislation has been updated;
  • Recommendations for escape routes have been included;
  • Guidance on compliance of EX rated areas (areas where there is a risk of explosion);
  • Further clarification on monitoring location and sampling ports requirements;
  • Further clarification on homogeneity requirements;
  • Guidance on monitoring from Biofilters.

The guidance has highlighted that the health and safety aspects of stack testing must always receive priority. The importance of monitoring environmental emissions should never be placed ahead of the health and safety of personnel whose job it is to conduct the monitoring.

The guidance covers the following topics:

  • Irish Safety, Health and Welfare Law: This section includes an overview of relevant Irish law.  There are various legal responsibilities relating to Safety, Health and Welfare for the parties involved in the monitoring. Included are the general duties of the stack testing organisation as an employer, the general duties of field staff as employees, the general duties of the licensee as a host site and the work at height regulations (S.I. No. 299 of 2007);
  • Aspects of Safety, Health and Welfare that are particularly relevant to stack testing: This includes escape routes, lone working, the Safe Pass Programme, PAT testing, the use of compressed gases, lifting and the Source Testing Association;
  • The Risk Assessment process;
  • Access Facilities and Services: This section includes guidance on access to sampling location, the services that need to be present, the need for the host site to make staff available to assist with the monitoring activity, the importance of conducting a site review in advance, the purpose of a site review, EX rated areas and persons in charge;
  • Sampling Location and Sampling Ports: This includes how the types of pollutants to be monitored will influence the required layout of the sampling location and the design of sampling ports;
  • EPA Independent Monitoring: This includes information on the EPA independent monitoring programme, the powers of authorised persons and the arrangements the licensee must have in place in anticipation of an unannounced Agency visit.

A focal point of inspector’s site visits and audits has been the safe and permanent access to all sampling and monitoring points. Should there be a failure to comply, enforcement action may be taken.

The Irish Standard I.S. EN 15259:2007 outlines current best practice on topics such as sampling locations, sampling ports, representative sampling, etc. but does not address Safety, Health and Welfare. All new plants, and changes to existing plants, that effect the facilities for air emissions monitoring must have regard to this standard as well as the guidance document.

The guidance includes a checklist to establish the suitability of an emission point for sampling.

To read the guidance in full click here.

May 2020