As an operator with a permit from a licensing authority performing the atmospheric emission license function under the National Environmental Management Air Quality Act, 2004 (Act No.39 of 2004), you will be aware that it requires you to ensure the monitoring of process emissions is performed correctly to ensure your emissions are within the permitted limits. The requirements are governed by:
a. The National Environmental Management: Air Quality Act, 2004;
b. The National Framework for Air Quality Management in the Republic of South Africa;
c. National Ambient Air Quality Standards;
d. Listed Activities and Associated Minimum Emission Standards
Where third party organisations are used to conduct this monitoring, it is a National Environmental Management requirement that the organisation holds accreditation to ISO/IEC 17025 for the monitoring to be performed.
Many organisations provide stack emissions monitoring services. Selecting a company accredited by the South African National Accreditation Service (SANAS) to ISO/IEC 17025 for Emission Testing and Ambient Air Monitoring is the best way to ensure you use a competent organisation that will both understand and meet not only your requirements but also those of the National Environmental Management: Air Quality Act, 2004.
Accreditation to ISO/IEC 17025 provides an independent and authoritative declaration that the Emission Testing and Ambient Air Monitoring organisation carrying out the the emissions monitoring has the people, facilities, equipment, technical expertise, management systems and track record to undertake the activity professionally and competently and with full traceability to international reference standards.
The ISO 17025 accreditation process
ISO 17025 accreditation is a rigorous and ongoing assessment of Emission Testing and Ambient Air monitoring activities to establish that:
- The organisation is impartial
- The organisation employs technically competent staff
- The organisation uses technically suitable sampling methods as prescribed by the Air Quality Act, 2004(Act No. 39 of 2004); refer to our schedule of accreditation https://www.sanas.co.za/certificate%20Published/T0846-06-2019.pdf, covering EPA, EN/BS and ISO stack monitoring standards.
- The organisation has the appropriate resources, equipment and facilities
- The organisation meets the requirements of ISO 17025.
Technical competence
The organisation must demonstrate that individuals carrying out Emission Testing and Ambient Air Monitoring are technically competent to do so and that methods and equipment are valid and fit for purpose.
This includes:
- Competent staff authorised and fully trained in all relevant stack monitoring activities
- Robust internal training
- Routine competence monitoring
- Regular technical internal auditing by qualified auditors
- Regular participation in recognised proficiency testing schemes
- Traceability to international reference standards
- Equipment calibrated with traceable standards and meets the EPA, EN BS and ISO standards as per their schedule of accreditation
- Verification and demonstration of ability to perform methods to National, European, International and Environment Agency specified standards.
Independence, Impartiality and Integrity
The organisation must demonstrate that:
- All emissions monitoring work is carried out independently and impartially
- Staff are free from undue financial, commercial or other pressures that may adversely affect the quality of work
What are the risks of using a stack emissions monitoring organisation that is not accredited to ISO/IEC 17025
- Inexperienced staff – competence is built on qualifications, knowledge and experience
- Insufficient resources leading to inadequate and incomplete monitoring work and the possibility of incorrect test results being reported
- Regulator refusal or query of reports
- A lack of impartiality
- No recourse ( no formal complaints procedure, no accountability to SANAS or the competent authority)
- Lack of due diligence/exposure to future claims
- Use of inappropriate sampling and analysis equipment
In summary:
With due consideration to the due diligence/exposure as mentioned, you are assured of quality results at all times upon utilising a reputable organisation that has been accredited to the requirements for Emission Testing and Ambient Air Monitoring to ISO 17025 requirements.
License holders and plant operators cannot afford the risk of non – compliance and the very real possibility of severe financial penalties, suspension of operations and jail sentences for those responsible for environmental due diligence and care as a result of utilising questionable data obtained by non accredited service providers.