Agency proposes new shift to self-monitoring by industry

The Environment Agency has published proposals for a scheme to assess the quality of companies' self-monitoring work, and targeting its own monitoring on sites with poorer scores.1 The effect will be to reduce the overall amount of independent monitoring - with the best-rated operators receiving no monitoring visits from the Agency at all.

The new scheme will initially cover emissions to air only, although the Agency intends to extend it to releases to land and water in due course.

Most emission monitoring under integrated pollution control (IPC) is already done by companies. The Agency audits their data through independent check monitoring visits commissioned from consultants, and the costs - some £2.5 million per year - are recovered from regulated businesses.

The system is unpopular with industry, which gripes about the cost and bureaucracy involved. Meanwhile, the Agency's management is keen to expand risk-based regulation, freeing up resources for more targeted inspections and for use elsewhere.

The new scheme - called "operator monitoring assessment" (OMA) - will score companies on their monitoring performance according to six criteria, including: management and training of staff, fitness for purpose of monitoring methods, maintenance and calibration of equipment, quality assurance of equipment and procedures and performance against emission limits.

It is similar in principle to the "operator performance risk appraisal" (OPRA) scheme, now being applied under IPC (ENDS Report 271, pp 32-33 ) and waste management licensing (ENDS Report 305, p 46 ).

Processes with a poor OMA score will receive more check monitoring than those with a good one. The Agency has piloted the scheme with 45 companies across various sectors. Sites involved included ICI's former Runcorn operation, Anglesey Aluminium and TXU's Rugeley power station.

Martin Bigg, the Agency's head of process industries regulation, told ENDS that around 35% of IPC processes currently receive check monitoring visits each year. "OMA will help us focus that effort where it is most needed, by providing a robust tool to indicate the quality of monitoring levels and help inspectors target the check monitoring programme," he said.

However, Mr Bigg revealed that implementation of OMA would lead to a reduction in the overall amount of check monitoring - and that some sites with good OMA ratings may receive no such visits at all.

Mr Bigg emphasised that the Agency's effort would not be determined solely by OMA scores. "OMA is just one element - an indicator," he said. "Inspectors will maintain their discretion, based on their knowledge of the operator, and this will provide a safety net."

However, the proposals do not appear to be based on any formal assessment of how useful check monitoring has been in auditing companies' self-monitoring procedures and data - or what the effect might be if check monitoring was cut back. This is despite the Agency having several years of check monitoring results.

Mr Bigg said it was very unusual for check monitoring to reveal any significant differences with self-monitoring data. There have been some notable exceptions, including the deliberate falsification of monitoring data at a Leigh Environmental landfill (ENDS Report 300, pp 22-24 ). The Scottish Environment Protection Agency has also reported several cases where operators' reported monitoring results were widely at variance with its own checks.

The implicit assumption that companies with a good OMA score will have consistently sound monitoring data is not discussed in the consultation paper. Some of the question-marks surrounding the issue mirror those being debated in connection with environmental management standards.

A series of recent prosecutions of companies certified to the EMAS and ISO14001 standards has thrown into doubt the premise that apparently well managed firms deserve a lighter regulatory touch (ENDS Report 309, pp 19-22 ).

Mr Bigg said that OMA scores will not be made public for the time being. But in the longer term, OMA is likely to be merged into OPRA, the scores for which will be made public for the first time in April 2002.

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