COVID-19 Regulatory Position Statement released by Environment Agency for monitoring of air and water emissions.

In a COVID-19 Regulatory Position Statement (RPS), released by the Environment Agency on 16th April, holders of installation, waste or radioactive substances activity permits have been advised that they “can make certain reasonable adjustments (such as delays or reschedules)” to environmental monitoring requirements should they be unable to comply due to COVID-19 restrictions.

mcerts flow meter systems

 

Specifically the RPS states:

  • Written agreement must be obtained from the EA prior to making use of the COVID-19 RPS via email from your area regulatory officer or site inspector
  • The holder must be able to show that they have taken all reasonable steps to comply with monitoring conditions, with explanations for non-compliance
  • This RPS does not apply to any other activity, even if under the same legislation.  Other permits or licences must be obtained for other activities.
  • If monitoring continues and a holder becomes aware of exceeding any limit value, they should still notify the EA immediately
  • You must comply with all the other requirements in your environmental permit unless they are covered by another COVID-19 RPS.
  • This COVID-19 RPS will be withdrawn on 30 June 2020 unless we extend it. After this date you must comply with your permit.

Monitoring Emissions to Water

With regards to monitoring emissions to water, periodic monitoring may be delayed if a permit holder:

  • Has staff shortages due to COVID-19
  • Has restricted access due to infection/risk of infection to people/places
  • Has restricted access to external laboratories

Guidance has been issued that the following alternatives should be considered:

  • Use of alternative tests e.g. (onsite chemical oxygen demand or total organic carbon measurements)
  • Emissions being calculated based on other parameters
  • If no alternative monitoring solution can be found, then the holder must contact the EA to discuss options
  • Samples that can not be analysed should be kept in suitable conditions for analysis at a later date

 

Monitoring Effluent Flow

  • Certification/Recertification of MCERTS for flow monitoring may be delayed but it must be rescheduled as soon as possible.
  • Any QM system reassessment audit should be considered for remote auditing with your assessor.
  • On-site maintenance of flow monitoring systems should be continued wherever possible.

 

All delays/reschedules should be risk-assessed for their impact to human health and the environment, which the holder must demonstrate that they are continuing to protect. For any waste operations monitoring the holder is required to not cause; a risk to water, air, soil, plants or animals; a nuisance through noise or odours; any adverse effect to the countryside or places of interest such as conservations areas and Ramsar sites.

Logging and Recording of Events

Any reasons for missing samples should be noted in the next monitoring return and all reschedules should be implemented as soon as possible – though seasonal sampling to replace missed collections does not need to be carried out.  Any collected samples that can’t be analysed should be stored for later analysis where possible.

Permit holders must also maintain records for 24 months to show the reasons why the COVID-19 RPS was used.  For example, records of:

  • staff absences
  • contractors being unavailable
  • supply chain failures

What to do if you have questions

The Environment Agency intends to monitor the use and compliance of this COVID-19 RPS through inspection and monitoring activity and are available for support and guidance.

At SIRIS we are continuing to deliver service, maintenance, inspection and installation requirements for our clients.  We are able to quickly adapt our working practices to individual site social-distancing requirements, in addition to our own, in-house rigid social distancing working methodology.  We are also working with clients for flexible and innovative solutions to waste flow monitoring during these challenging working conditions. 

Please talk to us if you have any concerns or questions about how COVID-19 may impact your ability to comply with your effluent flow monitoring requirements.