Before you measure, think.

Measuring our emissions, discharges or characterizing our waste is not a complex task, but it is a delicate one. Sometimes in our work we find ourselves with meaningless OCA (Accredited Control Body) measurements, with a surreal volume of parameters or excessively short of them, even with inconsistent results or with ill-considered sampling, without anyone having done anything about it. In fact, there are the most occasions that we find that regulatory measures are not even opened or browsed by the company, but go directly to the environmental paper drawer without being useful for anything else, something that in any case is nothing more than a waste of time, money and resources.

Measuring and not verifying the results obtained is like taking the company's annual medical checkup and not worrying more than if you are “Fit” or “Not Suitable”, without even seeing how your analytical results are.

However, the control of emission parameters, discharge, or even periodic waste analysis, can be very interesting, useful and even serve as a tool for the early diagnosis of the process itself and the prevention of future problems in it, as long as they are done with knowledge of the facts and carrying out a logical reasoning of what we want, need and are going to do.

Below we offer you a series of basic premises to be taken into account by any environmental manager, professional in the sector or manager, so that regulatory controls are useful, profitable and fruitful for your company:

What am I going to measure?

This is the first question to ask if you have to carry out some measurements, and although it may seem simple, it is a poisoned question because what we are going to measure at the focus or spill point of our company may depend on two factors:

• On the one hand, his thing is that we measure according to the process that gives rise to the emission or discharge to be controlled, establishing the pollutants that are expected to emit depending on the characteristics of the same.
• On the other hand, your thing is to measure what the regulations and/or environmental authorization issued by the competent body tell us, so that we can demonstrate that we comply with what they ask of us and we are in a situation of legal compliance.

Although it would be your thing, both factors do not have to coincide, and in fact on many occasions this is the case. We have seen processes that were aimed at measuring parameters that it was not possible for them to emit (we have had clients in plasterers who were required to measure SO2, something technically impossible) and we have seen processes that emitted pollutants that were never required by regulations or by the competent body, whose control was however crucial for the environment and the company.

Our advice at this point is threefold: Measure what you have legally established, complain to the competent body with sufficient technical grounds what you don't need to measure, so that you save significant money that you can use on other issues, and extend your measurements to those additional parameters that provide you with information about the operation of your process and its real impact on the environment.

How am I going to measure it?

This is another question that seems obvious and that everyone overlooks, often leaving this responsibility to fall on the control body itself (OCA), which often applies its standard procedures, the applicable regulations and little else (after all, that is all its responsibility).

And it's not that we think that the OCA cannot advise the company, because we are aware that they are the best support for this and in fact we always count on their assistance and opinion when we advise our clients, but it is that the company's environmental manager is the only one who can set the guidelines since:

• Only he knows what concentration is expected to emit for the different pollutants, an aspect that fundamentally marks in many cases the sampling and/or determination technique to be used. It will not be the first analysis in which we see a high number of parameters below the measurement threshold of the technique, when they have surely cost a lot of money.
• Only he knows under what conditions the gases or discharges come out at the sampling point, and therefore, he is the only one who can establish the basis for the technique to be used in each sample. Emissions with a high percentage of moisture can ruin, for example, certain sampling techniques.
• Only he knows what it is necessary to characterize and why at each moment, since only he knows how the process works and what parameters are representative.
• Only he knows what the original process of the emission or discharge is like, if it has cycles, if it is continuous, if it is stopped or starting up, if it is operating under normal conditions or needs to characterize some additional mode of operation, etc.

Our advice: Study your emissions and discharges beforehand, and require the supervisory body to measure what you say, as you say it, and the moment you say it, thus ensuring that the measure is useful and representative.

Will I be able to measure it?

As the famous TV sketch said, “if you have to go you go... but go for nothing...”. We must remind you that it is the company's responsibility to always have the emission bulbs and sampling boxes duly enabled for taking samples and measuring parameters, complying with all the requirements that are applicable to it by the regulations in force regarding accesses, equipment, sampling points, dimensions, etc.

Nor does it hurt to check that all the processes with emissions or discharges that we are going to measure the day the OCA comes

All the OCA must do on the day of the visit is to verify that the bulbs are properly enabled, and it will not be the first time they tell us that a control body has turned around on the same day of the visit, without measuring, charging the company for the trip, and without having the proper results because the bulbs were not properly enabled or because the bulb in question caused problems.

Our advice: Take a good look at the conditions of your bulbs and processes, and ensure that everything is in order before the OCA comes to measure.

Which OCA will be best to measure?

As we already told at the time in our “10 Basic Principles for the Environmentally Responsible”, we believe that the best thing is that there is no commitment to anyone, and that the person responsible for the environment has sufficient capacity to search for the OCA that best suits their technical and economic needs.

In Spain, as in many other countries, there are regulations that regulate and accredit these inspection bodies based on different standards, and you can find the OCAs that best suit you in each case on the website of the corresponding accreditation body, such as ENAC. It may also be necessary to ensure that said OCA is recognized by the competent environmental body, and it would even be interesting to go to this type of source to find useful references on the work carried out by these bodies.

Experience is also a degree, so consult and let yourself be advised by colleagues in the sector to see which OCA works best and gives the most guarantees, then ask everyone for offers to see what they give you and how much they ask for... of course, as in any other sector, don't be fooled by impossible discounts or surreal offers that have little or nothing to do with your process. Mark the fundamental times and conditions of your request and check that all your requirements are met when the offer arrives.

Our advice: Don't marry anyone, ask for offers from everyone and check the conditions they give you for measurement, both economic and technical, to choose the offer that best suits what you need with the cheapest price.

What to do when they come to measure?

In addition to letting them in (and even if it sounds like a joke, this is also part of our long experience), his thing is to accompany the OCA to:

• Ensure that everything is in compliance and that all necessary means are available to carry out the measurements.
• Accompany and record the actions carried out by the OCA, the observed in situ results and the operating parameters of the processes at all times.
• Resolve any doubts or queries you may have on the fly, clarify procedures and possible measurement requirements, and share as much information as possible about the controls.

At the time of the measurements, it is when more information must be collected both on the work carried out and on the state of the processes, information that will be vital for subsequent work and phases.

Our advice: Accompany the OCA during the visit and be proactive and collaborative to get the most out of it and information during the measurements.

And now that I have my measurements what?

As we said at the beginning of this post, to measure and not verify the results is to leave an important job of controlling and monitoring the production processes and the center itself, which causes the act of inspection itself to lose much of its meaning, assuming only an environmental procedure to overcome that is very expensive for the company.

Once we receive the measurement report from the OCA, and with the information that was collected during the measurements, your thing is for us to carry out a thorough analysis of the document to:

• See if any limit value is exceeded or if any legal requirement is breached, as is logical, and if these breaches are adequately described and recorded based on the uncertainty of the measure and other relevant factors.
• Check that all our requirements and requirements for measurement have been met.
• Ensure that the basic calculations associated with the report have been properly performed.
• Analyze, in contrast to the data from the collected production processes, how the fluctuations in the recorded process parameters have influenced the emission values, seeking the correlation and explanation of the recorded phenomena.

Our advice: Don't miss the opportunity to learn more about your processes and their potential for improvement through your regulatory controls.