Manual Stack-Emission Monitoring

Performance Standard for Organisations

Environment Agency
September 2003
Version 4

Record of amendments
Version
number
2
3

Date

Section

August 2002
October 2002

Annex C
4.4.2

October 2002

5.4.1

October 2002

5.4.2

September 2003

Annex H

Amendment
Updated contents of Annex.
Deleted requirement for site-specific protocol to be
signed by process operator and competent authority
before carrying out monitoring.
Approval should be sought from the competent authority
if an organisation modifies a technical procedure to take
into account site-specific conditions. It is not essential for
the monitoring organisation to have obtained approval
before carrying out the monitoring.
Amended hierarchy of methods and added informative
note
Amended Annex H : Stack emission monitoring report

Foreword
The Environment Agency established its Monitoring Certification Scheme: MCERTS to
deliver quality environmental measurements. The scheme provides for the product
certification of instruments, the competency certification of personnel and the accreditation of
organisations based on international standards. The term organisation is used generically. It
includes commercial test houses, laboratories, and industrial operators in-house monitoring
arrangements. MCERTS is progressively being extended to cover all regulatory monitoring
activities.
MCERTS for manual stack-emission monitoring has been developed in collaboration with the
Source Testing Association (STA), the UK trade association representing manual emission
monitoring companies, the Scottish Environment Protection Agency (SEPA) and the
Environment and Heritage Service, Department of Environment, Northern Ireland.
The scheme is split into two components the certification of personnel and the accreditation
of organisations. This document provides the performance standard for organisations.
MCERTS requires stack-emission monitoring organisations to be accredited by the United
Kingdom Accreditation Service (UKAS) to ISO/IEC17025 for the MCERTS standard. It
provides an application of EN ISO/IEC 17025 in the specific field of measurement of air
emissions from stacks and covers:

ethical requirements for independence and environmental awareness;

use of MCERTS certified personnel;
selection of appropriate methods following international standards;
method implementation;
estimation of measurement uncertainty;
use of appropriate equipment;
planning of a sampling measurement campaign
- site review
- risk assessment
- site-specific protocol;
reporting of results;
participation in proficiency-testing schemes.

The standard does not provide a sectorial application for analytical laboratory methods but
does specify that any methods shall be accredited to the requirements of EN ISO/IEC 17025.
The MCERTS personnel competency standard is published as a separate but related MCERTS
document. It defines the standards for certifying stack-emission monitoring personnel as
competent based on experience, training and examination. Sira Certification Service (SCS)
operates the personnel competency scheme on behalf of the Agency and is accredited by
UKAS to European Standard EN45013: General Criteria for Certification Bodies Operating
Certification of Personnel.

The benefits of MCERTS for stack-emission monitoring are that it:

provides formal certification of personnel and accreditation of organisations in accordance

with European and international standards;
provides assurance to all stakeholders, including industrial process operators, stackemission monitoring personnel and organisations, regulators and the public, of the
reliability of stack-emission monitoring data;
establishes a level playing field in the competitive stack-emission monitoring market
based on the Agencys requirements;
sends a message that manual stack-emission monitoring is a critical component in
producing defensible data for regulatory purposes;
promotes and raises the professional standing of stack-emission monitoring personnel and
organisations by establishing 'quality standards' to which all should aspire and by which
all shall be judged.

If you have any questions regarding the accreditation process, or would like further
information on how to apply, please contact:
UKAS
21 47 High Street
Feltham
Middlesex
TW13 4UN
Tel: 020 8917 8400
Fax: 020 8917 8500
Email: info@ukas.com
Further information on MCERTS, including copies of the performance standards,
examination syllabuses and guidance, can be obtained from the Agencys website at:
www.environment-agency.gov.uk/business/mcerts/
If you have any general questions about MCERTS, please contact:
Environment Agency
National Compliance Assessment Service
Lutra House
Dodd Way, off Seedlee Road
Walton Summit
Bamber Bridge
Preston PR5 8BX

Stuart Newstead
Head: National Compliance Assessment Service
February 2002

Tel: 01772 714362

Fax: 01772 714360

Contents
Introduction

1.

Scope

2.

References

3.

Terms and definitions

4.

Management requirements

5.

Technical requirements

5.1

General

5.2

Personnel

5.3

Accommodation and environmental conditions

5.4

Test methods and method validation

5.5

Equipment

10

5.6

Measurement traceability

12

5.7

Sampling

12

5.8

Handling of test items

14

5.9

Assuring the quality of test results

14

5.10

Reporting the results

15

6.

Status of this document

16

Annex A - Environmental policy

17

Annex B - Health and safety

18

Annex C - Equipment calibration

21

Annex D - Site review

22

Annex E Site-specific protocol

23

Annex F - Work file

25

Annex G - Monitoring records

26

Annex H Stack-emission monitoring report

27

MCERTS performance standard for organisations carrying out manual

stack-emission monitoring
Introduction
Manual stack-emission monitoring for regulatory purposes includes measurements for:

determining compliance with numerical limits in authorisations and permits;

the calibration of continuous emission monitoring systems (CEMs);
acceptance trials on new pollution abatement plant or alternative fuel
applications.

Note - stack-emission monitoring is a general term used to describe the preparation work prior to a measurement
campaign, undertaking the site work, calculating the monitoring results and producing the final report for the
client.

The extension of MCERTS to include manual stack-emission monitoring is built on proven

international standards to ensure good quality monitoring data. The scheme is split into two
components the certification of personnel to the MCERTS personnel competency standard
and the accreditation of stack-emission monitoring organisations to the MCERTS
performance standard for organisations.
The general requirements for the competence of testing laboratories are described in the
International Standard EN ISO/IEC 17025. This contains all the requirements laboratories
have to meet if they wish to demonstrate that they operate a quality system, are technically
competent, and are able to generate technically valid results.
Note - laboratories are referred to as stack-emission monitoring organisations (organisations) throughout this
performance standard. This covers both independent monitoring organisations and those which have in-house
monitoring teams.

EN ISO/IEC 17025 recognises at para.1.6 Note 1 that it might be necessary to explain or

interpret certain requirements in this International Standard to ensure that the requirements are
applied consistently.
This MCERTS performance standard provides criteria for the application of EN ISO/IEC
17025 in the specific field of monitoring of emissions from stationary sources (for example,
chimney stacks). In producing this MCERTS standard, the guidance for establishing
applications for specific fields given in Annex B of EN ISO/IEC 17025 has been followed.
This standard does not re-state all the provisions of EN ISO/IEC 17025. Monitoring
organisations are reminded of the need to comply with all the relevant criteria detailed in EN
ISO/IEC 17025.
The clause numbers in this document follow those of EN ISO/IEC 17025, although the text
from this International Standard is not repeated. Where no additional requirements are
needed, this is stated.
This standard should be used in conjunction with its companion standard the MCERTS
personnel competency standard. This is available on the Agencys web-site at:
www.environment-agency.gov.uk/business/mcerts/.
Page 1 of 28

Scope

1.1

The monitoring of stack-emissions is often called measurement, testing or sampling.

In this document, the term monitoring is used except where the specific meanings of
the alternatives are more appropriate.
The manual monitoring of stack-emissions can involve taking samples for laboratory
analysis, the in-situ determination of flue gas physical parameters such as temperature,
pressure and flow rate, and of particulate loadings by isokinetic sampling, and the insitu periodic instrumental monitoring of pollutants. This form of monitoring stackemissions is widely used, particularly where continuous emission monitoring
instruments are not available or are judged to be inappropriate for reasons of cost or
technical application. Its primary use is for regulatory purposes, including
measurement for determining compliance with authorised numerical limits, calibrating
continuous emission monitoring systems and acceptance trials on new pollution
abatement plant.
The monitoring of emissions from stationary sources can be undertaken for a wide
range of substances using various standard methods. Details of standard methods are
provided in the Agencys Technical Guidance Note M2. The methods organisations
are accredited to monitor under EN ISO/IEC 17025 for the MCERTS performance
standard shall be defined in their scope of activities.

1.2

This document is applicable to all organisations performing monitoring of emissions

from stationary sources.

1.3

No additional requirements to EN ISO/IEC 17025.

1.4

Accreditation of organisations to this performance standard will demonstrate that they

meet the UK environment agencies MCERTS requirements for regulatory monitoring
of stack-emissions from stationary sources.

1.5

The MCERTS standard contains both technical and health and safety requirements.
Compliance with regulatory and safety requirements on the operation of laboratories is
not covered by EN ISO/IEC 17025. However, carrying out stack-emission monitoring
is hazardous (for example, working at heights, lifting equipment, exposure to
chemicals); and, if correct health and safety practices are not adhered to, the quality of
the monitoring is often compromised.
Note - The health and safety requirements are set out to ensure that organisations have a health and
safety management system and are following safe systems of work (for example, undertaking risk
assessments). UKAS will audit whether these systems are in place it is not auditing the adequacy of
the systems. However, if UKAS assessors observe poor health and safety practice they will inform the
Agency. The Agency will then inform the relevant site inspector and the local health and safety office.

1.6

No additional requirements to EN ISO/IEC 17025.

Page 2 of 28

2.

References

BS EN ISO 14956/2001 Evaluation of the suitability of a measurement method by comparison

with a stated measurement uncertainty.
EN 45013 European Standard for bodies operating certification of personnel.
Hazards, Risk and Risk Control in Stack Testing Operations, Source Testing Association
document HS1069-00 (updated frequently).
EN ISO/IEC 17025:2000 General requirements for the competence of testing and calibration
laboratories.
MCERTS Personnel Competency Standard, Environment Agency, 2002.
Technical Guidance Note M1, Sampling Requirements for Monitoring Stack-Emissions to Air
from Industrial Installations, Environment Agency, 2002.
Technical Guidance Note M2, Monitoring of Stack-Emissions to Air, Environment Agency,
2002.

3.

Terms and definitions

Competent authority organisation responsible for implementing environmental legislation

(for example, in England and Wales the Environment Agency, in Scotland the Scottish
Environment Protection Agency (SEPA) and in Northern Ireland the Environment and
Heritage Service).
Conformance testing measurements and evaluations carried out on an instrument and/or
equipment to determine its compliance with a specified performance standard or requirements
(for example, in MCERTS product certification).
Emission-limit value the numerical limit on an emission (for example, mass, concentration),
that may not be exceeded during one or more periods of time. Emission-limit values may also
be laid down for certain groups, families or categories of substances.
Isokinetic sampling sampling at a flow rate such that the velocity and direction of the gas
entering the sampling nozzle are the same as the gas in the duct at the sampling point.
Measurement campaign the scope of work required on a particular site for a specific time
period.
Measurement series successive determinations carried out at the same sampling plane, and
at the same process conditions.
Method Implementation Document document published by the Agency outlining its
interpretation of the standard method.
Overall field blank a measurement sample taken at the plant site in an identical manner to
the normal samples in the series, except that no gas is sampled.
Page 3 of 28

Risk assessment an assessment of the health and safety hazards and associated risks
involved in stack measurement at a specific work location.
Sampling equipment equipment used to take samples of stack-emissions, instruments used
for direct reading of stack-emissions and instruments used to gather supporting information
on environmental conditions pertaining at the time of the measurements.
Sampling plane or sampling section a plane normal to the centreline of the stack at the
sampling position.
Sampling point specific position on the sample plane where the sample is extracted.
Sampling port holes in the wall of the stack through which access to the exhaust gas can be
gained.
Sampling position a suitable position on the plant where representative samples can be
obtained.
Site specific protocol - the installation specific application of an organisations technical
procedures. A protocol describes how the measurement method shall be employed in a given
situation. This may also be referred to as the measurement plan.
Site review a visit conducted by the organisation before undertaking stack-emission
measurements to ensure the physical and logistical situation is fully understood before
arriving on-site to conduct work. The review, sometimes referred to as a reconnaissance visit,
provides essential information for determining the appropriate measurement method and site
specific protocol and for carrying out a risk assessment.
Stack - structure through which pollutants are released to atmosphere. Chimney stacks are
intended to be of sufficient height to adequately disperse emissions in the atmosphere.
Measurement of emissions may also be undertaken in ducts, flues and vents.
Stack-emission monitoring organisations organisations that undertake the measurement of
emissions to air from stationary sources. This can include work undertaken at the laboratorys
permanent facilities, at sites away from their permanent facilities and in temporary or mobile
laboratories.
Standard conditions gas pressure, temperature constants and moisture conditions to which
measurements are referenced (101.3kPa; 273K; dry gas). Gases may also be referenced to
standard conditions of oxygen.
Stationary sources fixed position industrial processes from which emissions to air via stacks
are made.
Technical procedure the organisations detailed written procedures on how to perform a
method in line with its quality system.
Testing is used in EN ISO/IEC 17025 to describe the routine methodical assessment of an
entity. Testing may include sampling, measurement and monitoring. In this document the
Page 4 of 28

term monitoring is used except where the alternative is more appropriate. Also see
Conformance testing.
UKAS the United Kingdom Accreditation Service, the body appointed by the Government
to assess and accredit organisations that provide testing services to international standards, for
example EN ISO/IEC 17025.
Work file a file in which details of the stack measurement campaign for an individual site
are recorded.

Management requirements

4.1

Organisation

4.1.1 4.1.2

No additional requirements to EN ISO/IEC17025.

4.1.3

The management system shall stipulate that analysis of substances in a laboratory shall
be undertaken by a laboratory that holds accreditation to EN ISO/IEC 17025 for the
relevant method.

4.1.4

Stack-emission monitoring shall be carried out by an organisation that is free from any
commercial, financial and other pressures that might influence their technical
judgement. Industrial process operators using in-house monitoring teams shall have
management structures that ensure this requirement is met.
The results of all monitoring carried out for regulatory requirements shall be reported
by the monitoring organisations to their customers (that is, to industrial process
operators or the competent authority). This requirement includes results showing noncompliance as well as compliance with emission-limit values.
Authorisation for any departures from an organisations documented policies and
procedures shall be obtained from the competent authority.
An organisation shall have an environmental policy in place and take management
action to minimise the environmental impact of its operations.
Note Annex A provides details of good practice.

An organisation shall implement a health and safety policy addressing the hazards and
associated risks to health and safety in the activities associated with stack-emissions
monitoring. Organisations shall meet the requirements specified in Annex B.
4.1.5

No additional requirements to EN ISO/IEC17025.

4.2

Quality system

4.2.1 Documents specific to the monitoring of stack-emissions shall include:

a)

standards published by national and international standards making

organisations;
Page 5 of 28

b)
c)

d)
e)
f)
g)
h)

MCERTS Method Implementation Documents (MIDs) outlining the Agencys

interpretation of standard methods;
technical procedures providing detailed instructions on how standard methods
and any MCERTS MIDs, including guidance on implementation in Technical
Guidance Note M2, shall be performed;
a site review to ensure that the organisation understands the physical and
logistical situation before arriving on-site to conduct work;
site-specific protocols, which show how the technical procedures are to be
employed in a given situation;
a risk assessment detailing hazards and associated risks;
a work file detailing the stack measurement campaign for an individual site;
a standardised report providing sufficient detail to allow an audit trail back to
the on-site measurement and process plant operating conditions pertaining at
the time.

4.2.2 4.3.3.4 No additional requirements to EN ISO/IEC 17025.

4.4

Review of requests, tenders and contracts

4.4.1 - 4.4.5 No additional requirements to EN ISO/IEC 17025.

4.5

Subcontracting of tests (monitoring activities)

Organisations are permitted to subcontract monitoring activities to another
organisation accredited under MCERTS for that work. It is the responsibility of the
organisation to ensure that the subcontracted organisation is accredited under
MCERTS for the scope of work. If analytical work is subcontracted, it shall be to an
organisation that has accreditation to EN ISO/IEC 17025 for the scope of work.
Where individuals are employed on a subcontracted basis by an organisation, the
organisation shall ensure that the individual is certified under the MCERTS personnel
competency scheme to the required level.

4.6 4.11 No additional requirements to EN ISO/IEC 17025.

4.12

Control of records

4.12.1 General
4.12.1.1 No additional requirements to EN ISO/IEC 17025.
4.12.1.2 Records of all original observations, including process plant conditions such as
temperature, pressure, flow rate, feedstock, environmental conditions such as ambient
temperature, weather conditions and monitoring data shall be retained in accordance
with the requirements of the competent body.
4.12.1.3 4.14.2 No additional requirements to EN ISO/IEC 17025.

Page 6 of 28

Technical requirements

5.1

General
5.1.1 5.1.2 No additional requirements to EN ISO/IEC 17025.

5.2

Personnel
Monitoring organisations shall use personnel with the appropriate MCERTS
certification to undertake stack-emission measurement (see the MCERTS personnel
competency standard).
Note - the MCERTS standard defines three levels of competence - an entry level (trainee), Level 1
(technician) and Level 2 (team leader). Personnel with Level 2 certification are permitted to lead a
stack-emission monitoring team, and approve site reviews, risk assessments, site-specific protocols and
monitoring reports. Personnel with Level 1 certification are permitted to carry out stack-emission
monitoring as part of a team led by MCERTS Level 2 person. Trainees are only permitted to carry out
stack-emission monitoring under the direct supervision of MCERTS Level 2 person.

5.2.1 5.2.5 No additional requirements to EN ISO/IEC 17025.

5.3

Accommodation and environmental conditions

5.3.1

Stack-emission monitoring requires equipment, reagents and samples to be protected

from damage during storage and transportation from an organisations permanent site
to the sampling area.
Note - details concerning protecting the integrity of samples and reagents during storage and
transportation may be specified in the relevant standard method; these may include storage out of
sunlight and at specified temperatures.

5.3.2

Sampling shall be undertaken at a suitable location with suitable facilities (see Agency
Technical Guidance Note: M1).
Sampling is often undertaken at height in difficult conditions. A suitable platform
shall be provided that meets the size and safety requirements for the monitoring
exercise. Service requirements, such as electricity supply, shall also be taken into
consideration. Portable lighting shall be used when appropriate to ensure safe working
conditions.
The organisation shall have procedures in place to ensure that environmental
conditions do not affect the measurement result. For example, temporary shelter shall
be used when appropriate to protect personnel, equipment and monitoring operations
from weather conditions .

5.3.3

Stack-emission monitoring has a high potential for contamination of samples. The

organisation shall identify and assess the risk of contamination and a clean area shall
be available for setting up equipment and samples, recovering samples, and storing
equipment and samples.
Note a clean area may be defined in the sampling vicinity if the risk of contamination is low.

Page 7 of 28

5.3.4

Access to and use of areas affecting the quality of the monitoring shall be controlled.
If necessary, the area for equipment set up and the work area shall be cordoned off so
that access to the sampling equipment and monitoring operation is restricted. If
necessary, a mobile laboratory shall be manned or otherwise secure so access is
restricted at all times.

5.3.5

The work area shall be cleared of trip hazards and obstacles. Mobile laboratories and
transport vehicles shall be kept clean and free from sources of contamination.

5.4

Test methods and method validation

5.4.1

General
Monitoring shall, where possible, be carried out in accordance with appropriate
standard methods (see Technical Guidance Note: M2) and instructions on their
implementation.
The Agency is supplementing standard methods with Method Implementation
Documents (MIDs), where it is necessary to provide details on how the preferred
standard methods shall be used for regulatory monitoring.
The stack-emission monitoring organisation shall use written technical procedures
addressing the operation at the stack and the process conditions. The technical
procedures shall follow the standard method and the MID, where available, to provide
generic procedures for undertaking a method. The technical procedure shall state how
a method or group of methods shall be performed, providing supplementary material
clarifying technique, sampling and analysis policy, as well as detailed instructions on
how equipment shall be utilised, how data are to be recorded and how results are to be
reported.
Note - UKAS will accredit organisations for the technical procedures to ensure they follow the standard
methods, MIDs and the requirements of EN ISO/IEC 17025.

Site-specific protocols shall be used to detail the application of the technical

procedures to a specific site. Before conducting stack-emission monitoring, a person
certified to MCERTS Level 2 shall determine and propose a site-specific protocol that
is "fit for purpose" for the process and installation configuration. Approval shall be
sought from the competent authority if a standard method in an organisations
technical procedure requires modifying due to site-specific conditions.
If the method requires laboratory analysis of samples collected on-site the monitoring
organisation shall either be accredited for the analysis method to EN ISO/IEC 17025
or shall use another laboratory accredited for the method.
5.4.2

Selection of methods
The choice of measurement method shall be carried out in accordance with the
following standards and relevant documentation:

Agency Technical Guidance Note: M2;

Standard methods.
Page 8 of 28

If an appropriate CEN method is available, then this shall be selected. There is a

hierarchy of monitoring standards that shall be used in the following order of priority:

Comit European de Normalisation (CEN);

International Standardisation Organisation (ISO).

Note - when a CEN method is produced European Community member states must adopt it and any
equivalent method must be withdrawn. ISO methods are also commonly adopted, although this is not a
mandatory requirement.

If the substance cannot be monitored using methods covered by the above then a
method can be selected from any one of the following:

American Society for Testing and Materials (ASTM);

Association Franaise de Normalisation (AFNOR);
British Standards Institution (BSI);
Deutsches Institute fr Normung (DIN);
United States Environmental Protection Agency (US EPA);
Verein Deutscher Ingenieure (VDI).

When selecting a method, the organisation shall also take account of the following
restrictions:

the competent authority or legislation may specify the method for the specific
installation;
the suitability of the method (including the limit of detection) for determining
compliance with the emission-limit value.

Note the limit of detection may be stated in the standard method, if it is not stated it should be no
greater than 10% of the emission-limit value.

CEN Standards have often been validated for specific processes and conditions. These
may be used outside their scope of validation within specifications given in Agency
MIDs.
5.4.3

Laboratory developed methods

An in-house method developed by the organisation may be used in place of a standard
method if it is fully validated in accordance with the requirements of EN ISO/IEC
17025. The method developed by the organisation shall be validated to ensure it has
the equivalent quality to a CEN Standard method. Laboratory developed methods used
in place of standard methods shall be implemented using a technical procedure that is
UKAS accredited.

5.4.4

Non-standard methods
If a method requires developing to monitor a substance not covered by a standard
method, the organisation shall develop the method in accordance with the
requirements of EN ISO/IEC 17025. These methods shall be implemented using a
technical procedure which is UKAS accredited.
Page 9 of 28

5.4.5

Validation of methods

5.4.5.1 5.4.5.3 No additional requirements to EN ISO/IEC 17025.

5.4.6 Estimation of uncertainty of measurement
5.4.6.1 5.4.6.3
The organisation shall have procedures in place for providing an estimate of the
uncertainties relating to results.
The stated uncertainty of a standard method can only be achieved if the exacting
requirements of the standard method are complied with in full. When a standard
method is not complied with in full or a non-standard method is used, the following
approaches shall be used, depending on the situation to estimate uncertainty:

repeat measurements on reference materials;

experimental work, for example, repeatability experiments, paired comparisons
and ring tests;
estimations based on previous results/data e.g. instrument specifications,
calibration data, proficiency-testing schemes;
estimations based on considered judgement.

Estimating based on considered judgement shall be the method of last resort.

When there is no standard method available the organisation shall provide as much of
the above information as possible and calculate an estimate of the overall uncertainty
attached to the measurement according to ISO 14956.
5.4.7 5.4.8 No additional requirements to EN ISO/IEC 17025.
5.5

Equipment

5.5.1

No additional requirements to EN ISO/IEC 17025.

5.5.2

Procedures shall be in place to ensure that equipment is appropriate to the processspecific environment where it is to be used.
The equipment shall meet all the criteria specified in the standard method being used.
In cases where no equipment specifications are given, the equipment shall satisfy the
following requirements:

be non-reactive to the pollutant being monitored;

not cause any positive or negative interference to the monitoring operation;
have sufficient strength to withstand the environmental conditions (for
example, vibration, heat, shear forces, flex and abrasion) associated with the
process being monitored.
Page 10 of 28

Note specific requirements for equipment should be confirmed as part of the site review.

5.5.2 - 5.5.3 No additional requirements to ISO/IEC17025.

5.5.4

The identification of equipment shall be in an accessible location for viewing and it

shall be etched, stamped, or otherwise permanently fixed to the component.

5.5.5

A record of the monitoring and sites where stack-emission monitoring equipment has
been used shall be maintained.

5.5.6

EN ISO/IEC 17025 recognises that additional procedures may be necessary when

measuring equipment is used outside the permanent laboratory for tests and sampling.
Organisations shall have procedures in place to ensure that equipment transported to
site remains within valid calibration. If there is any doubt, the equipment shall be
calibrated on-site.
Leaks in sample trains shall be eliminated as far as practicable.
Where possible, mechanical connections shall be rigid and provide a positive seal
when tightened. Gasket material shall be non-reactive to the gas being measured and
able to withstand the prevailing operating temperatures without degrading.
Note - stack sampling equipment generally comprises several pieces of apparatus (for example, probes,
filters, traps, pumps, meters) connected together to form a sampling train. The equipment is connected
together on-site.

Contamination and deterioration of equipment shall be assessed and dealt with in a

planned manner. The specifications given in standard methods shall be followed. If
specifications are not detailed in a standard method, the following practices shall be
followed. Components and equipment exposed to the sample stream shall be
thoroughly cleaned and dried, including the sample media area, prior to conducting
sampling. If performing multiple runs with the same equipment, the sample train shall
be cleaned between runs. Cleaning shall be performed using appropriate methods,
tools and solvents to ensure that residue is removed and to prevent contaminating or
otherwise affecting the sample. The organisations technical procedure shall specify
the cleaning procedure.
5.5.7 5.5.9 No additional requirements to EN ISO/IEC 17025.
5.5.10 Before monitoring commences, the equipment shall be subject to operational and
quality checks in accordance with the relevant measurement standard.
Note - examples of good practice are given in Annex C.

5.5.11 5.5.1 No additional requirements to EN ISO/IEC 17025.

5.6

Measurement traceability

5.6.1 5.6.2.1.2 No additional requirements to EN ISO/IEC 17025.

Page 11 of 28

5.6.2.2 Testing
5.6.2.2.1 All aspects of the monitoring procedure shall be sufficiently prescribed and
implemented in a controlled manner so that the uncertainty of the results can be
determined in a valid and rigorous way.
The organisation shall hold nationally-traceable calibration artefacts (where available)
for all aspects of the monitoring process where inaccurate calibrations would affect the
validity of the overall measurement uncertainty of the results.
Note calibration gas mixtures are acceptable where they are obtained from a commercial company
with a calibration accreditation for the supply of the specific calibration gases required, or directly from
a recognised national standards laboratory. It is not necessary for gases obtained from a national
standards laboratory to be used for routine or everyday quality assurance/quality control checks, since
this may not be cost-effective. Instead, these should be used for regular checks on the concentrations of
more routinely used gas mixtures where these are utilised.

The organisation shall participate in proficiency testing or a similar intercomparison

activity where this is available, to demonstrate that the results obtained and their
measurement uncertainty are valid (see paragraph 5.9).
5.6.2.2.2 5.6.3.4 No additional requirements to EN ISO/IEC 17025.
5.7

Sampling (monitoring)

5.7.1

Stack-emission monitoring consists of sampling, analysis and reporting of results.

Note analysis may occur on site using a direct reading instrument or at a later date at an organisations
permanent facility or a subcontracted laboratory.

Sampling takes place as part of a measurement campaign. This requires a site review
and risk assessment to be carried out and a site-specific protocol to be produced.
Information specific to the measurement campaign shall be kept in a work file.
A measurement series shall be carried out under the conditions specified in the sitespecific protocol. The organisation shall obtain confirmation from the operator that the
process conditions specified were applicable during monitoring.
a) Site review
Stack monitoring personnel need to understand the physical and logistical situation
on-site before commencing work. Before stack-emission monitoring is undertaken, a
site review shall be undertaken and documented. This shall include an exchange of
information with the process operator to provide and obtain information relevant to the
work.
The review shall provide essential information for determining an appropriate
measurement method and developing a site-specific protocol. The review shall include
a risk assessment.
A person certified to MCERTS Level 2 shall approve the site review. This person,
however, need not be a member of the monitoring team. Information collected during
the visit shall be conveyed to the team before commencing work.
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Note 1 a person certified to MCERTS Level 1 is permitted to conduct a site review but only under the
direct supervision of the Level 2 person who approves the review (see MCERTS personnel competency
standard).

The monitoring work shall not commence until any remedial actions documented by
the site review have been implemented.
Note 2 it is advisable to allow sufficient time between the site review and the planned measurement
campaign for any remedial actions to be completed and to enable a detailed site-specific protocol to be
developed.

The site review may be abbreviated on repeat visits to the site once the organisation
has full knowledge/experience of the particular site, including the specific
requirements of the work in hand. However, a risk assessment shall be carried out at
the beginning of every visit.
To prevent any critical items being overlooked, the organisation shall prepare a
checklist of items that shall be evaluated. Annex D provides a list of items that shall
be evaluated and determined during a review and included in the organisations
checklist.
b) Risk assessment
An assessment of the hazards and associated risks involved in stack-emission
monitoring shall be undertaken and documented during a site review and before every
measurement campaign. The requirements specified in Annex B shall be followed.
c) Site-specific protocol
EN ISO/IEC 17025 requires a sampling plan to address the factors to be controlled or
monitored to ensure the validity of monitoring results. The sampling plan is referred to
as the site-specific protocol in this standard. A person certified to MCERTS Level 2
shall approve the site-specific protocol. The factors relevant to stack-emission
monitoring that shall be included in the site-specific protocol are contained in Annex
E. The site-specific protocol shall be updated, if required, to include feedback from
each visit.
Note when emission monitoring is undertaken for regulatory purposes, the site operator is normally
required to submit the site-specific protocol to the competent authority.

d) Work file
A work file shall be used to record the details of a stack measurement campaign. For
details required in a work file, see Annex F.

e) Monitoring record sheets

The organisation shall have procedures for recording monitoring data and operations
relating to stack-emission monitoring. Monitoring record sheets shall be used to
record this information. These shall be included as part of the final monitoring report.
For details required on monitoring record sheets, see Annex G.

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f) Blanks
When monitoring is undertaken requiring analysis of samples, sample blanks shall
also be analysed and reported. Many standards specify the procedure for blanks. For
methods where the taking of blanks is not addressed, instructions in the MCERTS
MID shall be followed, where available. Guidance on blanks is also available in
Technical Guidance Note: M2, which states that as a minimum an overall field blank
shall be produced for each measurement series and at least once per day.
g) Sample recovery
For certain techniques, samples need to be recovered at the end of the measurement
before they are analysed. In this case, sample recovery shall be carried out on-site
rather than at a permanent laboratory.
Sample recovery shall not affect the integrity of the result. Sample recovery shall be
undertaken according to the specifications of the standard method, MID and the
organisations technical procedure. The technical procedure shall state the reagents to
use (for example, water, toluene or acetone) and the cleaning technique (for example,
brushing or rinsing).
5.8

Handling of test items

5.8.1

The transport of stack gas from the stack to an analyser shall not affect the integrity of
the result.
Collected samples shall be maintained under environmental conditions that do not
alter the integrity of the result. For regulatory purposes, a chain of custody record shall
be maintained from the collection of samples, to sample storage, to sample analysis.
The record shall detail who has possession of the samples and the location of the
items.

5.8.2

In stack-emission monitoring, the test item includes the stack, which shall be
identifiable by a specific reference number. This number shall be consistent with any
identification specified by the competent authority and/or site operator.

5.8.3

Any deviations from a method caused by stack sampling facilities not conforming to
the method requirements (for example, access restricted to one port) shall be recorded.
Platform specifications are contained in Technical Guidance Note: M1.

5.8.4

No additional requirements to EN ISO/IEC 17025.

5.9

Assuring the quality of test results

Proficiency-testing (PT) schemes shall be used where available.
Note - current schemes include:

the instrumental analysis of standard gas mixtures;

the use of a reference device with known operational characteristics to determine the proficiency
of measuring physical parameters such as flow, velocity, temperature and the like;

the use of monitoring sites with known characteristics;

the use of a flow-testing scheme.

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The results obtained from such PT schemes are a snapshot of the organisations
capabilities, and shall be used to assess whether the organisation is complying with its
claimed measurement uncertainties. This information shall be made available to
UKAS, which will keep the competent authorities informed. If these are noncompliant, the organisation shall take steps to ensure adequate improvements are
implemented.
5.10

Reporting of results

5.10.1 General
A standard report format shall be used for regulatory compliance monitoring.
5.10.2 Test reports (monitoring reports)
A monitoring report shall include a description of the condition of, and unambiguous
identification of, the item(s) monitored. An organisation shall unambiguously identify
the substance, material or product measured. This refers to the stack and the stack gas
being sampled. A stack shall be uniquely identifiable. A diagram of the stack
dimensions shall be included in the report.
Stack-emission monitoring results shall be reported at standard reference conditions of
temperature and pressure. It may also be necessary to report stack-emission
monitoring results as a dry gas and at reference oxygen concentrations. The reference
conditions shall be recorded on a stack-emission monitoring report.
For information required in a monitoring report see Annex H.
5.10.3 Test reports (continued)
5.10.3.1 The organisation shall confirm with the site/process operator that the process
conditions under which sampling has occurred meet the requirements stipulated in the
site-specific protocol (the exact requirements are normally specified by the competent
authority in the permit). The monitoring report shall confirm that the requirements
have been met. For details of the types of process conditions that shall be recorded,
see the report template in Annex H.
The monitoring report shall specify the conditions (temperature and pressure) of the
stack gas being sampled and supporting environmental conditions.
5.10.3.2 No additional requirements to EN ISO/IEC17025.
5.10.4 No additional requirements to EN ISO/IEC17025.
5.10.5 Opinions and interpretations
Reports detailing results of regulatory compliance monitoring shall not contain
opinions or interpretations on whether the results demonstrate compliance or not with
emission limit values.

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5.10.6 5.10.9 No additional requirements to EN ISO/IEC 17025.

Status of this document

6.1

This MCERTS performance standard may be subject to review and amendment

following publication of this document. The latest version of the standard, together
with guidance on the scheme, is available on the Agencys website at:
www.environment-agency.gov.uk/business/mcerts/.

6.2

If you have any questions regarding the accreditation process, including how to make
an application, please contact UKAS at the address given in the foreword to this
document.

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Annex A - Environmental policy

A1

Good practice should ensure that the organisations activities do not harm the
environment.

A2

Stack-emission monitoring organisations should conduct their activities and operations

to reflect best environmental practice. This can be achieved by implementing an
environmental management system to pursue sustainability and continuous
improvement, as well as seeking ways of meeting environmental objectives.

A3

Particular care should be taken with the use of chemicals required for stack-emission
monitoring.

A4

The environmental policy should address the following:

use of fuel-efficient vehicles;

refrigeration in vehicles should use coolants that do not harm the environment;
sample containers should be recycled wherever possible;
reports should be on 100% post-consumer waste paper or in electronic format
if acceptable to the clients requirements;
batteries for sampling equipment should be rechargeable and (where possible)
recyclable;
equipment to be returned to manufacturer at end of useful life to be
disassembled and parts re-used where possible;
calibration and cleaning of equipment should avoid using solvents contributing
to ozone depletion/global warming.

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Annex B - Health and safety

B1

Relevant safety guidance shall be followed, for example, Agency Technical Guidance
Note: M1, STA publication Hazards, Risk and Risk Control in Stack Testing
Operations.

B2

The monitoring organisation shall implement procedures to minimise health and safety
risks during site work. The procedures shall include:

B3

using a risk-management approach to site work;

compliance with care of substances Control of Substances Hazardous to Health
(COSHH);
site-safety induction training;
safe systems for lone and remote working.

Equipment used on-site by the organisation shall meet all the necessary safety
standards required. Monitoring personnel shall use appropriate lifting equipment. As a
minimum personnel shall wear safety glasses and steel toe-capped footwear
conforming to appropriate standards while undertaking stack-emission monitoring.
Note equipment used on-site by the monitoring organisation also includes any of the operators
equipment they may use (for example, lifting equipment).

B4

Appropriate control measures (for example, safe working procedures, local exhaust
ventilation and personal protective equipment) shall be detailed in the organisations
technical procedure for the relevant methods.

B5

The monitoring organisation shall undertake and document a risk assessment specific
to the required work and sampling location. This shall be undertaken in three stages:

as part of a site review;

before pre-sampling preparation in the laboratory;
before to on-site monitoring.

B6

The site review risk assessment shall include a section that shall be completed before
entering the area of work. This shall be used by the monitoring organisation to find out
standard site safety information such as fire alarms and procedures, chemical hazard
alarms and procedures, intrinsically safe working areas, hygiene regulations and the
like. This information may be covered in a formal site induction or a permit to work
system. On sites where these are not available, it is the responsibility of the person
certified to MCERTS Level 2 (team leader) to obtain the information.

B7

The monitoring organisations risk assessment shall confirm that the site/process
operator has the following elements in place before undertaking stack-emission work:

B8

a safety policy covering work on site in accordance with the requirements of

the Management of Health and Safety at Work Regulations;
a safe sample platform and work area.

Monitoring personnel visiting or working on a site for the first time shall attend a site
induction if provided by the site operator. Attendance at an induction shall be recorded
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on the risk assessment for each member of the monitoring team.

B9

The risk assessment shall include an assessment of the level of risk from each of the
various hazards present and as a minimum shall include:

B10

general site hazards site traffic, fire and emergency, mechanical operations,
chemical operations;
physical hazards at the stack lifting, falling, burns, electricity, compressed
gases;
chemical hazards at the stack exposure to substances from flue gases,
exposure to substances used in monitoring tests;
weather and environment temperature extremes, wind, rain, lightning, snow
and ice, sunburn;
chemical hazards at the laboratory exposure to chemicals used for equipment
and sample preparation.

The risk assessment shall also include:

a COSHH assessment of exposure to workplace substances (both laboratory

and on-site);
information on the composition and pressure of the gas in the stack to be
monitored and the process characteristics;
identification of the control measures are required to reduce exposure to an
acceptable level.

B11

Organisations that undertake lone working on-site shall incorporate safety procedures
into the risk assessment (for example, use of personal alarm, regular contact with site
personnel).

B12

The risk assessment shall clearly show the hazards for each working area (for example
monitoring position, stack and the like).

B13

The risk assessment shall include whether the risk is negligible, as low as is
reasonably practicable (ALARP) or unacceptably high. The level of risk shall be that
recorded at the time of assessment, not the level that would be the case if control
measures were put in place.

B14

The operator shall be shown the risk assessment and be given the opportunity to
comment on it. For in-house teams, a representative of the operator not directly
involved in the work shall be shown the risk assessment. Typically, this could be the
environmental manager or safety manager.

B15

Work shall not commence until the organisations risk assessment confirms that the
risks are ALARP, or control measures have been put into place (including those that
are the responsibility of the operator) to reduce the risk to an acceptable level
(negligible, ALARP).

B16

Before work commences, the risk assessment shall be communicated by the Level 2
person (team leader) to other members of the monitoring team. All team members sign
the risk assessment to confirm they have seen and understood its content.
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Annex C - Equipment calibration

The following gives details of good practice regarding the on-site calibration of stackemission monitoring equipment.
C1

Equipment should undergo operational checks to ensure it is functioning correctly

before and during use (for example, correct indicator lights on analyser, pump
operating, heated sample line at correct temperature).

C2

Instruments that are subject to calibration shifts during transport or during monitoring
should be subject to on-site calibration. In such cases it is not sufficient to reference a
calibration made in the laboratory before taking the instrument to the site.

C2

Instruments used to measure physical parameters (for example, flow meters) should, if
appropriate, be checked on-site against a known standard such as a critical orifice.

C3

The range of instrumental analysers should be selected to ensure that, as far as

practicable the upper point of the range is twice the emission limit value for the
substance being measured.

C4

Instrumental analysers are calibrated using a zero gas and a span gas. The span gas
concentration is equivalent to the emission limit value of the substance being
measured.

C5

Zero and span checks should be carried out on instrumental analysers on-site before,
after and if required during measurement using traceable gases of known
concentrations. The results of the calibration check should be reported, with the data
indicating the difference between the analysers reading and the known value of the
standard.

C6

If the span and zero drifts are within the specified tolerances of the applicable standard
method, the measurement run is acceptable and the results may be reported. If the
drifts exceed the allowable tolerances, then the instrument should be re-calibrated and
the measurement repeated.

C7

The zero and span gas calibrations should confirm the integrity of the complete
sampling system by being introduced into the system in accordance with the
applicable standard method.

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Annex D - Site review

D1

At each stage of the site review, health and safety shall be considered and the risk
assessment completed.

D2

Factors that shall be included in a site review are:

Site information

address and contact information;

general information about the process;

scope of work;
Process conditions

process characteristics (material balance, process-flow diagrams, feedstock

details and the like);

expected emissions (concentration or mass);

expected process variations;

site instrumentation relevant to the monitoring process;

emission control equipment (type, operating mode, instrumentation, control

arrangements);
Sampling location

access to the stack;

adequate work area at the sampling positions;

availability of required utilities (electrical, lighting, water);

sample ports (accessibility, correct size, sufficient number, properly located);

the stack dimensions at the sampling location;

a pitot tube traverse of the velocity profile;

temperature and moisture of the stack gas;

diagram of the sampling point locations and stack geometry;

site restrictions on using equipment, for example intrinsically safe areas;

physical and chemical restrictions to using equipment;

chemical composition of stack gas;

determine appropriate monitoring equipment for the application.

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Annex E Site-specific protocol

The following details shall be addressed in a site-specific protocol:

the site name, address and operator contact;

the planned date of the measurement campaign;
the names of sampling team members, their competency and specific
responsibility;
the type of process;
a description of the site;
the identity of the installations to be measured;
the operational/ feed details, for example, continuous, batch process;
the duration of any batch processes;
for non-continuous processes, the part of the process when sampling will take
place;
any unusual occurrences that take place during the process;
the process details that need to be collected over the monitoring period;
the emission-limit values;
expected emission values;
the substances to be monitored at each installation;
the reference conditions for reporting concentrations;
the measurement method for each substance;
the organisations technical procedure reference covering implementation of
the above method;
the overall uncertainty of the technical procedure;
any modifications to the technical procedure, with justifications and any
resulting changes to the uncertainties;

Note - where the operator or competent authority requires deviations, additions or exclusions from the
documented sampling procedures, these must be recorded in detail to satisfy the requirements of ISO
17025 on sampling (ISO 17025, 5.7).

the equipment used for each substance monitored;

the sampling duration and number of samples for each measurement, including
blanks;
for manual methods, the proposed sample flow-rate, volume and minimum
sampling times;
for instrumental methods, the proposed span-gas concentration;
the measurement concentration range and lower detection limit;
a description of the location of the sampling plane for each release point;
for each sampling plane, a description of the type of sampling port;
for each sampling plane, a summary of the number, arrangement and
orientation of the sample line(s), and the number of sampling points per line;
for each sampling plane, a summary of compliance with CEN Standards;

Note a statement of compliance with CEN Standards is required to satisfy the requirements of EN
ISO/IEC 17025 on control of non-conforming tests (ISO 17025, 4.9).

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for manual methods requiring a separate chemical analysis stage, details of the
analytical method, the laboratory carrying out the analysis, chain-of-custody
details, allowable time for transit to the laboratory, storage conditions and
archiving requirements;
the procedure for recording monitoring data;
the method to be followed for correction of results to standard conditions;
the report format, the person who will be writing the report and the person who
will be checking the report;
the procedure for checking data quality;
the date the results report is due to be issued;
the reference number and date of the on-site health and safety risk assessment
the team carried out;
the reference number of the use of hazardous chemicals risk assessments for
each measurement method;
any site-specific safety requirements, for example, local safety induction
course, intrinsically safe site;
any other relevant health and safety requirements.

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Annex F - Work file

A work file shall contain the following:

site-specific protocol;
site review;
risk assessment;
equipment checklist, including reference to equipment history file;
volume of reagents and amount of sample media required;
forms used by the site operator;
site calculation and data sheets;
record of process conditions at time of monitoring;
record of deviations from the approved site protocol.

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Annex G - Monitoring records

Monitoring records shall include:

the date;
the names of the monitoring team members making the records;
the measurement procedure used;
the identification of the equipment;
the sampling location (including diagrams as necessary);
environmental conditions, for example, atmospheric pressure;
details of measurement start and finish times;
for manual methods, details of sampling, for example, dry gas metre readings,
solution volumes, pressure and temperature readings;
for manual methods, the sample details, for example, sample bottle or sorbent
tube identification label;
for instrumental methods, the zero and span gas verification results;
for instrumental methods, the output or indicated readings of the analyser.

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Annex H Stack-emission monitoring report

A stack-emission monitoring report shall include the following information on each page:

a unique reference in the following format:

- Agency reference number (if carrying out work for the Agency);
- permit number;
- operator and installation name;
- year of the monitoring visit; and
- sequential number of the visit in the year (if applicable).
a version number; and
a page number, which shall be written as page x of y.

The report shall contain the following information in the order specified:
Part 1: Executive Summary
Cover Sheet
MCERTS logo, the UKAS logo and registration number of the monitoring organisation;
title;
permit number;
operator name;
installation name;
dates of the monitoring visit;
contract number or reference;
name and address of the client organisation (where applicable);
name and address of the monitoring organisation;
date of the report;
name, MCERTS registration number and the function of the person approving the report
for the monitoring organisation; and
the signature of the person approving the report
Contents
The content sheet shall describe the contents of both parts of the report.
Monitoring Objectives
the overall aim of the monitoring campaign;
the substances to be monitored at each emission point; and
any special requirements.
Monitoring Results
emission point;
substances to be monitored;
emission limit value expressed in the terms and units defined in the permit;
periodic monitoring result in the same terms as the emission limit value;
uncertainty associated with the result at a 95% confidence level;
units for the emission limit value, the periodic monitoring result and the uncertainty;
reference conditions at which the results are expressed;
date of monitoring;
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start and end times for the monitoring;

name and reference number of monitoring method used;
accreditation for use of the method, such as MCERTS, UKAS; and
process status at the time of monitoring, such as load and feedstock.

Operating information
whether process was continuous or batch process;
whether the whole of the batch was sampled or the details of the part of the batch sampled
(if applicable);
what fuel was used during monitoring (if applicable);
what feedstock used during monitoring (if applicable);
the normal load, throughput or continuous rating of the plant;
what type of abatement system and whether operating; and
the periodic monitoring results and the results obtained for the corresponding period by
the operators CEMS.
Monitoring Deviations
an explanation why any substance(s) in the monitoring objectives was not monitored;
an explanation why any substance(s) were not monitored in accordance with the monitoring
method stated in Environment Agency TGN: M2; and
any other issues relevant to the monitoring results
Part 2: Supporting information
Cover sheet
The cover sheet for Part 2 should contain the same information that is detailed in the Part 1
cover sheet.
Contents
The contents sheet shall describe the contents of the whole report.
Appendix 1
the names, MCERTS registration numbers and the functions of those persons engaged in
the monitoring of the installation;
the substance(s) monitored, the reference number of the standard method used and the
reference to the Technical Procedure used by the monitoring organisation; and
a reference to the equipment check lists used on the monitoring campaign.
Further appendices (one for each emission point)
diagrams showing the dimensions of the stack and the monitoring facilities;
flow criteria measurements, such as measurements for temperature, pressure and stack gas
velocity;
gas measurements, such as oxygen and carbon dioxide;
water vapour measurements;
sampling measurements, such as stack gas temperature and velocity during sampling;

If the client agrees the monitoring organisation may provide them with only Part 1 (Executive Summary) of the
monitoring report. However, Part 2 must be retained at the monitoring organisations premises and be available
for auditing for a minimum of 4 years.

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instrumental gas analyser site calibration measurements including zero and span gas
concentrations;
instrumental gas analyser results;
analysis sheets including the name of the analytical laboratory, the accreditation for the
use of the analytical method and the date of the analysis;
the manual monitoring method results calculations, including concentrations and mass
emissions; and
uncertainty calculations.

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