Odour Guidance Internal Guidance For The Regulation of Odour v3 - EA England Wales - 2002

ENVIRONMENT AGENCY
ODOUR GUIDANCE
Internal Guidance for the Regulation of Odour

at Waste Management Facilities
July 2002
VERSION 3.0
(Amended following external consultation)
Not to be applied directly to any existing permit or registered application but may be
used to identify issues and promote consistent resolution.
Note: This document constitutes guidance issued by the Environment Agency to its regulation
officers.
This document has been produced in consultation with officers from different regions
and it is issued with the approval of the National Waste Group. It will be subject to
periodic review to reflect any developments in technical guidance which affect the
advice herein.
The Working Group consisted of:-
Keith Ashcroft North West Region

Brian Bone Midlands Region
Jan Gronow National Policy
Mark Harvey Southern Region
Nigel Kendrick Environment Agency Wales
Jonathan Lees South West Region
Chris Peters (Chair) Thames Region
Andrew Phillips Environment Agency Wales
Lorraine Powell EPNS
Carol Romero North West Region
Jim Scott North East Region
Dave Young (Lead Author) Anglian Region
William Edwards Thames Region
Odour Guidance for Waste Sites, Version 3.0, July 2002 1

CONTENTS
EXECUTIVE SUMMARY ............................................................................................................................ 4
1.0 OBJECTIVE......................................................................................................................................... 6
2.0 INTRODUCTION................................................................................................................................. 6
2.1 PREAMBLE .......................................................................................................................................... 6
2.2 LEGAL BACKGROUND........................................................................................................................... 6
2.3 GENERAL CONSIDERATIONS ................................................................................................................. 9
3.0 INFORMATION REQUIRED IN SUPPORT OF AN APPLICATION ........................................... 10
4.0 LICENSING APPROACH ................................................................................................................. 11
5.0 INSPECTION AND MONITORING ................................................................................................. 13
6.0 ENFORCEMENT ............................................................................................................................... 16

FIGURE 6.1 FLOW DIAGRAM INDICATING THOUGHT PROCESSES FOR ENFORCEMENT ACTION ................... 19
7.0 HEALTH & SAFETY AND HEALTH.............................................................................................. 20
APPENDIX A - FACTORS CONTIBUTING TO ODOUR PROBLEMS FROM WASTE

MANAGEMENT FACILITIES .................................................................................................................. 21
TABLE A.1............................................................................................................................................... 22
APPENDIX B - PROCEDURE FOR CARRYING OUT AN ASSESSMENT OF ODOUR AT WASTE
MANAGEMENT FACILITIES .................................................................................................................. 27
B1 OBJECTIVE....................................................................................................................................... 28
B2 PROCEDURES................................................................................................................................... 28
B2.1 GENERAL ..................................................................................................................................... 28
B2.2 AT THE ASSESSMENT LOCATION .................................................................................................... 29
B2.3 HOW TO REPORT THE RESULTS ....................................................................................................... 30
B2.4 TRAINING AND CALIBRATION ......................................................................................................... 31
B3 ODOUR ASSESSMENT REPORT.................................................................................................... 32
B3.1 REPORT PRO-FORMA ..................................................................................................................... 32
B3.2 NOTES ON COMPLETING PROFORMA .............................................................................................. 32
B3.3 CLASSIFICATION SYSTEM FOR ODOUR PARAMETERS ....................................................................... 32
APPENDIX C - METEOROLOGICAL DATA.......................................................................................... 35
C1 GENERAL .......................................................................................................................................... 36
C2 ATMOSPHERIC STABILITY .......................................................................................................... 36

TABLE C2.1 ATMOSPHERIC STABILITY CATEGORIES .................................................................................... 37
TABLE C3 THE BEAUFORT WIND SCALE .................................................................................................... 38
APPENDIX D - ODOUR DESCRIPTORS.................................................................................................. 39
TABLE D1 “PLEASANT” ODOUR DESCRIPTORS AND “HEDONIC” SCORE ...................................................... 41
TABLE D2 “UNPLEASANT” ODOUR DESCRIPTORS AND “HEDONIC” SCORE .................................................. 42
TABLE D3 ODOUR DESCRIPTORS WITHOUT “HEDONIC” SCORE ................................................................... 43

FIGURE D1 ODOUR WHEEL ......................................................................................................................... 44
APPENDIX E - UNDERSTANDING SMELL ............................................................................................ 45
E1 REALISTIC EXPECTATIONS OF THE NOSE .............................................................................................. 46
E2 ODOUR FATIGUE ................................................................................................................................ 47
INDEX.......................................................................................................................................................... 48

EXECUTIVE SUMMARY
Wherever bulk quantities of waste are handled, kept, treated or disposed of there is potential
for the generation of offensive odours. Geology, economics, logistics (e.g. transport systems)
etc. often result in waste management facilities being situated close to residential, commercial,
industrial or amenity areas. It is reasonable that members of the public, going about their
normal living, working or leisure activities, should expect not to be offended by odours arising
from these facilities.
The EC Framework Directive on Waste makes it a relevant objective to ensure that waste is
recovered or disposed of without harm to human health or pollution of the environment,
including without nuisance through noise or odour. The Framework Directive is transposed
into the UK’s national legislation mainly through the Environmental Protection Act 1990 and
the Waste Management Licensing Regulations 1994. The control of odour from waste
management facilities will be within the remit of the Environment Agency and the planning
authority, where odour nuisance will be a material consideration in the determination of a
planning application. Conditions in the waste management licence should complement the
planning requirements for the site in order to avoid any unnecessary duplication of controls.
This document uses, for convention, the format of “nuisance” to refer to nuisance in respect
of relevant objectives under the EC Framework Directive and “Nuisance” to refer to Statutory
Nuisance in respect of the powers of Environmental Health Authorities.
The Agency has a duty to ensure that the deposit, recovery and disposal of controlled
waste does not take place in a manner likely to cause pollution of the environment or
harm to human health. As such, links must be maintained with other authorities such
as local authorities (in their role as planning and environmental health authorities) and
the Health and Safety Executive. Odour does present potential health issues, even if
only in perception, and it is therefore important to remember that the Agency does have
powers and duties to address human health issues in addition to pollution and amenity
issues.
The aim of this guidance is to provide Agency officers with the relevant background to this
issue and to put forward a nationally consistent approach to the control of odour through the
permitting system and the subsequent monitoring of any odours produced.
It proposes that:
• all new licence applications are assessed with regard to odours via a risk
assessment provided by the applicant or operator, bearing in mind that some sites
may have already provided odour assessments as part of their planning permission
process. This risk assessment will be used to define the approach to odour control
within the licence;
• the impact of odour on the surrounding environment is considered as part of

routine site inspections;
• odour is primarily controlled at source by good operational practices, the correct

use and maintenance of plant and operator training;

• odour controls are considered in consultation with other relevant regulatory
authorities.

1.0 OBJECTIVE
1.1 The objective of this document is to provide guidance to Agency officers seeking to
control odours originating from licensed and exempt waste management facilities; to
suggest areas that need to be considered in setting licence conditions ; and to seek
national consistency in the monitoring of odours. In respect of the last item, Appendix
B describes a scheme for subjective monitoring of odours around waste management
facilities. It is intended for use by EA officers, but could equally well be used by site
operators.
1.2 This guidance applies to landfill sites and other waste management activities that
fall under PPC regulations, until such time as sectors specific guidance becomes
available. For IPPC sites, reference must also be made to the Agency’s IPPC
technical guidance on odour1.
2.0 INTRODUCTION
2.1 Preamble
2.1.1 A dictionary definition of odour gives:-
odour a) that characteristic property of a substance which makes it

perceptible to the sense of smell,
b) a smell whether pleasant or unpleasant; fragrance or stench.
2.1.2 The perceptibility of an odour depends on the concentration of that substance in the
atmosphere. For each substance there is a limiting concentration in air below which
its odour is not perceptible. This is generally referred to as the odour threshold of that
substance. More information is available in the Agency’s IPPC technical guidance note
on odour.
2.1.3 The subject of odour is a complex one.

• An odour can arise from a single substance or from a combination of substances.
• In combination with other substances, the characteristic odour of a single substance
can be modified so as to be unrecognisable.
• Odour from a combination of substances changes as the mixture becomes diluted
and the concentration of each component falls below its odour threshold.
• Odours from a substance or mixture of substances can be pleasant when dilute or
offensive when concentrated.
• Odours that are pleasant or acceptable to one nose can be offensive to another.
(See Appendix D)
• People have different odour thresholds, so odours that are detected by one person
may not be detectable by another.
2.2 Legal background
1
EA, IPPC H4 Technical Guidance Note, Horizontal Guidance for Odour, Part 1 – Regulation and Permitting
(draft), Part 2 – Odour Assessment and Control (draft)

2.2.1 The following provides a brief overview of the legal background relating to the control
of odours from waste management facilities.
2.2.2 Activities involving the recovery or disposal of waste are subject to the requirements
of the Framework Directive on waste (Directive 75/442/EEC, as amended by Directive
91/156/EEC). Article 4 of the Directive requires that member states ensure that waste
is recovered and disposed of without endangering human health and without using
processes or methods which could harm the environment, and in particular:
- without risk to water, air, soil and plants and animals
- without causing a nuisance through noise or odours,
- without adversely affecting the countryside or places of special interest.
The waste management licensing system established under Part II of the Environmental
Protection Act 1990, and the Waste Management Licensing Regulations 1994, is the
main means by which the Directive’s requirements have been transposed into national
law. The Environment Agency, under Section 35 of the Environmental Protection Act
1990 (EPA90), grants licences to waste management facilities on such terms and
subject to such conditions as appear to be appropriate to the activities to which the
licence relates. The purpose of the terms and conditions are to ensure that the activities
authorised do not cause pollution of the environment, harm to human health or become
seriously detrimental to the amenities of the locality. The Agency is required to
discharge their functions, including licensing, with regard to the relevant objectives of
the Framework Directive.
2.2.3 “Harm” is defined in Section 29 of EPA90 as including, in the case of man, offence to
any of his senses or harm to his property.
2.2.4 The 1994 Regulations state, in Schedule 4 Paragraph 4, that the relevant objectives,
transposed from the EC Framework Directive on Waste, in relation to the disposal and
recovery of waste include, inter alia, that processes do not cause nuisances through
odour.
2.2.5 Statutory guidance given in Waste Management Paper No. 4 (WMP4) indicates that
the planning function and the licensing function should complement each other rather
than duplicating controls. The planning system controls the development and use of
land in the public interest, and WMP4 states that the prevention of nuisance is one of
the important issues in determining the location of waste management facilities.
2.2.6 Many waste management facilities will be subject to an environmental impact

assessment as part of this process. However, WMP4 states that planning controls are
not an appropriate means for the detailed control of pollution from waste management
facilities and that this should be done by the Agency, as Waste Regulation Authority,
through the licensing system to ensure that the relevant objectives are met.
2.2.7 Where planning permission (resulting from the taking of a specified action by a planning
authority before 30 April 1994) was granted after 1 May 1994, the waste management
licensing system should be used for imposing detailed controls to ensure the relevant
objectives are taken into account. For example, by requiring impact assessments at the

licence application stage and through the life of the site until surrender of the licence,
routine monitoring frequencies and protocols, and remedial action to be taken in the event
of the appropriate standard not being achieved. Although the planning permission may
have been issued with regard to the relevant objectives, licence conditions should be
imposed that complement, rather than duplicate or overstep, the framework set by the
planning permission.
2.2.8 However, where the Agency is not satisfied that the relevant objectives are likely to be met
within the framework of the planning conditions, a licence must still only be granted with
such conditions that appear to the waste regulation authority to be appropriate (Section
35(3) of the 1990 Act), regardless of the date of the planning permission.
2.2.9 It is, however, not permissible to reject an application for a licence on the grounds of
serious detriment if planning permission (resulting from the taking of a specified action
by a planning authority before 30 April 1994) was granted after 1 May 1994. There is
therefore a need for the Agency, as a statutory consultee, to communicate any concerns to
the planning authority; in particular on the basis of serious detriment to the amenities of the
locality to ensure that amenity will be adequately protected (thus achieving the relevant
objectives)
2.2.10 Where planning permission was granted before 1 May 1994 or where it is not required
(Schedule 4, Section 9(7) of the 1994 Regulations), the Agency is under a duty to reject a
licence application on the grounds of serious detriment to the amenities of the locality.
Licence conditions need to be imposed to prevent serious detriment to the amenities of the
locality affected by the activities controlled by the licence.
2.2.11 As with noise, the control of odour is the responsibility of a number of authorities. All
proposed sites likely to produce odour areas should be discussed with and perhaps
inspected in conjunction with the local Environmental Health and Planning Officers.
2.2.12 Part III of the Environmental Protection Act, 1990 enables Environmental Health
Officers to control any odour that is prejudicial to health or a nuisance that a waste
management facility might cause to a nearby community. In Scotland, however,
nuisance is dealt with principally under the Public Health (Scotland) Act, 1897.
2.2.13 WMP4 advises that licence conditions relating in a general way to Nuisance should
therefore be avoided. However, Section 29 of Environmental Protection Act, 1990
defines the “harm to human health” aspect of the EC Framework Directive on Waste’s
relevant objective of nuisance to include offence to any of man’s senses. WMP4
further advises, therefore, that licence conditions that control harm in a specific way
must be included where necessary.
2.2.14 Planning Policy Guidance Note PPG23, at paragraph 3.23, advises Local Planning
Authorities that a lack of confidence in the effectiveness of controls which may be
imposed under pollution control legislation is not a legitimate ground for the refusal of
a planning permission or for the imposition of conditions on a planning permission
which would merely duplicate such controls. PPG10, which replaces parts of PPG23,
has not changed this guidance.

2.2.15 If odour from a site constitutes a Statutory Nuisance, an Abatement Notice may be
served by the Local Authority. This may require that the nuisance is stopped altogether
or restricted. Where a licence has been issued and the site operated within the
conditions of that licence, it does not mean that an Abatement Notice cannot be
served. The fact that licence conditions are being met does not constitute a defence
against odour Nuisance proceedings. Whether a Statutory Nuisance occurs will
depend on the interpretations of an Environmental Health Officer or the court.
2.2.16 The decision as to whether an odour constitutes a Statutory Nuisance is likely to

depend somewhat on it being persistent, but the odours that cause the majority of
complaints are transitory. However, it follows that if Statutory Nuisance occurs, then
insufficient control has been exercised through the licensing procedures by the Agency,
since it has much greater scope under “offence to man’s senses.”
2.2.17 There are waste management facilities with planning permission that are exempt from waste
management licensing. In such cases the relevant objectives must still be achieved, both
through any planning permission and also by virtue of regulation 17(4) of the 1994
Regulations and the terms of the particular exemption.
2.2.18 Regulation 18 of the 1994 Regulations makes it an offence for an establishment or

undertaking to carry on an exempt activity (as defined in Schedule 3 of the 1994
Regulations) without being registered with the appropriate registration authority, this being
the Agency in most cases. The registration authority has a duty to maintain a register of
such activities.
2.2.19 Although, the exempt activities form the “self-regulation” aspect of waste management,
the Agency has a duty to carry out periodic inspections of these activities. Where an
exempt activity is being carried out in a manner not consistent with the relevant
objectives, it cannot continue to be exempt from licensing.
2.3 General considerations
2.3.1 Wherever waste is handled the potential for generation and escape of odour exists.
2.3.2 There is the view that waste management facilities should not cause odours. A recent
Scottish High Court ruling gave that a condition, which required that “All emissions to
air from the process shall be free from offensive odours as perceived by an authorised
officer of the Agency, outside the process boundary”, was a valid condition.
However, this related to an authorisation under Part I of EPA90 and it is currently not
clear how relevant this decision would be under Part II of EPA90 in respect of the
Waste Management Licensing Regulations under English law.
2.3.3 In an appeal decision relating to Waste Management Licence conditions, (Alco Waste
Management Limited vs. Environment Agency, February 1997), the Planning
Inspectorate gave a complementary (but not as absolute) view in that “... the operator
cannot guarantee that the treatment of waste shall be free from offensive odours. All
that can be required is that odours are controlled so as not to harm human health or
amenity off the site”.

2.3.4 The appeal decision reaches many other conclusions and the following is based on
those conclusions:-
2.3.4.1 The purpose of licensing is “to ensure that the disposal of controlled waste
does not give rise to pollution of the environment, harm to human health, or
serious detriment to the amenities of the locality” (Paragraph B10, WMP26B).
Section 29 of EPA90 defines harm as including offence to any of man’s senses
and this must include the sense of smell. This can be safeguarded through the
imposition of conditions on a waste management licence.
2.3.4.2 There may be the possibility that odours, and the causes of odours, from waste
management facilities could be a risk to human health via chemical or
microbiological toxicity, or by causing stress or precipitating asthma attacks.
This guidance paper considers only amenity issues. The potential harm to
human health aspect of landfill gas is being considered by the landfill gas Task
and Finish Group but it must be accepted that there are potential health risks
from sources other than landfill gas.
2.3.4.3 Amenity is a subjective issue. Amongst a group of individuals, not all will
agree, but a consensus can emerge about what could reasonably be considered
as offensive smells. The objective of this guidance is to achieve national
consistency in the assessment of odours.
2.3.4.4 The identification and analysis of harm to an amenity is not something which
can be wholly defined only by employing scientific methods; it must include a
subjective assessment of prevailing conditions by those directly affected or by
experienced observers. The directly affected group, or “target group”, are the
people who live, work or use amenities outside the site boundaries.
3.0 INFORMATION REQUIRED IN SUPPORT OF AN APPLICATION
3.1 As mentioned above, wherever waste is handled, the potential for the generation and
release of odour exists. Therefore, at all stages of the development of a waste
management facility, from planning through to post closure, an assessment of the
possible risks should be carried out by the operator.
3.2 The assessment should take into consideration potential sources of odour, what actions
can be taken or are planned to minimise or eliminate them, the proximity, direction and
sensitivity of likely receptors, other factors such as prevailing winds and weather
conditions and any other pathways which may exist. This may form part of an
Environmental Impact Assessment produced as part of the planning application.
3.3 Appendix A is intended as an aide memoire listing the potential sources of odour from
different types of waste management facility and options available to effect
minimisation or control where appropriate.
3.4 At the pre-application stage, the method statement or working plan should be able to
show that all aspects of potential odour generation and release have been considered
by the operator and addressed or rejected as inappropriate.

3.5 The Agency also has an opportunity to comment at the planning stage as a statutory
consultee. For a waste management facility, the opportunity exists to comment on the
appropriate use of the land in question, with respect to nearby housing and other
developments. Where planning consent is given against advice, the Agency will have
a difficult task in applying the appropriate pollution controls due to the location of the
site.
3.6 It is important to recognise that sites which fall within the licensing exemption criteria
still need to comply with the relevant objectives, including not causing nuisance
through odour. Therefore should an exempt site cause such a problem that means it
does not comply with the relevant objectives, it will no longer meet the terms of the
exemption and becomes a licensable activity.
3.7 Equally, existing sites, where the licence exerts no odour controls need to be
considered for modification in this respect where necessary. See 5.16.
4.0 LICENSING APPROACH
4.1 WMP4 makes it clear that licence conditions must leave the licence holder in no doubt
about the standards to be met. The placing of a condition on a licence which, in itself,
specifically seeks prescriptively to limit or eliminate odour from a waste management
facility is not likely to be the most effective means of achieving such control.
Proactive means are required to achieve adequate and effective control of odours at
source by licence conditions which ensure good day-to-day site management of
operational activities on the site. This aspect is not covered by this guidance paper
but an idea of the scope of the issues which may be addressed can be obtained by
reference to the tables contained in Appendix A.
4.2 However, it may ultimately become necessary to take prescriptive action with respect
to odours by the placement of licence conditions that specifically address such issues.
Areas which might need to be considered are:-
§ The provision and maintenance of measures to secure the minimisation of release

of offensive odours under everyday circumstances and particularly when specified
operations are undertaken, which the operators risk assessment has shown are
likely to increase the risk of odour release , e.g.:-
− excavation into waste;
− removal of leachate monitoring chimney lids or leachate manhole covers;
− extension of leachate monitoring chimneys;
− removal of intermediate cover;
− maintenance of gas abstraction system;
− storage of wastes.
§ Notification to the Agency when such actions are to be undertaken.
§ The provision and maintenance of measures to contain or suppress any odours
released or generated.
§ The escape of offensive odours beyond the site boundary and the effect on
sensitive receptors identified in the risk assessment.
§ The provision of an effective and approved odour monitoring regime.

§ The requirement to report to the Agency incidents of odour either reported to the
operator or detected via a monitoring regime.
4.3 Licence conditions may specify what needs to be done or may require that proposed
actions to meet a desired objective are detailed and approved via the working plan and
guidance on this aspect should be sought by reference to the Agency’s Library of
Licence Conditions.2 Some further discussion on what may need to be taken into
consideration is given below.
4.4 The provision and maintenance of measures to control odours may need to take into
consideration:-
− how agreement on the provisions should be made - in accordance with conditions,
in writing or via the working plan;
− when the agreement should be reached - prior to the deposit of waste or by a set
date;
− the restriction of a waste or wastes either likely to give rise to or shown to give rise
to odour problems;
− methods of keeping, storing, handling, treating, placing, discharging such wastes;
− method of sealing containers, chimneys, boreholes, chambers, tanks, pipes which
contain wastes or derived materials likely to give rise to offensive odours;
− methods of filtering, scrubbing emissions from chimneys, vents, extraction units
likely to give rise to offensive odours.
4.5 It is important that the agreed measures be maintained or available on site for use
should an odour occur. It may be, should the agreed measures need to be used, that
they do not prove to be entirely effective in which case revision of what is agreed is
clearly necessary. If agreed measures are not maintained or available, this should be
viewed as a clear breach of licence conditions and if odour problems occur under such
circumstances this should be viewed as a serious breach of licence conditions.
4.6 Conditions seeking to control the detection of odours beyond the site boundary should
be dependent on the location of the nearest receptor of odours. It may be that a local
amenity such as a much visited local beauty spot or much used footpath is immediately
adjacent to the site boundary in which case a condition requiring no odours beyond the
site boundary should be justified. It may be, however, that the nearest receptor is a
residential development for example some 500 metres beyond the site boundary, in
which case the condition should be tempered accordingly. Consideration should also
be given to the significance of highways adjacent to the site particularly if they provide
access to amenity, residential, commercial or industrial development.
4.7 It must also be recognised that weather conditions and the topography of the area will
affect the way in which odour is dispersed. For example, in certain circumstances, it is
possible for an odour, arising from a site, to rise above ground level and be carried
beyond the site boundary to become detectable again at some point beyond it. (See
Appendix C)
2
Library of Licence Conditions and Working Plan Specifications – Volume 1: Waste Management Licences, Edition 2,
Published 2 August 1999

4.8 Any scheme designed to monitor for offensive odours should detail:-
− the method of assessment to be employed
− identification of personnel specified to carry out monitoring, paying particular
attention to the possibility that actual site staff may suffer from odour fatigue due
to constant exposure to an odour. – See also 5.6
− details of guidance, instruction and training given to specified personnel
− minimum frequency of monitoring
− liaison with the Environment Agency
− the period over which the monitoring shall take place
− monitoring points on and off the site, and
− record keeping.
4.9 It must be remembered that some waste management facilities and activities, exempt
from licensing, have the potential to cause odour. However, if such sites cannot meet
the relevant objective relating to odour, they become licensable.
5.0 INSPECTION AND MONITORING
5.1 The Agency has a duty to carry out appropriate periodic inspections of waste
management facilities. Statutory guidance on inspection frequency has been provided
in an amendment to WMP4, which requires inspection frequency to be determined by a
risk-based approach.
5.2 Under Section 34 of EPA90 there is a ‘Duty of Care’ incumbent upon anyone who
handles waste to ensure that all necessary actions are taken to protect the environment
and human health. Bearing in mind the definition of harm in Section 29 of the Act
which includes offence to any of man’s senses, it follows that the ‘Duty of Care’ must
include protection from offensive odours.
5.3 Paragraph 4.34 of WMP4 advises there is an expectation that the licensee of a waste
management facility should carry out its own environmental monitoring which, again,
in view of the definitions given in Section 29 of EPA90 should include monitoring the
air for offensive smells. It should be part of the operator’s responsibility to carry out
such monitoring.
5.4 To deal with the problem effectively, it is necessary for the operator to have a number
of things in place:-
• sufficient day-to-day control to minimise or contain any problems via frequent and
regular full inspections of the site carried out by the licensee or his staff;
• a scheme to monitor the extent of the odours and to detect when a problem has
arisen or is likely to occur;
• techniques and equipment which are acknowledged as being effective need to be in
place or available to deal with incidents as they occur;
• a requirement to take effective action in the event of offensive odours being
detected.

5.5 The level of action and monitoring required around a facility should be gauged in
accordance with the risk from that site. For example, sites accepting potentially
odorous wastes, some special waste streams or a high proportion of putrescible waste
can present a high degree of risk of odours and are likely to receive a relatively high
level of attention subject to their location relative to sensitive receptors. Conversely,
sites accepting inert wastes3 present a low risk of odour problems.
5.6 A scheme for the subjective monitoring of odours around waste management facilities
is suggested in Appendix B. The scheme is designed for Agency officers but would
easily be adaptable to the requirements placed on an operator and could therefore be
suggested as a model. In any such scheme, operators, in particular, should recognise
the possibility that staff associated with a site, which may have odour problems, could
suffer from odour fatigue, i.e. the inability to detect relevant odours due to constant
exposure to them. In such circumstances it may be prudent to use staff not directly
associated with the site. As with other forms of environmental monitoring, Agency
officers should also carry out audit monitoring to check the results reported by the
operator, but again officers should be aware of the possibility of odour fatigue
resulting from regular or constant exposure to such odours. The scheme suggests that
monitoring should be followed by site inspections.
5.7 In addition to monitoring of odours by the operator and Agency officers, complaints
about odour voiced by the local community can, in themselves, be an effective form of
monitoring where problems are known to exist. Complaints should be encouraged by
providing or publicising a mechanism, such as the Agency’s Freefone emergency
number, 0800 80 70 60, for the receipt of complaints. It should also be explained to
complainants that is important for them to continue to complain rather than become
apathetic if nothing seems to be happening, since that is often one of the only ways in
which the Agency might be able to attach a scale to the problem. In this respect both
the number of complaints and the number of complainants are important and need to
be recorded and details passed to the operator. When a complaint is received the
following information should be recorded.
a) Name, address and telephone number of complainant(s)

b) Time complaint received
c) Location of odour if not at address above
d) Date(s) and time(s) to which complaint relates
e) Duration of odour(s) - when it started; is it there now?
f) When did it cease?
g) Any description of odour
5.8 Complaints received should also be checked out by Agency inspectors and site
personnel whenever possible. Officers should note, however, that the temporal
variance of odours may mean that the odour has subsided or changed from the time the
complaint was received. It may be appropriate to leave a log or diary with the
complainant so that they can record incidents of odour. Details noted should include:
dates, times and duration that the odour was detected; where the odour was detected
3
Landfill directive definition – no risk, cannot by definition give off odourous gases unless not inert

(inside/outside?); a description of the odour; weather conditions when the odour was
detected.
5.9 Where a site is shown beyond all reasonable doubt to be the cause of odour problems
in a locality in terms of harm or detriment to the amenity, all relevant potential sources
of odours on the site should be identified and given attention. Not every potential
source of odour on the site may be generating offensive odours at any one time, but all
should be addressed in view of their potential detriment to amenity. It might be
unacceptable to leave the installation of any necessary controls for a phased, longer
term programme as any identified detriment to amenity might remain until all potential
sources have been dealt with.
5.10 There may be other sources of offensive odours in the locality which should be taken
into account during any investigation and these too may need to be addressed by the
relevant authority. In such circumstances, a liaison should be maintained with the
Local Authority Environmental Health Officer, a request made to monitor these other
sites and to record whether they are, or are not, causing odours. This is not an
argument, however, to ignore or delay implementing any necessary control of odours
from a waste management facility (WMF) once they have been positively identified.
The officer should also be aware, however, of the possibility of an odour from a WMF
being due to the disposal of an odorous waste arising from a nearby local source. The
assessment of the WMF will need to take into account such a source, and it may need
to be investigated separately.
5.11 It is also important to encourage the operator to form a liaison with the local
community and perhaps for the Agency to be involved in this liaison. This is likely to
give operators a better understanding of the intensity, scale and emotive nature of any
problems arising from their site. It is also likely to better motivate the operator to
cure the problems and make them, perhaps, more accountable for the consequences of
their development and the controls they exercise upon it. By inclusion of regular site
visits within this liaison, it is possible also for the community to feel involved in the
improvement of the amenity in the locality where problems are seen to be being
overcome.
5.12 A strategy to monitor odours should be devised in consultation with the Agency and
the Local Authority EHO, such that evidence can be compared between the operator’s
records, those of the Agency and those of the local authority in the event of complaints
being raised about offensive odours in the area. As outlined in 5.6 above, it should be
borne in mind that reliable complaints, in themselves, are a form of monitoring.
5.13 Paragraph 2.5 of WMP4 advises that there should be no doubt about the standards to
be met. Where an odour is consistent and due to known, specific chemical(s) which
can readily be measured by instrumental means, e.g. hydrogen sulphide, limits can be
set, perhaps at odour threshold limits at the site boundary or at the nearest sensitive
receptor beyond the site boundary. However, under normal circumstances due to the
variability and complexity of odours there are seemingly no readily available scientific
measurable indicators or factors for odours which might be incorporated into any
control standards or licence conditions.

5.14 Where there is difference of opinion based on the interpretation of subjective
monitoring and likely source of odour, but an obvious problem exists, recourse can
then be made to other techniques such as olfactometry using odour panels or the
application of more specific and scientific techniques such as gas chromatography and
mass spectrometry to collect air samples to identify the offending source. It is not
currently within the intentions of this guidance to discuss these techniques since they
are more fully covered in other Agency documentation.4
5.15 Subsequently, once the source producing or likely to produce detriment to the
amenities of the locality or harm to man’s senses has been identified, if generated by
waste management activities, all that may be required is an agreement, via the working
plan, changing inappropriate practices or stopping the acceptance of any offending
waste stream(s). Alternatively, should this agreement not be reached, EPA90 allows
for the modification of the conditions of a licence under Section 37 or the revocation
or suspension of a licence under Section 38 or Section 42 by the issue of appropriate
notices. The operator however has the right of appeal and under normal circumstances
the requirements of such notices would be ineffective pending the outcome of such an
appeal.
5.16 If an appeal is considered likely it should not be unreasonable for the Agency to use the
provisions of Section 43(6) of EPA90 to ensure that necessary works be carried out as
soon as possible. Under these provisions, the requirements of such notices remain
effective during any appeal, provided that the notice includes a statement to the effect
that in the opinion of the Environment Agency the required action is necessary for the
purpose of preventing or, where that is not practicable, minimising pollution of the
environment or harm to human health, which includes offence to man’s senses.
6.0 ENFORCEMENT
6.1 Notwithstanding anything in the discussion below, reference should be made to the
Agency’s Enforcement and Prosecution Policy document.5
6.2 It goes without saying that enforcement action comes into its own when discussion,
negotiation and persuasion have failed. That does not mean to say that enforcement
action should not be started until the above have reached their conclusion as often
enforcement action can take time to proceed and in the meantime, amenity and human
health can remain affected. However, this approach requires a careful balance to
ensure that if prosecution is proceeding, there is compliance with all the requirements
of both the Criminal Procedure and Investigation Act, 1996 and the Police and
Criminal Evidence Act, 1984.
6.3 The course of enforcement action taken depends of course on the particular problem.
Figure 6.1 below attempts to set out some outline thought processes aimed at assisting
officers in deciding which course of action to take. It makes an initial assumption that
to Agency officers’ minds, it has been established that the Waste Management Facility
4
Odour assessment and control – Guidance for Regulators and Industry – In preparation
5
Environment Agency – Enforcement and Prosecution Policy and Guidance – Version 2 published 30
September 1999

(WMF) is the source of the problem and other, possible, nearby sources have been
eliminated. It is not intended to form definitive enforcement guidelines. That is not
within the intended scope of this paper.
6.4 Where the decision process has led to the conclusion that prosecution is the only
available option, the importance of accurate, factual statements from officers and, if
appropriate, those affected in the locality is essential.
6.5 Paragraphs 6.7 and 6.8 below give guidance on the aspects and detail which may or
need to be covered in such statements. It is important to remember that hearsay
evidence cannot be included in statements. If an officer visits a site as a result of
complaints from the locality, in reporting that visit as evidence his statement must state
that he went to the site as a result of information received. It must not state that he
received “N” complaints.
6.6 It is acceptable, however, to state that “N” telephone calls were received from local
residents and that statements from “n” residents are produced as evidence.
6.7 An officer’s statement should cover the following points:-
• Name
• Job
• Qualifications, if relevant, e.g. chemist
• Length of time doing job and/or related duties
• Other relevant experience e.g. member of this “expert” group
• Health, general and at the time to which the statement relates, e.g. cold, sinusitis
etc.
• Smoker?
• Time and date of observations
• Location of observations with respect to the site in question
• Method of conducting observations,
− Walking? Where?
− Driving? Where? Windows, sunroof, vents open?
• Observations on weather conditions, particularly wind speed and direction, but also
other relevant meteorological conditions (see assessment form in section B3).
• If possible, an indication of atmospheric stability (see C2).
• Strength of odours - observations could relate to guidance in this document
provided that the guidance is produced as evidence in the form of an exhibit
• Was the site visited?
• Conditions on the site?
• Did observations on the site correlate to observations outside? In the officer’s
opinion, are the odours the same.
If the statement is in relation to an odour assessment (as described in Appendix B),

reference should be made to the odour assessment report number (see section B3).
This report will then cover observations on meteorological conditions and strength of
odour.

6.8 A resident’s statement should cover the following points:-
• Name
• Address
• Length of time at that address
• Occupation
• Health, general and at the time to which the statement relates, e.g. cold, sinusitis
etc.
• Smoker?
• Statement of the date(s), time(s) and duration of periods when the resident has
been affected by odours. If diary of odours kept, it should be produced in
evidence
• Where were they affected by the odours? Inside (where, how) and/or outside
(where, how)
• Description of smell
• Weather conditions.

Does the Modify licence under S 43(6)
NO NO Issue notice under NO
licence include + S 37 to include boundary
Compliance? S 42(5) requiring Compliance?
a "Boundary condition with statement of
compliance
Condition"? why modification is needed
YES YES
YES
Issue notice under NO

S 42(5) requiring Compliance?
compliance
YES
NO
What is scale of problem/
YES YES NO Consider Action
Can the source of Is the problem Is the licence Issue notice under breach?
Suspension or revocation
odour from the covered by a condition S 42(5) requiring Compliance? Persistence, frequency,
of licence or prosecution
site be identified? YES licence condition? sufficient? compliance strength of odour, location and
under S 33(1)(b) or (c)
YES density of receptors
NO NO
Can the licence NO

be modified to
address situation?
YES
Modify licence under S 43(6)

NO Issue notice under NO
+ S 37 to include boundary
Compliance? S 42(5) requiring Compliance?
condition with statement of
compliance
why modification is needed
YES YES
Figure 6.1 Flow Diagram Indicating Thought Processes For Enforcement Action
Note: Diagram assumes it has been established, in the Agency Officer’s mind, that the Waste Management Facility is the source of the
odour problem off site. See section 6.3

7.0 HEALTH & SAFETY AND HEALTH
7.1 While the above text draws attention to various health and Health and Safety issues, it is
important to remind officers of these issues:-
• The health effects of landfill sites are being studied and will be reported on elsewhere in due
course.
• Officers should be aware of their own health and safety when carrying out odour monitoring
around waste management facilities. Inhalations should not be made directly over, or even
relatively close to unknown drums, leachate chimneys, gas wells etc.
• Before visiting a site, officers must also refer to the Agency’s Health & Safety Management
Procedures Manual.
Where concerns are received from members of the public with respect to health or Health and
Safety issues, in addition to noting and dealing with the concern as appropriate, the person
should also be made aware of the other avenues open to them to address or mollify their
concerns if necessary, e.g. The Health & Safety Executive, the Local Authority Environmental
Health Department, their own GP.

APPENDIX A - FACTORS CONTIBUTING TO ODOUR PROBLEMS FROM WASTE
MANAGEMENT FACILITIES

TABLE A.1
Type Factors that may contribute to odour Comment / Options / Mitigating Actions
of problems
Site
Sheeting of vehicles and speed of covering of wastes. Review Working Plan procedures for
Disposal of Odorous Wastes
dealing with malodorous wastes. Ultimately review nature and range of waste permitted
In co-disposal landfill sites, the deposit of bulk quantities of sulphur bearing wastes, such as
gypsum and plaster board, such that large, discrete deposits of sulphates occur should be
Disposal of sulphur bearing wastes. avoided due to risk of formation of large quantities of H2S by bacterial action and the resultant
odour and health and safety problem. Small deposits at a controlled rate should not cause
problems provided normal controls are in place.
Fire on site: Accidentally started
Landfill Sites
Dig out, isolate, damp down (care – may make matters worse), cover, call fire emergency
Receipt of burning wastes
services, etc.
Mixing of incompatible wastes
Landfill Gas: Passive venting/ Vent trenches General presumption against; consider active extraction and/or scrubbing using carbon, peat etc.
Ineffective collection system Consider upgrading
Inadequate collection system Consider extending
Failure of collection system:
Pump failure Effect repairs, planned maintenance, increase routine inspection by operator
Pipework failure Effect repairs, increase inspection frequency, increase routine inspection by operator
Flare system: Failure of flame Automatic re-ignition or shutdown fitted?
Poor flame / combustion:

(Incorrect gas mixture For all factors - See guidance and recommendations in EA Landfill Gas guidance6
Incorrect temperature
Low residence time)
Height of flare stack
6
Technical Guidance for Landfill Gas Flaring in the UK
TABLE A1 (contd.)
Leachate system:
Septic leachate, high sulphide content Treat empirically with H2O2, Ozone etc. Increased frequency of monitoring & reporting by
Open leachate monitoring chimneys operator
Odour release by aeration Consider covering and attaching to scrubber or landfill gas flare system
High surface area, uncovered Consider alternative treatments
Reduce area, cover
Landfill Sites (contd)
Operational activities / failures:

Inadequate compaction Increase compaction rate
Large working face / area Reduce size / area. Location of deposits – move tipping area
Wastes not buried quickly enough Cover progressively
Use of cover:
7
Type/Depth/Maintenance of old See guidance and recommendations in EA Landfill Cover Task & Finish Group output
Excavations into old wastes:
Excavation of trenches Prior information to Agency? Proactive Informative around locality and cover quickly
Drilling of wells Prior information to Agency? Proactive informative around locality and cap quickly
Slow burial of excavated wastes Bury immediately
Open trenches Consider covers & use of odour scrubbers
Can be effective but often more offensive to people in the locality than waste odours due to
Use of odour counteractants or neutralisers “false” odour or unknown constituents (fear element). Should be used selectively and with
caution
Many atmospheric conditions e.g. high pressure, calm, foggy, or inversion can exacerbate,
Weather conditions prolong or increase the range of any odour present as a result of operational conditions on any
site. Consider phasing of tipping sequence in respect of prevailing wind and weather conditions
Location of site with respect to receptors Planning considerations - appropriate use of land? Effect of Topography
7
Review and Guidance on the Use of Landfill Cover Materials. Edition 1.0. May 2000
TABLE A1 (contd.)
Composting of Odorous Wastes Review working plan procedures. Ultimately review nature and range of wastes accepted
Operational activities / failures:
Composting
Monitoring of temperatures Needs careful attention, operator responsibility

Facilities
Waste turning anaerobic Needs careful attention, see below

Turning compost at required intervals Fundamental principle, important to maintain aerobic state by turning or introduction of air by
other means
Height of windrows Maximum height - 2 metres
8
See EA guidance on Composting
Location of site in relation to proximity of
Planning consideration - appropriate use of land. Consider requirement to enclose facility
receptors
Disposal of Odorous Wastes:
Residual wastes Attention to end of day cleanliness required in case of putrescible wastes
Transfer Stations
Age of wastes Household wastes already up to at least two / three weeks old on arrival. Process quickly
Ventilation Doors that open only to allow passage of vehicles probable recipe for trouble without roof level
ventilation. Roof level ventilation also likely to require scrubbers or filters which in themselves
will require regular inspection / maintenance
Opening of tankers, drums etc. for Can cause severe odour problems in locality. Should be carried out under negative pressure
inspection, sampling etc. Transfer of situations with extraction and scrubbing
wastes from drum to bulk
Nature of wastes Consider review nature of wastes accepted
See also EA guidance on clinical waste facilities9
8
Technical Guidance on Composting Operations. V3.0, for external consultation.
9
Technical Guidance on Licensing Clinical Waste Facilities
TABLE A1 (contd.)
Control matter, need for attention to operational detail. Potential ‘Duty of Care’ issue if wrong
Physical & Chemical
Blending: Incompatible wastes

information given
Treatment Plants.
Neutralisation, redox, precipitation:

Odour from incompatible wastes, Odour collecting / treatment hoods over tanks/vents. Control matter, correct information
unexpected reactions available? Wastes checking procedures? Potential ‘Duty of Care’ issue if wrong information
given
Overheating Odour collecting / treatment hoods over tanks/vents. Process control matter. Correct
information about wastes available? Potential ‘Duty of Care’ issue if wrong information given.
Wastes checking procedures?
Location of site with respect to proximity of

Planning consideration - appropriate use of land
receptors
Age of waste/Onset of anaerobic conditions Minimise storage period

Storage &
Transport
Waste is Food and food processing wastes,

Minimise quantity handled per load, minimise transit / storage time
including brewery wastes
The transport of wastes is not a licensing issue but since this activity has significant potential for
the creating of odour nuisance it is felt worthy of note that this is a potential ‘Duty of Care’ issue
or ‘Harm to Human Health’ issue within the meaning of Section 29 EPA, but officers might be
Transport of Wastes
able to influence at source via liaison with the local authority in respect of odour at the source
site or by giving advice in respect of the timing of transportation and the route taken to the
disposal / recovery facility.

APPENDIX B - PROCEDURE FOR CARRYING OUT AN ASSESSMENT OF ODOUR AT
WASTE MANAGEMENT FACILITIES

PROCEDURE FOR CARRYING OUT AN ASSESSMENT OF ODOUR FROM WASTE
MANAGEMENT FACILITIES BY AGENCY OFFICERS
B1 OBJECTIVE
B1.1 To provide a clearly written procedure for a consistent, albeit subjective, assessment of odours
around licensed waste management facilities.
B1.2 It is intended that this guidance lays down a framework of principles which can be applied
consistently. It is realised that there will be a need for local adaptation of monitoring
procedures according to conditions at the site in question, its location and local surroundings,
the nature of any complaints, and reporting procedures according to management arrangements
and resource availability.
B2 PROCEDURES
B2.1 General
B2.1.1 To carry out the assessment, the inspector uses his own sense of smell to try and detect odours,
which may arise from the site being assessed. Each inspector likely to be involved in carrying
out odour assessments should initially accompany a more experienced inspector on an
assessment to ensure that the nature and offensiveness of any odours detected are being
perceived similarly. In addition, two or more officers should occasionally carry out assessments
together to ensure that assessments continue to be carried out to the same perceptions. If an
inspector has a cold, sore throat, sinus trouble etc. they should not carry out the assessment.
B2.1.2 Assessments should be carried out both routinely and in response to specific complaints. In
addition assessment should be carried out which are targeted to weather conditions likely to lead
to adverse odour at identified receptors. To this end, each inspector involved in carrying out
odour assessments must have regard to the weather forecasts for the area, including wind
strength and direction, barometric pressure, rainfall, temperature and humidity.
B2.1.3 Specific attention to the following points of detail should be noted:-
• The inspector should not smoke or consume strongly flavoured food or drink, including
coffee, for at least half an hour before the assessment is carried out.
• The consumption of confectionery or soft drinks should be avoided immediately before
and during the assessment.
• Scented toiletries, such as perfume/aftershave should not be applied immediately before
or during an assessment.
• The vehicle used during the assessment should not contain any deodorisers.
B2.1.4 Any complaint or contact regarding odour should be recorded in the appropriate manner, be it
incident form, contact form, log book or diary and responded to in accordance with the targets
set in the Agency’s Customer Charter. Section 5.7 indicates what, ideally, should be recorded
when a complaint is received. The licence holder should be informed when a complaint has
been received and should be aware, on a general basis, that an odour assessment is likely to be
undertaken by an inspector on the day of receipt of the complaint, if practicable.

B2.1.5 Where complaints are received on a regular basis, an odour assessment should be carried out on
each site visit and statistics of complaints received and odour assessments carried out should be
kept and maintained by those involved.
B2.2 At the Assessment Location
B2.2.1 The assessment involves the inspector walking, as far as access allows, from a point, at a
distance from the site, towards the site boundary (or onto the site itself) and then continuing on
away from the site again. Where the assessment is being carried out routinely, the starting point
should be down wind of the site, progressing towards the site boundary and then away from the
site in an up wind direction. Where the assessment is being carried out in response to a specific
complaint, the starting point will be the location from which the complaint was made. When
arriving to carry out an assessment, the inspector should not go straight to the site, but rather
to the intended starting point.
B2.2.2 In carrying out the assessment, the inspector should walk slowly and breathe normally. If odour
cannot be detected in this way, the inspector should periodically stand still and inhale deeply.
(Note: If odour but can only be detected by inhaling deeply, the intensity should be noted as 2
(faint). If odour is detected while walking, the intensity should be recorded as at least 3 – see
B3.3.1)
B2.2.3 At appropriate intervals, the intensity, extent, i.e. persistence, and a description of the odour,
together with the location from site boundary, should be recorded. In addition the sensitivity of
the location where the assessment is being made, with regard to receptors, should be noted (see
B3.3), as well as any external activities such as agricultural practices that could be the source of
the odour. The possibility that an odour may change with distance due to dilution effects should
be taken into consideration.
B2.2.4 Periodically, the odour assessment around sites considered to be sensitive should include fixed
location assessments. The inspectors responsible for the site should determine a number of
receptor-sensitive locations. These locations will be determined from analysis of existing data
and of complaints received.
B2.2.5 A fixed location assessment should incorporate measurements reported over a standard time
period, say 5 minutes per location. The intensity and extent can then be evaluated over a time
period. Either, the intensity and duration of odour should be measured each time odour is
perceived, or measurements should be made at fixed time intervals, over a 5 minute period every
30 seconds would be the minimum requirement. For the latter method, a standard yes/no
response would be required as well as indication of intensity, but extent measurements would
not be necessary.
B2.2.6 On eventual arrival at the site the atmospheric conditions prevalent at the time, See Appendix
C, should be evaluated if possible and recorded against site-specific factors, such as the location
and nature of site activities and location of sensitive receptors. A compass and hand-held
anemometer would be useful but is not essential
B2.2.7 The appropriate part of the site boundary relative to wind direction or complaints should first be
walked to detect any odour. Once again the inspector should walk slowly and breath normally.
When odour cannot be detected in this way, the inspector should again periodically stand still
and inhale deeply facing upwind. In this respect, a common sense approach should be taken

and the inspector should not inhale deeply over any boreholes. Particular care should be taken
if any sulphidic (rotten eggs) odours are perceived.
B2.2.8 In order to determine the extent of the odour "plume” in sensitive areas, it may become
necessary to carry out assessments away from the site at points perpendicular to the plume axis
and equidistant from the source. The results should be plotted onto an appropriate plan. In
some circumstances it may be difficult to conduct such a survey because of the lack of access to
land in the vicinity of the site.
B2.2.9 Following an odour assessment a site inspection should be carried out seeking to trace any
observed odour back to source and to evaluate any potential odour-producing activities or
locations. Appendices A and C may prove useful in the respect.
B2.3 How to report the results
B2.3.1 All observations should be noted on the odour assessment report, following the classification
system for odour parameters. Observations should be reported to a member of the site’s
technically competent management following the inspection. A report form is suggested in
Section B3 of this appendix. However, this paper does not seek to impose yet another form on
Agency officers if there exists already adequate alternative means of recording necessary
information.
B2.3.2 The odour inspection report should be passed to the appropriate senior inspector for signing and
recording what further action is required, e.g. letter to licence holder requiring odour control or
enforcement of licence condition requiring no odours beyond site boundary. The result of the
odour assessment, and any action required, should be confirmed on the completed assessment
report and the impact of odour arising from the site should be discussed with the licence holder
at regular liaison meetings.
B2.3.3 Consideration should be given to carrying out periodic VOC surveys with the licence holder at
sites where particular problems have been identified. The inspector should discuss this with his
Line Manager before approaching the licence holder. Sampling for analysis of odorous trace
gases should not be carried out routinely but may be considered if a significant odour problem is
being disputed by the licence holder or proving difficult to resolve.
B2.3.4 A spreadsheet file can be set up for storing odour assessments for identified sites and
responsibility for inputting collected data should lie with the primary inspector.
B2.3.5 Data should be input at least monthly, and sorted by date and location. Each inspector should
be trained in the use of all applicable input and output functions.
B2.3.6 A bar chart for intensity, extent and sensitivity can be set up for one location at each site. The
chart should be revised monthly, by altering the range, and output for appropriate locations
printed as required. Other graphical methods, including time-series XY plots, should be used as
required, for example, for discussion at liaison meetings or to evaluate changes in operational
practices.
B2.3.7 A rose diagram can set up to display wind direction for each site. This should be updated daily
and output printed on a monthly or quarterly basis, depending on the number of assessments
carried out.

B2.3.8 Output for each site should be assessed at a frequency dependent on conditions encountered and
complaints received, but at no less than once per quarter.
B2.3.9 Odour assessments should be carried out at a frequency determined by the potential for odour to
cause a problem and number of complaints received, and this frequency should be reviewed by
the line manager, in consultation with Licensing Officer and the responsible Area Functional
Manager on a regular basis.
B2.4 Training and calibration
B2.4.1 All inspectors responsible for assessing odour should be trained in the use of this procedure.
B2.4.2 For each sensitive and high risk site, and at a frequency no less than twice a year, two inspectors
should carry out an odour assessment independently but simultaneously. The completed
assessment reports should then be sent to the responsible officer, to evaluate for consistency.
Such exercises can be used to confirm how representative the odour assessments are.
B2.4.3 Consideration may also need to be given to evaluating the sensitivity of each inspector’s sense
of smell using olfactometry methods.

B3 ODOUR ASSESSMENT REPORT
B3.1 Report Pro-forma
B3.1.1 A suggested pro-forma for reporting the results of the Odour Assessment is shown on the
following pages.
B3.2 Notes on Completing Proforma
B3.2.1 To complete the entry on ‘General Air Stability’ reference should be made to appendix C.
B3.2.2 The entry for ‘General Air Quality’ should include whether or not the air quality is good,
average or poor as this may influence odour perception on the day.
B3.2.3 The entry for ‘Ground Conditions’ should record whether the ground is wet as a result of recent
rainfall as this may influence odour dispersion.
B3.2.4 ‘External Sources of Odour’ refers to activities, not associated with the waste management
facility being assessed, that could be a source of odour.
B3.2.5 For entries on ‘Odour Intensity’, ‘Odour Extent’ and ‘Location Sensitivity’, the classification
system presented in B3.3 below should be used.
B3.3 Classification System for odour Parameters
B3.3.1 Intensity
1 No detectable odour
2 Faint odour (barely detectable, need to stand still and inhale facing into the wind)
3 Moderate odour (odour easily detected while walking and breathing normally,
possibly offensive)
4 Strong odour (bearable, but offensive odour - will my clothes/hair smell?)
5 Very strong odour (this is when you really wish you were somewhere else)
B3.3.2 Extent (assuming odour detectable, if not then 0)
1 Local and impersistent (only detected during brief periods when wind drops or blows)
2 Impersistent as above, but detected away from site boundary
3 Persistent, but fairly localised
4 Persistent and pervasive up to 50 m from site boundary
5 Persistent and widespread (odour detected >50 m from site boundary)
B3.3.3 Sensitivity of Location where Odour Detected

(assuming detectable, if not then 0)
1 Remote (no housing, commercial/industrial premises or public area within 500 m)

2 Low sensitivity (no housing, etc. within 100 m of area affected by odour)
3 Moderate sensitivity (housing, etc. within 100 m of area affected by odour)
4 High sensitivity (housing, etc. within area affected by odour)
5 Extra sensitive (complaints arising from residents within area affected by odour)

ODOUR ASSESSMENT REPORT FILE NO.
Site Assessment Date
Assessment Start Time Assessment Finish Time
Complaint Received Yes/No Date
Location of Complaint Grid Reference (where

Area location is not a property)
Weather Wind (strength and

direction)
Temperature Bar Pressure
(deg. C) (mbar)
(rising/falling)
% Cloud Cover General Air Stability
(see appendix C)
General Air Quality Ground Condition
Enter results of assessment overleaf
Plan attached showing location and extent of odour Yes/No
Additional comments
Action required
Reported to on site :
Signature :

ODOUR ASSESSMENT REPORT contd.
Sensitivity
Intensity
Location
Extent
Odour
Odour
Location Odour Description External sources of odour Waste sources of odour
Odour Intensity Odour Extent (assuming odour detectable, if not then 0)

1 -No detectable odour 1 -Local and impersistent (only detected during brief periods when wind drops or blows)
2 -Faint odour (barely detectable, need to stand still and inhale facing into the wind) 2 -Impersistent as above, but detected away from site boundary
3 -Moderate odour (odour easily detected while walking and breathing normally, possibly offensive) 3 -Persistent, but fairly localised
4 -Strong odour (bearable, but offensive odour - will my clothes/hair smell?) 4 -Persistent and pervasive up to 50 m from site boundary
5 -Very strong odour (this is when you really wish you were somewhere else) 5 -Persistent and widespread (odour detected >50 m from site boundary)
Location Sensitivity (assuming detectable, if not then 0)

1 -Remote (no housing, commercial/industrial premises or public area within 500 m)
2 -Low sensitivity (no housing, etc. within 100 m of area affected by odour)
3 -Moderate sensitivity (housing, etc. within 100 m of area affected by odour)
4 -High sensitivity (housing, etc. within area affected by odour)
5 -Extra sensitive (complaints arising from residents within area affected by odour)
APPENDIX C - METEOROLOGICAL DATA

METEOROLOGICAL DATA
C1 GENERAL
C1.1 This appendix is included as general guidance since it is useful, and usually necessary, to take
account of meteorological conditions in determining causes and patterns of odour problems,
where they exist. The transport of pollutants from the source to receptor are affected by
meteorological variables, or state of the atmosphere in terms of; wind speed and direction;
insolation (amount of sunlight); lapse rate (temperature variation with height); mixing depth, and
precipitation. The non-meteorological factors such as type and quantity of odorous substances,
topography and individual susceptibility must also be considered. It is not intended that full
meteorological monitoring should take place at every site.
C2 ATMOSPHERIC STABILITY
C2.1 When considering the dispersion of air pollution or odour plumes, it is convenient to classify the
possible states of the atmosphere into stability categories originally defined by Pasquill10. An
assessment of the stability category should be made when odour monitoring as this describes the
potential for dispersion of odours from a source.
C2.2 Table C2.1 illustrates typical features of each category and the extent of dilution that may be
expected under different atmospheric conditions.
C2.3 Stability Categories range from A, the most unstable, though to G, the most stable.
• Category A corresponds to the most unstable atmospheric conditions and results in the
greatest amount of plume spreading. Surface heating effects caused by direct sunlight act as
an extra source of turbulence over and above that caused by the wind.
• Category D, a “neutral” category is one where the turbulence is generated entirely by the
wind and the degree of mixing will be less than Category A.
• Category F/G are stable categories which result in the least spreading of a plume as the
mechanical (wind induced) turbulence is suppressed in these conditions.
10
F Pasquill and F B Smith, “Atmospheric Diffusion”, Chichester, Ellis Horwood, 1983

Table C2.1 Atmospheric Stability Categories
Category Stability Dispersion* Occurrence Wind speed Time of day Sunshine or cloud cover
(% time in km/h
year)
A Very Unstable Very good Day time only Strong sunshine
<1 <5 Most common in summer
B Unstable Good 5 to 10 7 to 18 Day time only Slight to moderate sunshine
C Slightly Unstable Moderate 20 >7 Mainly day time Moderate sunshine
D Neutral Moderate 45 to 60 7 to 29 Day or night Slight sunshine or overcast
E Stable Poor 5-10 7 to 18 Night time only Clear or overcast
F/G Very Stable Very poor 10 <11 Night time only Clear (inversion)
* These are generalisations – e.g. Category A, while on average it may result in good dispersion, fluctuations in plume rise may result in localised short-term plugs of
odour in the vicinity of the site.
C2.4 The term stability refers to the tendency of the atmosphere to resist or enhance vertical motion and therefore turbulence. Stability is related to
both the change of temperature with height, which is often dependent on wind speed and the amount of sunlight and will therefore differ between
daytime and nighttime. The turbulence of the atmosphere is important determining the amount of dilution of odours. As a general rule, the more unstable
the atmosphere, the greater the dilution and the lower the odour impact of the site. Odour problems are more likely to occur when wind speeds are low
and skies are overcast, and at night when stable conditions are more common.

Table C3 The Beaufort Wind Scale
Force Description Observation km/hour
0 Calm Smoke rises vertically <1
1 Light air Direction of wind shown by smoke drift, but

not wind vanes 1-5
2 Light breeze Wind felt on face; leaves rustle, ordinary

vane moved by wind 6 - 11
3 Gentle breeze Leaves and small twigs in constant motion

12 - 19
4 Moderate Raises dust and loose paper; small branches

breeze are moved 20 - 29
5 Fresh breeze Small trees in leaf begin to sway, small

branches are moved 30 - 39
6 Strong breeze Large branches in motion; umbrellas used

with difficulty 40 - 50
7 Near gale Whole trees in motion; inconvenience felt

when walking against wind 51 - 61
8 Gale Twigs break off trees; progress generally

impeded 62 - 74
9 Strong gale Slight structural damage occurs (chimney

pots and slates removed) 75 - 87
10 Storm Trees uprooted; considerable structural

damage occurs 88 - 101
C3.1 The above table provides a rough approximation of wind speed in the absence of an
anemometer. A rough idea of wind direction can be obtained by observation, e.g. of smoke
plumes if appropriate, and reference to OS maps.

APPENDIX D - ODOUR DESCRIPTORS

ODOUR DESCRIPTORS
D1.1 The following information is included principally for background interest but also as an aid to
officers in their own assessment of odours, particularly in establishing the source of odours other
than those from waste management facilities.
D1.2 As indicated in section 5.7, it is useful, when recording information from a complainant, to seek
their description of an odour that is offending them. Tables D1 and D2 are derived from
American research work11 on odour descriptors which also concludes, as suggested at 2.1.3 in
the main body of this document, that both pleasant and unpleasant odours may become
offensive.
D1.3 Table D1 lists odour descriptors generally found as pleasant in decreasing order of pleasantness
based on “Hedonic scores” allocated by 150 participants in the American research. Similarly,
Table D2 lists unpleasant odours in increasing odour of unpleasantness.
D1.4 Table D3 presents the same odour descriptors in alphabetical order so that their pleasant or
unpleasant rating is not indicated and would not therefore influence the use of a particular
descriptor.
D1.5 Figure D1 presents an “Odour Wheel” which attempts to link recognised waste derived odours
with possible sources on waste management facilities.
11
Dravnieks A, Masurat T, Lamm R A, “Hedonics of Odours and Odour Descriptors”:, in Journal of the Air Pollution Control
Association, July 1984, Vol. 34 No. 7, pp 752-755

Table D1 “Pleasant” Odour Descriptors and “Hedonic” Score
Description Hedonic Description Hedonic Description Hedonic

Score Score Score
Bakery (fresh bread) 3.53 Spicy 1.99 Eucalyptus 0.99
Rose 3.08 Peanut butter 1.99 Laurel leaves 0.97
Strawberry 2.93 Perfumery 1.96 Soapy 0.96
Orange 2.86 Grapefruit 1.95 Woody, resinous 0.94
Floral 2.79 Coconut 1.93 Light 0.91
Chocolate 2.78 Nutty 1.92 Dill 0.87
Fruity, citrus 2.72 Clove 1.67 Warm 0.78
Violets 2.68 Cooked vegetables 1.58 Grainy (as grain) 0.63
Peach 2.67 Raisins 1.56 Geranium leaves 0.57
Apple 2.61 Cool, cooling 1.53 Beany 0.54
Pineapple 2.59 Aromatic 1.41 Mushroom 0.52
Vanilla 2.57 Tea leaves 1.40 Eggy (fresh eggs) 0.45
Cherry 2.55 Green pepper 1.39 Raw potato 0.26
Cinnamon 2.54 Celery 1.36 Musky 0.21
Fried chicken 2.53 Crushed grass 1.34 Black pepper 0.19
Fragrant 2.52 Hay 1.31 Cork 0.19
Lemon 2.50 Raw cucumber 1.30
Minty, peppermint 2.50 Leather 1.30
Popcorn 2.47 Seasoning (for meat) 1.27
Melon 2.41 Oak wood, cognac 1.23
Meaty (cooked, good) 2.34 Anise (liquorice) 1.21
Coffee 2.33 Bark, birch bark 1.18
Caramel 2.32 Soupy 1.13
Pear 2.26 Caraway 1.06
Maple syrup 2.26 Malty 1.05
Lavender 2.25 Incense 1.01
Fruity, other than 2.23 Molasses 1.00
citrus
Fresh green 2.19
vegetables
Cologne 2.16
Herbal, green, cut 2.14
grass
Cedarwood 2.11
Honey 2.08
Grape juice 2.07
Buttery, fresh butter 2.04
Sweet 2.03
Almond 2.01
Banana 2.00
Note: The higher the positive “score”, the more pleasant the odour descriptor and similarly below, the
greater the negative figure, the more unpleasant the odour descriptor.

Table D2 “Unpleasant” Odour Descriptors and “Hedonic” Score
Description Hedonic Description Hedonic Description Hedonic

Score Score Score
Dry, powdery -0.07 Seminal, sperm-like -1.04 Stale -2.04
Yeasty -0.07 Animal -1.13 Burnt milk -2.19
Burnt candle -0.08 Gasoline, solvent -1.16 Mouse-like -2.20
Beery -0.14 Mothballs -1.25 Wet wool, wet dog -2.28
Rope -0.16 Sour, vinegar -1.26 Household gas -2.30
Garlic, onion -0.17 Creosote -1.35 Sharp, pungent, acid -2.34
Crushed weeds -0.21 Bitter -1.38 Sulfidic -2.45
Alcoholic -0.47 Oily, fatty -1.41 Ammonia -2.47
Cardboard -0.54 Burnt paper -1.47 Sweaty -2.53
Camphor -0.55 Burn, smoky -1.53 Dirty linen -2.55
Sauerkraut -0.60 Etherish, anaesthetic -1.54 Fermented (rotten) -2.76
fruit
Fresh tobacco smoke -0.66 Disinfectant, carbolic -1.60 Stale tobacco smoke -2.83
Kippery-smoked fish -0.69 Tar -1.63 Sour milk -2.91
Turpentine (pine oil) -0.73 Chemical -1.64 Burnt rubber -3.01
Paint -0.75 Blood, raw meat -1.64 Rancid -3.15
Heavy -0.79 Kerosene -1.67 Urine -3.34
Nail polish remover -0.81 Cleaning fluid -1.69 Sickening -3.34
Varnish -0.85 Sooty -1.69 Faecal (like manure) -3.36
Chalky -0.85 Musty, earthy, mouldy -1.94 Cat urine -3.64
Medicinal -0.89 Fishy -1.98 Sewer odour -3.68
Wet paper -0.94 Putrid, foul, decayed -3.74
Metallic -0.94 Cadaverous (dead -3.75
animal)
New rubber -0.96

Table D3 Odour Descriptors without “Hedonic” Score
Alcoholic Eggy (fresh eggs) Oak wood, cognac

Almond Etherish, anaesthetic Oily, fatty
Ammonia Eucalyptus Orange
Animal Faecal (like manure) Paint
Anise (liquorice) Fermented (rotten) fruit Peach
Apple Fishy Peanut butter
Aromatic Floral Pear
Bakery (fresh bread) Fragrant Perfumery
Banana Fresh green vegetables Pineapple
Bark, birch bark Fresh tobacco smoke Popcorn
Beany Fried chicken Putrid, foul, decayed
Beery Fruity, citrus Raisins
Bitter Fruity, other than citrus Rancid
Black pepper Garlic, onion Raw cucumber
Blood, raw meat Gasoline, solvent Raw potato
Burn, smoky Geranium leaves Rope
Burnt candle Grainy (as grain) Rose
Burnt milk Grape juice Sauerkraut
Burnt paper Grapefruit Seasoning (for meat)
Burnt rubber Green pepper Seminal, sperm-like
Buttery, fresh butter Hay Sewer odour
Cadaverous (dead animal) Heavy Sharp, pungent, acid
Camphor Herbal, green, cut grass Sickening
Caramel Honey Soapy
Caraway Household gas Sooty
Cardboard Incense Soupy
Cat urine Kerosene Sour milk
Cedarwood Kippery (smoked fish) Sour, vinegar
Celery Laurel leaves Spicy
Chalky Lavender Stale
Chemical Leather Stale tobacco smoke
Cherry Lemon Strawberry
Chocolate Light Sulfidic
Cinnamon Malty Sweaty
Cleaning fluid Maple syrup Sweet
Clove Meaty (cooked, good) Tar
Coconut Medicinal Tea leaves
Coffee Melon Turpentine (pine oil)
Cologne Metallic Urine
Cooked vegetables Minty, peppermint Vanilla
Cool, cooling Molasses Varnish
Cork Mothballs Violets
Creosote Mouse-like Warm
Crushed grass Mushroom Wet paper
Crushed weeds Musky Wet wool, wet dog
Dill Musty, earthy, mouldy Woody, resinous
Dirty linen Nail polish remover Yeasty
Disinfectant, carbolic New rubber
Dry, powdery Nutty

Figure D1 Odour Wheel
The odour wheel above makes an attempt to link commonly used descriptors of odours around waste
management facilities with the most likely chemical cause and/or origin(s).
Note: Butyl mercaptan is listed in the original version of WMP26 as an identified likely
constituent of landfill gas. Being a mercaptan, it is highly odorous but the Merck Index
merely describes its odour as “Skunk like.”
There are very few people who have experienced skunk odour but the author is indebted
to the Head Keeper of Exeter Zoo for his colourful descriptions having had first hand
experience of the odour. These simplify to “an intense clinging combination of rotting
cabbages and rotting onions.”

APPENDIX E - UNDERSTANDING SMELL

UNDERSTANDING SMELL
This document concentrates on subjective odour monitoring as the initial regulatory procedure for
assessing the nature, strength and extent of any odour problems originating from waste management
facilities. However, it is important to realise that the ability to detect, and often describe, smells varies
from person to person in much the same way as the ability of other senses vary, e.g. sight and hearing.
The following is therefore intended as background reading endeavouring to put the perception of smell
into perspective and indicate how, at times, it can be misleading or even fail.
E1 Realistic expectations of the nose
Some facts 12
§ The nose is considered to be the organ of the sense of smell for the body, but its main function is to
adjust inhaled air to body temperature and to humidify it before it goes down into the delicate
linings of the lungs. It does this by passing the air through its narrow vascular passages.
§ The average person breathes about 8 litres of air (23,000,000 molecules) every minute and the
weight of the daily intake of air has been calculated to be about 13.5 kg.
§ The olfactory chambers, containing the smell receptors, are found at the top of the nose, behind the
bridge. The area of the olfactory epithelia (smell cells) is about the size of a postage stamp with
half at the top of each nostril. A sniff causes an eddy of air to pass into the upper chamber and any
odorous molecules can then come into contact with the olfactory receptors and be detected as smell.
§ In order to be odorous a compound must have a molecular mass of between 15 and 300. For
example, alcohol (C2H5OH) with a molecular mass of 46 is odorous, whereas sucrose (C12H22O11),
with a molecular mass of 342, is not. So in order to be smelt, molecules must lie within a certain
size range, but in order to penetrate the mucous layer covering the smell cells, they must also be
soluble in water and lipids.
§ The average person can detect by smell 1 g (7 x 1012 molecules) of butanoic acid (a sweaty, cheesy
smell) dispersed uniformly throughout a ten-storey building.
§ The Guinness Book of Records lists vanilla aldehyde (4-hydroxy-3-methoxy benzaldehyde) as the
most pungent smell, detectable at 2 x 10-8 mg/litre of air. About 1 drop (2.75 x 10-3 g) would be
detectable in an enclosed space 13.7 m high and with the floor area of a football pitch.
§ From the olfactory cells the nerve impulses pass into a complex circuit in the brain called the limbic
system. This system is now known to be vital for emotion and motivation states as well as thought
and memory processes. People can rapidly say how they feel about a particular smell.
§ The limbic system, although crucial to behaviour, is a non-verbal part of the brain. This fact results
in people having difficulty when asked to name a smell.
§ The way the sense of smell links to our brain means that it is primarily controlled by the non-verbal,
unconscious stages, and therefore it can affect our behaviour in ways of which we may not be
consciously aware.
12
Source: What the Nose Knows, Steve Van Toller, Biological Sciences Review, May 1995, pp 2-5

§ Perfumers, who are often chemists, and other professionals for whom the sense of smell is critical,
learn to use smell classifications to communicate information about odours, but in general, people
perform poorly when asked to name odours.
§ To show just how difficult it is to describe and name smells, ask a person to name ten smells and
time how long it takes them to produce their list. Then ask the same person to name ten colours,
also against the clock. With another person, reverse the process asking them to name colours first
and then smells. You will usually find a great discrepancy in the time it takes for people to list ten
items in these two categories, with the smells taking longer to produce.
§ One reason contributing to the difficulty in naming smells is that while colour names are taught to
children at a very early age, it would be very unusual, apart from the rather basic “nice” and “nasty”,
for a child to be taught smell names.
E2 Odour fatigue
Odour fatigue can take a number of different forms:-
§ At one extreme there is the action of gases such as hydrogen sulphide. In hazardous
concentrations, the first action of hydrogen sulphide is to paralyse the olfactory nerves rendering the
nose unable to detect its rotten egg odour, thus increasing the hazardous potential.
§ At a different level, it is likely that if you wear perfume or aftershave you will quickly become
unaware of the perfume given off by your own toiletry. However, you are still likely to be aware of
the perfume given off by the toiletry being worn by someone passing close to you and vice versa.
§ In the same way, people working in an odorous situation, such as a waste management facility, will
quickly become unaware of their odorous surrounding possibly to the extent that they are unable to
detect regular odours.

INDEX

incompatible ................................................24, 27
A
inhale..................................................... 32, 34, 37
amenity.............................4, 7, 8, 9, 10, 12, 15, 16 inspection(s) ...................................... 4, 13, 14, 15
local ..............................................................12
L
anemometer ................................................. 31, 42
atmospheric conditions ................................ 25, 31 Landfill gas........................................................24
leachate.................................................. 11, 20, 25
B
liaison ........................................ 13, 15, 27, 32, 33
bar chart ............................................................33 licence ........ 4, 6, 7, 8, 9, 10, 11, 12, 15, 16, 30, 32
conditions.............................. 6, 8, 9, 11, 12, 15
C
limbic system .....................................................54
complainants .....................................................14 Local Authority........................................ 9, 15, 20
complaints ...... 9, 14, 15, 17, 30, 31, 32, 33, 35, 37 log book .............................................................30
compliance ........................................................16
M
contact form.......................................................30
controlled waste.................................................10 mass spectrometry..............................................15
cover...................................................... 11, 24, 25 mercaptan ..........................................................50
Criminal Procedure and Investigation Act..........16 monitor .................................................. 12, 13, 15
monitoring4, 6, 8, 11, 13, 14, 15, 20, 25, 30, 40, 54
D
audit..............................................................14
detriment subjective .................................... 10, 14, 15, 30
serious....................................................... 8, 10
N
detriment to amenity..........................................15
diary............................................................ 18, 30 Nose
Directive..............................................................4 expectations of...............................................54
Framework.............................................. 4, 7, 8 notice.............................................................9, 16
drums .......................................................... 20, 26 nuisance............................................... 4, 8, 11, 27
Duty of Care ................................................ 13, 27 Nuisance
Statutory..................................................4, 8, 9
E
O
emissions....................................................... 9, 12
enforcement................................................. 16, 32 observations.................................................17, 32
EPA90........................................... 7, 9, 10, 13, 16 odour
exempt................................................. 6, 9, 11, 13 assessment........ 4, 10, 12, 30, 31, 32, 33, 40, 46
assessment.....................................................54
F
control............................................. 4, 5, 11, 32
fire ....................................................................24 controls ....................................... 4, 7, 8, 11, 15
flare system .......................................................24 counteractants ...............................................25
definition.........................................................6
G
duration.........................................................31
gas chromatography...........................................15 fatigue...........................................................14
gas wells............................................................20 location ................ 11, 12, 14, 30, 31, 32, 33, 36
GP .....................................................................20 offensive.............................. 4, 9, 11, 12, 13, 15
graphical methods..............................................33 perception .......................................................4
persistence.....................................................31
H
plume............................................................32
harm.......................................4, 7, 8, 9, 10, 13, 16 release of .......................................................11
health sources ........................................ 10, 14, 15, 46
human................................4, 7, 8, 9, 10, 13, 16 strength .........................................................17
Health odour fatigue......................................................55
Environmental ................................ 4, 8, 15, 20 offence ....................................... 7, 8, 9, 10, 13, 16
Public..............................................................8 olfactometry.................................................15, 33
health and safety.......................................... 20, 24 olfactory epithelia ..............................................54
Health and Safety Executive.................................4 operational practices ................................ 4, 11, 33
health effects......................................................20 other sources......................................................15
hydrogen sulphide..............................................55
P
I
Pasquill stability.................................................40
incident form .....................................................30 pathways ............................................................10

planning......................................... 8, 9, 25, 26, 27 odorous .........................................................13
Police and Criminal Evidence Act .....................16 weather conditions ........................... 10, 12, 17, 30
pollution ...................................7, 8, 10, 11, 16, 40 wells ..................................................................25
pollution of the environment.................... 7, 10, 16 working face ......................................................25
PPG10 .................................................................8 working plan.................................... 10, 12, 16, 26
PPG23 .................................................................8
prevailing winds ................................................10
prosecution .................................................. 16, 17
R
receptors.......................................... 10, 14, 30, 31
recording ............................................... 14, 30, 31
relevant objective(s) ................................. 4, 7, 8, 9
remedial action ....................................................8
revocation ..........................................................16
risk .........................................4, 10, 11, 13, 24, 33
S
samples
air 15
scientific...................................................... 10, 15
Section 29...................................... 7, 8, 10, 13, 27
Section 33..........................................................13
Section 37..........................................................16
Section 38..........................................................16
Section 43..........................................................16
sense of smell ....................................................54
site boundary .................. 11, 12, 15, 31, 32, 34, 37
smell
detection .......................................................54
most pungent.................................................54
sense of .........................................................54
sources
nearby ...........................................................16
statement(s) ..................................... 10, 16, 17, 18
strategy..............................................................15
sulphidic............................................................32
suspension .........................................................16
T
tankers...............................................................26
toiletries.............................................................30
trace gases .........................................................32
training.......................................................... 4, 13
transportation ................................................ 4, 27
trenches .................................................... 25, 26
W
waste
putrescible.....................................................13
special...........................................................13
waste management facility........... 8, 10, 11, 13, 15
Waste Management Paper....................................7
waste regulation authority....................................8
wastes
brewery.........................................................27
burning.........................................................24
excavated ...................................................25
food......................................................... 27, 30


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ENVIRONMENT AGENCY

Internal Guidance for the Regulation of Odour

(Amended following external consultation)

The Working Group consisted of:-

Keith Ashcroft North West Region

Odour Guidance for Waste Sites, Version 3.0, July 2002 1

EXECUTIVE SUMMARY ............................................................................................................................ 4

4.0 LICENSING APPROACH ................................................................................................................. 11

5.0 INSPECTION AND MONITORING ................................................................................................. 13

6.0 ENFORCEMENT ............................................................................................................................... 16

APPENDIX A - FACTORS CONTIBUTING TO ODOUR PROBLEMS FROM WASTE

C2 ATMOSPHERIC STABILITY .......................................................................................................... 36

Odour Guidance for Waste Sites, Version 3.0, July 2002 2

Odour Guidance for Waste Sites, Version 3.0, July 2002 3

• the impact of odour on the surrounding environment is considered as part of

• odour is primarily controlled at source by good operational practices, the correct

Odour Guidance for Waste Sites, Version 3.0, July 2002 4

Odour Guidance for Waste Sites, Version 3.0, July 2002 5

2.1.1 A dictionary definition of odour gives:-

odour a) that characteristic property of a substance which makes it

b) a smell whether pleasant or unpleasant; fragrance or stench.

2.1.3 The subject of odour is a complex one.

2.2 Legal background

Odour Guidance for Waste Sites, Version 3.0, July 2002 6

2.2.6 Many waste management facilities will be subject to an environmental impact

Odour Guidance for Waste Sites, Version 3.0, July 2002 7

Odour Guidance for Waste Sites, Version 3.0, July 2002 8

2.2.16 The decision as to whether an odour constitutes a Statutory Nuisance is likely to

2.2.18 Regulation 18 of the 1994 Regulations makes it an offence for an establishment or

2.3 General considerations

Odour Guidance for Waste Sites, Version 3.0, July 2002 9

3.0 INFORMATION REQUIRED IN SUPPORT OF AN APPLICATION

Odour Guidance for Waste Sites, Version 3.0, July 2002 10

4.0 LICENSING APPROACH

§ The provision and maintenance of measures to secure the minimisation of release

Odour Guidance for Waste Sites, Version 3.0, July 2002 11

Odour Guidance for Waste Sites, Version 3.0, July 2002 12

5.0 INSPECTION AND MONITORING

Odour Guidance for Waste Sites, Version 3.0, July 2002 13

a) Name, address and telephone number of complainant(s)

Odour Guidance for Waste Sites, Version 3.0, July 2002 14

Odour Guidance for Waste Sites, Version 3.0, July 2002 15

Odour Guidance for Waste Sites, Version 3.0, July 2002 16

6.7 An officer’s statement should cover the following points:-

If the statement is in relation to an odour assessment (as described in Appendix B),

Odour Guidance for Waste Sites, Version 3.0, July 2002 17

Odour Guidance for Waste Sites, Version 3.0, July 2002 18

Issue notice under NO

Can the licence NO

Modify licence under S 43(6)

Odour Guidance for Waste Sites, Version 3.0, July 2002 19

Odour Guidance for Waste Sites, Version 3.0, July 2002 20

Odour Guidance for Waste Sites, Version 3.0, July 2002 21

Poor flame / combustion:

Height of flare stack

Operational activities / failures:

Monitoring of temperatures Needs careful attention, operator responsibility

Waste turning anaerobic Needs careful attention, see below

Disposal of Odorous Wastes:

Nature of wastes Consider review nature of wastes accepted

See also EA guidance on clinical waste facilities9

Blending: Incompatible wastes