Poor Identification of AirBorne Hazard While Establishing the Industrial Ventilation Systems as the control mechanics and ignorance of the importance of baseline monitoring.
How many times have we seen chimney emission report of a spray booth system recording not detected concentration of VOC ? Until we have had the CAR 2014, the revised version of Clean Air Regulation 1978, didn’t most of the emission monitoring parameters was based on Full Standard C without taking any regards of the airborne hazard being generated by the process ? Aren’t we not still seeing a scrubber monitoring objective is still very based on the six gaseous in CAR 1978 (Sulphuric Acid, Hydrochloric Acid, Chlorine, Hydrogen Sulphide, Hydrogen Fluoride, Oxides of Nitrogen) without checking the actual source ? Are we going to have these six gaseous and vapours detected when the actual source is something else altogether. Let’s not even get into the ambient air report if it ever make sense. We conduct ambient air report based on the parameters stipulated in the Recommended Malaysia Air Quality Guideline RMAQG without connecting any dot to the stationary source of emissions. Isn’t the sole purpose ambient air monitoring is to check if any chimney is undergoing downwash and increasing the ground level concentration of the pollutant being emitted. If the pollutant is not listed under the RMAQG, are we going to deem the industry is not causing environmental impact without even screening for the actual pollutant being emitted ? We have experience many incidents as such; a glove industry is in denial that the scrubber emission has residual chlorine when they don’t have the baseline load and peak results while also have had a non detected results from day one even though there a re changes in the system flow rate, a spray booth emission results which indicates Not detected VOC results in its report when they do not deploy any organic adoption system on it; a soldering company deems their emission results are ok when their fumes are completely clogging their adsorptive carbon filters, reducing the efflux velocity and system flow rate tremendously showing non detected results as the low flow rate not capturing the air borne hazard at source and not transporting it along the duct. We even had an auditor telling this client that efflux velocity is not a statutory regulated parameters for emission report and all one has to look at is only the parameters stipulated in CAR 2014. How can you evaluate a chimney performance when it is not functioning properly due to its flow rate is not within the acceptable operating condition. You do not conduct monitoring and testing when you know the system is out of specs. One has to rectify the fault before embarking into a periodical monitoring. The whole issue here is that people expect DOE to derive every single emission objectives and guide them how to operate their Industrial Ventilation System when in actual fact it is suppose to be the responsibility of the user and system designers to establish these highest level of airborne hazards / pollutant control operability. How many systems provider are training the end user to operate the system competently. OK….those are the rantings of the nonsensical patterns of adhering to statutory regulations with zero technical knowledge. Now allow us to present the facts in order to derive these rantings in a technical perspective complete with its counter measures for improvement.
The need to define the risk of airborne hazards prior to establishment of control mechanics
HOW TO IDENTIFY AIR BORNE POLLUTANT ?
Parameters to be used to identify and evaluate the risk of airborne hazards generated from process
MSDS, CSDS, Process analysis and the parameters stated in the figure above can play a crucial role in comprehensive identification of airborne hazards. Currently, based on guideline by Department of Occupational Safety and Health, there are systematic approaches in registering a particular chemical and evaluating its risk. This evaluation can be further enhanced by the industrial ventilation system designer by studying in depth the airborne hazard generation by conducting simulation or calculation to determine the generation at the point of generation. These simulation will provide the basis the significant airborne chemical emission, the emission dispersion towards the recipients breathing zone, the possibilities of fugitive dispersion in the event the local capture at LEV is not 100%, establishment of area emission monitoring for control measure integrity and baseline chemical exposure monitoring for workers health, proof of commissioning evaluating the permissible exposure limit upon start up of the LEV system or even GV system, baseline chimney emission monitoring and etc.
Sample of design simulation for airborne emission at the point of generation
The next time you call someone to design your industrial ventilation system, do ask them to determine the airborne hazard and get them to quantify the load and how their system will abate the airborne hazardous chemical at the point of removal and at the point of chimney emission. Do get them to determine the parameters for performance evaluation which consist of period chimney emission, daily, weekly and monthly performance monitoring, annual thorough assessment, emission declaration and every other measures to ensure the operation of any new system can be controlled to be efficient within the acceptable standard.
CONDUCT BASELINE MONITORING OF THE VERY SPECIFIC AIRBORNE CHEMICALS AND KEEP THE DATA AS THE PEAK LIMIT TO ENSURE THE OPERATION IS WITHIN THE BASELINE CONDITION
Do not conduct monitoring without identifying the exact air borne chemical involved in the process. This is why prior to any monitoring, a complete preliminary data which is to be gathered during the design stage on detail identification of the airborne hazards, the quantity, simulation, calculation, estimated emission, estimated results in comparisons to permissible exposure limit and permissible threshold limit values of the above said suspended chemicals. Once the data is in place, the next step will be baseline monitoring.
Baseline monitoring is a very important element in the project management of design, installation and commissioning of any industrial ventilation system, name it Local Exhaust Ventilation System or General Ventilation System. In fact, baseline monitoring is even important for a general ventilation which deploys a simple AHU system. The list of baseline monitoring which must be incorporated in the project management any Industrial Ventilation System are as follows :-
emission of identified airborne chemicals at the point of generation (area emission monitoring) - important to evaluate the control efficiency of any LEG and GV systems
exposure monitoring of the hazards before installation of any control system.
emission at the point of generation during the testing commissioning process (LEV, GV system are installed to remove airborne hazards as such baseline personal exposure and area must be conducted). This figure will also represent the baseline load into the air cleaning device.
The emission quality at the chimney or air cleaning device outlet also known as (baseline chimney emission quality). This monitoring must be compared to the baseline load to evaluate the abatement using the air cleaning device. The final results must be as low as practicable and definitely need to be within the Clean Air Regulation 2014 Threshold Limit Values. This emission quality will also work at the performance evaluation criterion for the air cleaning device.
Baseline LEV and GV system performance depicting the objective of the maiden performance meeting the design objective while setting acceptable limit criterion for the periodical assessment. (Never allow Industrial Hygiene Technician to set their own general criterion for evaluation purposes as they need to derive the criterion based on design specification. The designer must have added the justification for their selection of design specifics such as capture velocity or transport velocity.)
Baseline ambient air monitoring to determine the ground level concentration at periphery or any sensitive recipient of possible downwash from chimney emission due to poor dispersion efficiency.
Baseline Monitoring Data Essential for Effective Operation and Maintenance of any Industrial ventilation system
Once the baseline data is establish, the performance monitoring criterion can be set to be within the baseline and minimum limit which can be based on either 10% flow rate variance, or lower limit of capture velocity, transport velocity, efflux velocity, differential pressure upper limit and etc. Continual execution of performance monitoring data can be analysed and cross checked with these parameters above to take note of the system performance. The decision to trigger maintenance shall be derived based on the dwindling patterns logged in the performance monitoring.
The most important pointers to be taken note here is that, every single monitoring carried out must be based on the identified air borne hazards, the baseline data and its periodical performance. One must be able to read these periodical reports to trigger actions or log the performance. Completing a monitoring exercise just to solely adhere to the statutory regulation and to present a happy ending results should never be the practise.
FAQ on Performance Monitoring
At this point you may review back your current approach in managing every single industrial ventilation systems. If you are merely conducting monitoring to ensure you dont have NCR during audit or to ensure DOE and DOSH does not give you notices of improvements, then it’s about time you make the changes. Take the chemical registry and expand from there to finalise the source of every airborne contaminant related to your industrial ventilation systems. Then, work on the baseline data and verify the criterion set. Get someone to plot the data of every monitoring carried out all these while. Verify of your maintenance program is based on these data and its pattern. Engage a good monitoring company who approach monitoring on this manner to enhance your monitoring program with the objective to sustain high amount of airborne hazard control integrity. Stop picking companies which merely does monitoring with poor knowledge of industrial ventilation and how it affects the environments and workers exposure.