What is OMA?
The Operator Monitoring Assessment (OMA) scheme was developed and is managed by the Environment Agency (EA) and allows them to assess the quality and reliability of operators’ self-monitoring. The OMA scheme covers assessments of the self monitoring of emissions to air and discharges to water.
Does OMA apply to me?
The OMA scheme applies to processes that are regulated under the Environmental Permitting Regulations. If you have an environmental permit from the EA that includes emissions to air and/ or discharges to water and includes monitoring requirements for that, you will fall under the OMA scheme. An OMA is carried out every four years as a minimum and the frequency be increased if the EA feel is it appropriate due to your sites environmental risk.
Are OMA audits necessary?
The EA carry out OMA audits for a number of reasons. The audits purpose is to assess operators’ self monitoring, including any monitoring carried out on their behalf e.g. by contractors. This is to ensure that your monitoring techniques are suitable and provide accurate data so both you and the EA can be confident you are not causing environmental damage through your emissions and discharges. The OMA audit is also used to indicate any necessary monitoring improvements that are needed to ensure accuracy and robustness in case something goes wrong. The scheme also helps the EA target independent auditing of point source emissions to make sure higher risk operations are prioritised.
What will happen in my OMA audit?
There are different auditing criteria for emissions to atmosphere and discharges to water and both audits are divided into four sections. Each of these sections contains a series of elements, which are scored against your operating arrangements. The four sections are:
- OMA 1 Management of monitoring
- OMA 2 Periodic monitoring and test laboratories
- OMA 3 Continuous monitoring
- OMA 4 Quality assurance
When the time comes for your audit, the EA will send a Compliance Officer. The officer will interview relevant site personnel, view relevant documentation and inspect the monitoring location(s). All relevant information reflecting the quality and reliability of your self-monitoring and any issues will be checked and recorded.
Following the audit, you will receive your report. Each element will be scored between 1 (poor) and 5 (excellent). If, upon reviewing your report, you have received a 1 or a 2, you will usually be required to make improvements. As a result, you will need to put appropriate action plans in place to improve your monitoring procedures.
How to I prepare for an OMA audit?
It is important that your OMA audit accurately reflects your current monitoring situation so you should never hide or falsify your operating procedures. However, planning and preparing for the audit will help you ensure it is carried out effectively and efficiently. Reading the OMA guidance document from the EA will make sure you have everything in place and know what to expect. This document is used by Compliance Officers to carry out your audit, so it will give you a really good idea of what is included and the areas of questioning that the audit will focus on.
You will need to prepare the documentation necessary for the audit to make sure you give the EA a clear picture of how you monitor your emissions or discharges. This documentation should be available, up to date and signed ready for your audit. The documents you will be asked for will include:
- Company organogram and details of staff responsibilities, specifically for monitoring
- Environmental permit, monitoring schedules and copies of monitoring returns
- Recent emission monitoring reports
- Management system reviews that deal with monitoring
- Details of any accreditation, certification and type approvals claimed
- Internal and external audits that relate to monitoring
In addition to these documents, other information may be required as part of the audit. This may include:
- Monitoring procedures
- Performance and validation data
- Training records
- Calibration and maintenance procedures, records and schedules
- Monitoring equipment instruction manuals and performance data
For the audit, you will also have to make sure that audit trails are available. This means you can demonstrate who carried out the monitoring, when it was done and what equipment and/ or methodology was used. Don’t forget to consider who does monitoring when the regular person is on leave or off sick! When you know when your audit is going to take place, you should make sure that all of the necessary people are available. Who needs to be present will depend on your process but it will include those who are responsible for monitoring, those familiar with the emissions points and the equipment that you use. Supplementary evidence that demonstrates good practice or intended improvements should also be made available to the auditor to show where you go above and beyond the requirements and to demonstrate continual improvement.
Finally, carrying out a pre-OMA audit either by yourselves or by an external consultant will help you to identify what an audit will be like and identify any gaps you will need to address before the official EA audit. This should adopt the same methodology and use the guidance document that the EA would to give an accurate picture of the site monitoring conditions.
If you have an Environmental Permit with monitoring requirements, you will be subject to an OMA audit every four years with the EA. Understanding what your requirements are exactly and what to expect in an audit will help you to prepare for a stress free and successful audit with the EA. Taking a proactive approach by completing a pre-OMA audit will certainly help you prepare and make continual improvements to your monitoring processes.