Process Guidance Note 6/34(11) - Defra

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5.20 Regulators should use their discretion, in consultation with individual operators, in agreeing the appropriate level of environmental management. Simple systems which ensure that LAPPC considerations are taken account of in the day-to-day running of a process may well suffice, especially for small and medium-sized enterprises. Regulators are urged to encourage operators to have an EMS for all their activities, but it is outside the legal scope of an LAPPC permit to require an EMS for purposes other than LAPPC compliance. For further information/advice refer to the appropriate chapter of the appropriate Guidance Manual for England and Wales, Scotland and Northern Ireland. Training 5.21 Staff at all levels need the necessary training and instruction in their duties relating to control of the process and emissions to air. In order to minimise risk of emissions, particular emphasis should be given to control procedures during start-up, shut down and abnormal conditions. Training may often sensibly be addressed in the EMS referred to above. ‣ All staff whose functions could impact on air emissions from the activity should receive appropriate training on those functions. This should include: awareness of their responsibilities under the permit; steps that are necessary to minimise emissions during start-up and shutdown; actions to take when there are abnormal conditions, or accidents or spillages that could, if not controlled, result in emissions. ‣ The operator should maintain a statement of training requirements for each post with the above mentioned functions and keep a record of the training received by each person. These documents should be made available to the regulator on request. Maintenance 5.22 Effective preventative maintenance plays a key part in achieving compliance with emission limits and other provisions. All aspects of the process including all plant, buildings and the equipment concerned with the control of emissions to air should be properly maintained. In particular: ‣ The operator should have the following available for inspection by the regulator: a written maintenance programme for all pollution control equipment; and a record of maintenance that has been undertaken. PG6/34(11) 26
6. Summary of changes The main changes to this note, with the reasons for the change, are summarised in Table 6.1. Minor changes that will not impact on the permit conditions e.g. slight alterations to the Process Description have not been recorded. Table 6.1 - Summary of changes Section/paragraph/row Change Reason Comment Introduction Simplification of text Addition of links Make Note clearer Change to electronic format Removes need for extensive footnotes/references PG6/34(11) 27
Page 1 and 2: www.gov.uk/defra Process Guidance N
Page 3 and 4: Defra would like to acknowledge the
Page 5 and 6: Contents Revision of the guidance .
Page 7 and 8: 1. Introduction Legal basis 1.1 Thi
Page 9 and 10: Updating the guidance 1.9 The guida
Page 11 and 12: Temporary location of a SMART repai
Page 13 and 14: Permit reviews 2.7 Under LAPPC, the
Page 15 and 16: Application Methods 3.5 Most coatin
Page 17 and 18: Seam sealing 3.17 Weld seams and jo
Page 19 and 20: Figure 3.1 - Potential VOC releases
Page 21 and 22: VOC compliant coatings 4.4 Complian
Page 23 and 24: Visible emissions 4.8 The aim shoul
Page 25 and 26: 5. Control techniques Summary of be
Page 27 and 28: 5.9 Where no such guarantee is obta
Page 29 and 30: General control techniques Dust and
Page 31: An exception to the previous paragr
Page 35 and 36: these limits may differ since they
Page 37 and 38: 8.4 The volatile content of the coa
Page 39 and 40: Appendix 1: Application form Applic
Page 41 and 42: A5 Any holding company? Is the oper
Page 43 and 44: B6 Provide detailed procedures and
Page 45 and 46: B22 Additional Information Please s
Page 47 and 48: C4 C5 Data Protection Declaration T
Page 49 and 50: Conditions Non-VOC emissions Table
Page 51 and 52: 13. Spray applied coatings shall be
Page 53 and 54: The following two conditions are no

Process Guidance Note 6/34(11) - Defra

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