ENVIRONMENT IN FOCUS
On the plus side, the majority of industry
service providers have responded very
positively: substandard samplers have
been replaced; samplers have been
relocated to positions that comply with
the standard (unless they are used for
internal reporting purposes); reports
have been upgraded and include copies
of equipment calibration certificates.
Operational management is being
informed timeously of approaches to
deposition limits or to excedences.
So where does your operation stand
with regard to dustfall monitoring and
reporting?
Are you confident in your service
provider? Have you scoped them
correctly? Do you receive feedback
timeously? Do you understand your
reports received?
bucket height above ground, bucket-
stand design, or bucket location. Any
one of these criteria singularly or any
combination of these may not meet the
prescribed requirements. If the sample
is not collected in accordance with the
standard, then it cannot be accepted as
accurate or correct and thus satisfies
the disqualifying conditions, namely,
‘inaccurate, incorrect, misleading or false’.
Reports submitted to operations and
authorities have been observed to show
evidence of ‘cut and paste’; incorrect
calculation of sample masses; non-
compatibility with the standard quoted
in the report against that used in the
field; and lack of calibration certificates
and signatures of responsible persons at
the service provider compiling or signing
off the report. Some service providers
are collecting samples in excess of the
prescribed 30 days ± 2 days, with cases of
42 days to ±90 days being noted.
Operations are receiving reports up to
four months after the sample collection,
thereby making it impossible for the
operation to take timeous steps to
prevent the possibility of not exceeding
the prescribed deposition limit in any
two consecutive months of a year.
A comprehensive short course on dustfall
monitoring and reporting will be offered
across the country from March 2019
through Aspasa. The course will cover:
• legal requirements;
• checklists to enable operational
personnel to conduct service provider
audits of installed equipment and
reports;
• a guideline on how to scope your
service provider correctly with
respect to dustfall monitoring and
reporting; and
• a practical component of the training
will be an audit of a correctly
installed monitoring station against
an incorrectly installed monitoring
station.
Contact Aspasa for course details.
Naturally, our in situ and post-audit
discussions of our observations of
installations and reports with operational
management have received a mixed
reception from service providers,
including unpleasant correspondence
received by me personally from a
dissatisfied service provider. This was
addressed by simply sending extracts of
the existing legal requirements to the
particular service provider and inviting
discussion of photographs of the service
provider’s equipment in the field. No
further related correspondence has been
received from that quarter.
www.quarryonline.co.za
Reaction from service
providers to the industry
Alan Cluett, founder of Cluett Consulting.
QUARRY SA | MARCH/APRIL 2019_35