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Stack emission monitoring and Clean Air Regulations 2014 compliance

A stack test report tells you what came out of the stack on one day. It does not tell you whether your abatement system is working, whether the result is representative, or whether you will pass the next one. Those are different questions, and they are the ones worth asking.

Got a stack test report you are not sure about? Send it to us with your system details. We will read it against the Clean Air Regulations and tell you what it actually shows.

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What the regulations require

The Environmental Quality (Clean Air) Regulations 2014 set emission limits by source category and require written approval from DOE before fuel-burning equipment or air pollution control equipment is installed or altered. Approval is granted on a design, and the plant is then expected to demonstrate that it performs as designed.

Two obligations follow. You need approval before you install, and you need monitoring evidence afterwards. Sites that commission equipment and then arrange monitoring as an afterthought usually find the two do not line up.

Where we are most useful

Verifying that abatement actually works

Removal efficiency claimed by a supplier and removal efficiency measured on your stack are frequently different numbers. On a recent engagement involving an electrophoretic coating line fitted with a UV photocatalytic oxidation system, the third-party test measured across two inlets and one outlet and reported non-methane hydrocarbon removal in the high seventies as a percentage. That figure is only meaningful once you establish three things: whether the sampling captured representative operating conditions, whether the outlet concentration itself sits within the applicable limit regardless of the percentage removed, and whether an upstream fuel-burning source is contributing to what the outlet sees.

Percentage removal is a sales metric. Outlet concentration against the regulatory limit is the compliance metric. They are not interchangeable, and a system can achieve an impressive removal rate and still fail.

Reading a third-party test report properly

We review reports produced by testing laboratories — including reports produced overseas for imported equipment — against Malaysian limits. Common findings: parameters tested that are not the ones DOE will ask about, sampling conducted at a convenient rather than a representative production rate, units or reference oxygen conditions that do not convert cleanly to the Malaysian basis, and missing detail on isokinetic conditions for particulate sampling.

Specifying continuous monitoring

Where continuous emission monitoring is warranted, the specification matters more than the brand. Range, response time, interference from other stack constituents, calibration regime, data logging and how the output will actually be used for compliance reporting all need settling before purchase. We advise on specification independently of any supplier.

Written approval submissions

For new fuel-burning equipment or new abatement systems, we prepare the DOE submission — source characterisation, expected emissions, control system design basis, predicted performance against the applicable limits, and monitoring arrangements.

Parameters and sources we work with

ParameterTypical source
Particulate matterBoilers, furnaces, dryers, material handling, bag filter outlets
Oxides of nitrogen (NOx)Fuel-burning equipment, thermal oxidisers
Sulphur dioxideFuel-burning equipment, particularly on heavier fuels
Non-methane hydrocarbons and VOCCoating, painting, printing, solvent handling, e-coat and curing ovens
Acid gasesMetal finishing, chemical process scrubber outlets
Odour and nuisance complaintsFood processing, rendering, wastewater treatment, composting

Abatement systems we assess

Wet and dry scrubbers, bag filters and cartridge collectors, cyclones, thermal and catalytic oxidisers, activated carbon adsorption, UV photocatalytic oxidation, and biofilters. We assess whether the system chosen is appropriate for the stream, not only whether it is running.

Common questions

Do you carry out the stack testing yourselves?
We design and supervise the monitoring programme and interpret the results. Sampling and laboratory analysis are carried out by accredited testing providers, which keeps the interpretation independent of the measurement.
Our supplier says the system meets the standard. Is that not enough?
A supplier's performance claim is made under design conditions on a specific stream. Your stream is not that one. The claim is a starting point for verification, not a substitute for it.
We have a test report in a foreign language or foreign units. Can you use it?
Yes. We routinely work from reports produced outside Malaysia for imported equipment, and part of the work is converting the basis so it means something against Malaysian limits.
What if the result shows we are non-compliant?
Better that you know it than that DOE does. The report then becomes the basis for a corrective plan, and a site that has identified and is actively addressing a problem is in a materially different position from one that has not.
Do we need written approval for a system we already installed?
If it is fuel-burning or air pollution control equipment installed or altered without approval, yes, and it should be addressed. Tell us the situation and we will advise on the route.

Start with the report you already have

Or with the system you are about to buy, which is the cheaper moment.

Request a Report Review