Good management requires every Visible Emissions Training and Certification activity to be periodically reviewed and evaluated in order to assess effectiveness. Since the certification process is the foundation of the opacity observation, audits should be conducted to assure that any observer generating opacity data be duly certified.
Smoke generators are complex machines subject to specific design and operating parameters necessary for valid certifications.
ETA has developed a detailed evaluation form as an aid to conducting the evaluation of a visible emissions training program in a systematic manner. This form has been used to evaluation numerous VE training programs for ETA and state agencies for managerial purposes. It has also been used in litigation.
The audit covers every aspect of ETA’s training programs:
- Staff qualifications.
- Lecture content.
- Field procedures.
- Record keeping.
- Quality assurance.
There are mandatory requirements for many aspects of the training and certification program stipulated by the U.S. EPA in Method 9. These items are considered the minimal program content and criteria necessary for a training program. Visual Determination of the Opacity of Emissions from Stationary Sources (Method 9) was published in the Federal Register (40 CFR 60), Volume 39, No. 219 on November 12, 1974. Additional items, while not regulatory requirements, make up the necessary elements of an effective VE training program. They can be found in EPA-600/4-77-027b, Quality Assurance Handbook for Air Pollution Measurement Systems: Volume III. Stationary Source Specific Methods, Addition Section 3.12 and guideline documents EPA 340/1-75-007 and EPA-650/4-74005-1.