Complaints and your Odour Management Plan
If you’re an operator producing odour emissions, you’ve probably experienced odour complaints somewhere along the line. But is this always a burden? We’ve put together all you need to know about why you get (and don’t get) odour complaints. Plus how you can use them to your advantage, and ultimately improve your odour management plan.
The Odd Odour Complaint isn’t a Big Deal. Right?
Chances are, you only get a few odour complaints here and there. Which doesn’t seem so bad really. But the scope of complaints can be vastly under-estimated. A single complaint, for example, can indicate that there are another 25 people who have experienced the same issue but don’t complain. And despite not complaining through official channels, those people are likely to relay their experience to at least another 10 people. That means that for every complaint received, there could be more than 250 negative contact points. So a slightly bigger deal than it first appears then.
This is especially true in recent times, thanks to social media platforms such as facebook and twitter. It’s now much easier and faster than it has been in previous decades to disseminate information to a far greater audience.
Why Doesn’t Everyone Complain?
It’s very easy to see why you could think that if there are no (or very few) complaints, there’s no problem. But is that accurate? In our experience, there are many and varied reasons why somebody may choose not to complain. Perhaps most notable is that they may have a vested interest in the operator responsible for an odour. In small communities in particular, for example, the region’s main employer may be responsible. Understandable, then, to choose not to complain and risk your own livelihood. Similarly, those working and living near odorous facilities can very easily develop a long-term tolerance to an odour. Which basically means they don’t smell it after a while.
Think about when you go on holiday. The plane has a very particular smell to it when you board. But after a while, you get used to it and don’t smell it any more. Thank goodness. People also get fed up with repeatedly complaining, especially if they don’t think it’s going to make a difference. It’s called ‘complaint fatigue’. Or it could be that while an odour is annoying, it’s not that annoying. And you know it won’t last long, so why waste time and energy on it?
Suddenly that 250 negative contact points per complaint doesn’t seem too far-fetched.
How Can I Tell if an Odour Complaint is the Real Deal?
Odour complaints are incredibly subjective, so of course there are factors to consider. While a single report may be well meaning and accurate, a complainant could be mistaken about the date, time or source of an odour. A complaint could also be malicious or part of an ongoing personal campaign, if the complainant has an ongoing issue with the operator.
To validate the extent of an odour issue, complainants may be asked to maintain odour logs. The Environment Agency has developed an Odour Complaint Report Form (which you can find in their H4 Odour Guidance Document). It’s designed to capture a range of factors which help qualify the accuracy of odour complaints. This helps to identify incident patterns, process behaviour and daily patterns, allowing an Environment Agency Officer to build a picture of what’s actually going on at a site. They should also conduct site visits, or field monitoring.
Of course this requires a good awareness of the way odour disperses, as a single ‘sniff’ may give a vastly skewed picture of an odour emission. Often, analytical techniques and modelling such as dispersion modelling are more effective to get a full picture. You may also find it worthwhile to conduct your own odour measurement and impact analysis activities. This could include a field odour impact survey or an odour emission assessment. The data output of these kinds of analysis can be critical. Firstly, for improving your odour management plan. And secondly in court cases, to demonstrate an effective response to odour complaints.
How are Complaints Valuable for my Odour Management Plan?
There’s no immediate need to panic if you receive a few odour complaints. They do not substantiate a permit breach. Importantly though, they do provide evidence of patterns of odour emissions. This can support an investigation by the regulator to achieve substantiation of a permit breach. And it can also corroborate evidence of known failures. Plus, odour complaints demonstrate the extent of impact on the local community, when an operator fails to control its process. Patterns of failure and response can be very influential in court cases involving odour complaints.
Sounds a bit stressful, but in reality odour complaints can be very powerful for operators. How? They give you an opportunity to demonstrate your commitment to responding to (and addressing) odour management problems. The best way to do this is with a robust and effective odour management plan.
Help! My Odour Management Plan Stinks!
First of all, don’t worry. It’s not unusual for an odour management plan to need a bit of tweaking (or creating!). There are lots of handy resources available to help you. To get you started, here’s what’s available from the Environment Agency and the IAQM. And at Silsoe Odours, we’ve got heaps of experience in the odour industry. So feel free to give us a call on 01525 351396. Our odour experts will be happy to talk to you about odour complaints and your odour management plan.
Here’s a Handy Set of References…
Institute of Air Quality Management (IAQM)
Guidance on the assessment of odour for planning
Odour Study Day
Want to know more about odour complaints, and the implications for your odour management plan?
Join us at the Odour Study Day training course.
The next one’s pencilled in for Autumn 2018. Drop us a line and we’ll keep you posted, as places fill up fast.
Ref: Phil Longhurst, Cranfield University