Just How Lucky Do You Feel?
With the public spun up with PFAS hysteria, regulators are being pressured to direct/order industrial parties to just “go sample” for PFAS. As articulated in the “PFAS – Putting the Cart Before the Horse” article in the October edition of The Standard, laboratories are quickly being accredited without having undergone PFAS-specific audits or PFAS performance evaluation (PE) studies. Additionally, laboratory reference materials are scarce (e.g., branched vs. linear isomers), and state agencies have been regularly expanding the list of PFAS compounds being mandated and requiring lower detection limits, even though many compounds seem to be on these lists without the support of grounded toxicological science.
Of significant concern, is that US EPA 537 is exclusively a drinking water method, and there are no approved US EPA methods for PFAS in non-drinking water aqueous samples, or for solids/sediments/sludges or tissue samples. However, commercial laboratories have been taking it upon themselves to develop their own extraction and analytical methods, simply referring to these methods as “Method 537 Modified.” What are those modifications that, in many cases, bear no resemblance to Method 537, and what are the chances of getting even reasonable data comparability between laboratories? If you are not asking those questions, then you need to ask yourself a question. Just how lucky do you feel?
There is a better way. Request copies of your candidate laboratory SOPs and review their PFAS extraction and analytical procedures for technical soundness. Submit blind PE samples (purchased from reputable vendors) to your candidate laboratories to assess data accuracy against true values. Finally, and arguably the most important pre-project assessment activity, is to perform a rigorous on-site audit of your candidate PFAS laboratories. Critical data validation is also important when assessing the quality of your PFAS laboratory, but to be sure, you cannot change anything or drive the quality process at that back end of projects.
Each year, Environmental Standards is retained to audit (internal) industrial laboratories and commercial environmental laboratories – generally performing about 100 engagements per year. Many of these audits are multi-sponsor directed, meaning the labor and expenses associated with the audit are shared amongst the confidential sponsors. Over the last few months, Environmental Standards has been requested to perform on-site audits of PFAS laboratories, nationwide.
Contact Rock Vitale if you or your colleagues are interested in receiving a copy of Environmental Standards’ 2020 laboratory audit list.
