The Standard, Environmental Standards, Inc.

Main Newsletter Page

The Standard
June 2009 - Page 4

Defense Department Environmental Laboratory Accreditation Program
The Assistant Deputy Under Secretary of Defense issued a memorandum establishing the Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) on December 24, 2008. The program is intended to promote consistency among the DoD components, facilitate the procurement of analytical services, shift the expense of laboratory assessments from the DoD to the private sector, and allow the DoD to focus its resources on providing project-specific quality assurance oversight. Effective October 1, 2009, laboratories that are seeking to perform testing in support of the DoD environmental restoration programs (Army, Navy, or Air Force) will be subject to DoD ELAP requirements.

The DoD ELAP will require laboratories to demonstrate conformance to the DoD Quality Systems Manual for Environmental Laboratories, which is based on the National Environmental Laboratory Accreditation Conference Quality Systems Standard – the standard that provides guidelines for implementing the international standard, ISO/IEC 17025, General Requirements for the Competence of Testing and Calibration Laboratories. DoD ELAP oversight will apply to laboratories providing data serving environmental programs/projects at DoD operations, activities, and installations, including government-owned, contractor-operated facilities and formerly used defense sites, where testing is being performed in support of environmental restoration programs. Accreditation will be open to all environmental laboratories that can demonstrate conformance to the DoD Quality Systems Manual.

The DoD Environmental Data Quality Workgroup, which will provide oversight of the DoD ELAP accreditation process, will authorize third-party organizations to assess laboratory conformance to the DoD Quality Systems Manual and to monitor implementation of corrective action responses. These assessment organizations must meet program requirements, such as submission of a documented management system conforming to the international standard, ISO/IEC 17011; acceptance of specific conditions and criteria for recognition; and completion of assessor training. Accredited laboratories will receive certificates that detail their scope of accreditation from the third-party assessors.

Clarification Of Requirements For 40 CFR Part 136 Methods
On May 7, 2009, Richard Reding, Chief of the US EPA Engineering and Analytical Support Branch of the Office of Science and Technology, issued a memorandum calling for higher and more uniform standards of quality assurance (QA) for methods performed under 40 CFR Part 136. This memorandum addressed concerns about differing amounts and types of QA and quality control (QC) procedures in the currently approved methods.

The key points of this memorandum are listed below.

When the QA/QC requirements for an approved method are presented in a separate part of the compendium of methods, such as Standard Methods and ASTM Methods, the QA/QC methods must be followed even when the QA/QC section may not be cited in the Federal Register.
The QA/QC followed when using Standard Methods and ASTM compendium methods must be in compliance with the most recent editions of these methods - even though older editions of the analytical methods may still be cited and approved.
If a laboratory auditor determines that an approved method may have insufficient QA/QC requirements, it is reasonable to require QA/QC equivalent to other approved US EPA methods and/or to the NELAC QA/QC requirements.
Twelve QC checks that are considered essential requirements for all 40 CFR Part 136 testing are identified; these QC checks must be incorporated into the laboratory's documented quality system unless a written rationale is provided that indicates why these controls are inappropriate for the specific analytical method(s).

This memorandum, which clarifies a number of ambiguities in approved methods, constitutes a strong endorsement of a high level of quality system standards and requirements across all 40 CFR Part 136 analytical programs.

Fungal Results Interpretation - Know The Full Story
The interpretation of fungal results is impacted by a number of factors and is typically not a straightforward process. Some professionals and laboratories provide a straight statistical review of the fungal results (comparing outdoor results to indoor results) to provide an indication of the presence of elevated levels of fungal spores. The statistical approach provides direction to areas of concern, but by no means provides the whole story for a fungal investigation. Fungal spore counts in air are impacted by a number of factors - a diurnal cycle, airflow patterns, seasonal variation, and physical disturbances. These variations can be orders of magnitude for samples collected minutes apart (e.g., 1000 spores to 100,000 spores). Unless a large number of samples covering different times of the day and a good portion of the property inside and outside are used, the statistical approach falls short. A statistically rigorous sample collection and analysis scheme is expensive and success is not guaranteed.

In order to get the complete picture, a professional must gather information to supplement sample results - information relative to the surrounding land use, surrounding rooms, connected buildings, property history (e.g., leaks, fires, and floods), HVAC system layout, and visual observation. Interviews with complaining occupants, non-complaining occupants, property managers, and maintenance personnel provide information that can be used to develop an effective sample collection scheme. Property owners should be aware that properties with fungus issues typically involve more than just replacing the drywall.

If you suspect your property has fungal or other indoor environmental issues, contact Quality Assurance Chemist Stephen T. Zeiner, CRMI, CEAC, at 610-935-5577 for assistance.

Summer 2009 Conferences
The Battelle In Situ and On-Site Bioremediation Symposium was held May 5-8, 2009, in Baltimore, Maryland. Principal Geoscientist Gerry Kirkpatrick, P.G., presented “In-Situ Bioremediation of Chlorinated Solvents in Fractured Triassic Bedrock of Southeastern Pennsylvania.”

The annual TCEQ Environmental Trade Fair and Conference was held in Austin, Texas, May 12-14, 2009. Technical Director of Chemistry/Principal Rock J. Vitale, CEAC, CPC, presented “Nonylphenols - A New Group of Compounds of Concern” and Quality Assurance Specialist/Principal Ruth L. Forman, CEAC, presented “The Art of Reading a Lab Report - Can You Pass the Test?”

The Florida Society of Environmental Analysts (FSEA) Spring Meeting and Technical Session was held in St. Petersburg Beach, Florida, May 20-22, 2009. Rock J. Vitale, CEAC, CPC, presented “The Do’s and Don’ts Regarding MDL Verification Studies.”

The 2009 Northeast Sustainable Communities Workshop was held June 18, 2009, in Newark, New Jersey. Gerry Kirkpatrick, P.G., was a panelist for the session “Sustainable Approaches to Assessment and Remediation at Brownfields Sites.”

The 15th Annual Good Laboratory Practice (GLP) Reception & Conference, sponsored by the VA AWWA / VWEA Laboratory Practice Committee, will be held August 3-4, 2009, in Charlottesville, Virginia. Senior Quality Assurance Chemist Pat Conlon will present “How to Prepare Your Laboratory for an Internal and ‘Official’ Audit and Document Control.” Mr. Conlon will also present “The NELAC Institute Efforts to Assist Laboratories” on behalf of The NELAC Institute.

The 2009 National Environmental Monitoring Conference (NEMC) will be held August 10-14, 2009, in San Antonio, Texas. Ruth L. Forman, CEAC, will present “The Impact of New US EPA Methods - A Case Study of Contortions and Permutations - US EPA Method 5035.” Pat Conlon will present two papers: “1,4-Dioxane Micro-Aqueous Extraction with GCMS SIM” and “Discussion of the Limitations of Citeable References for Commonly Accepted Performance Standards for Technical Measurements and for Ethical Practices.”

If you would like a copy of any of these presentations, please contact Marketing Coordinator Abby Wilson at awilson@envstd.com.

Previous 1 2 3 4
Return to main Newsletter page