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March 2020 – California – State Water Resources

Environmental Standards’ Comments Influence California’s Proposed ELAP Regulations

The California State Water Resources Control Board (SWRCB) proposed new regulations for an Environmental Laboratory Accreditation Program (ELAP), and recently solicited comments. The deadline for comments on the proposed regulations were set at 45 days. The proposed regulations were to adopt the 2016 The NELAC Institute (TNI)/NELAC accreditation rules. The following was stated:

The broad objective of the proposed regulations is to modernize the accreditation program within the authority granted by the Environmental Laboratory Accreditation Act. The proposed regulations include:

  • Updates to the administrative process for operating an accreditation program.
  • Modification or elimination of outdated requirements.
  • Replacement of existing accreditation standards with the nationally recognized, consensus-based 2016 TNI Standard – Revision 2.1, Volume 1, Management and Technical Requirements for Laboratories Performing Environmental Analysis (2016 TNI Standard), with two exceptions.

Environmental Standards provided comments recommending that ELAP require all laboratories seeking accreditation for per- and polyfluoroalkyl substances (PFAS) analytical services to meet the proficiency testing (PT) requirements as outlined in 2016 TNI Standard (EL‑V1M1‑2016‑Rev. 2.1: Proficiency Testing). The reason for this comment was that the board had grandfathered testing for PFAS without meeting the requirement for PT samples as outlined in the 2016 TNI Standard.

After review of all comments received, the board proposed additional changes to the rules based on Environmental Standards’ posted docket comments. Environmental Standards recommended that ELAP require laboratories seeking PFAS accreditation to provide PT sample results in accordance with the 2016 TNI accreditation requirements. Based on the changes to the previously proposed regulations, all laboratories providing PFAS analytical services will be required to submit PT sample results for accreditation by the California SWRCB.

The proposed ELAP regulations will be considered by the California SWRCB for adoption at the Board’s March 17, 2020 meeting.


Gary Yakub


David Thal

David Thal, CQA, CEAC, CFS

Principal Chemist