01.1 Chemistry Quality Assurance – Data Validation
Third-Party Data Validation
Analytical results generated from environmental samples become the basis for assessments and remedial decisions. The degree to which data are valid can make the difference between a correct assessment and an unnecessary cleanup effort.
Data users have historically assumed that laboratory-reported results are absolute, accurate, and reliable because laboratories are professional firms certified by state and federal agencies. This assumption can be a costly mistake. It is prudent to have data validated by an independent third party. The validation of data by the firm that collected the samples, even when there is an experienced chemist with appropriate credentials on staff, may represent a conflict of interest. Consultants may be reluctant to qualify data due to sampling for which their firm is responsible.
Depth of Experience
For more than 30 years, Environmental Standards has brought extensive analytical expertise, including familiarity with organic, inorganic, radiological, and explosives analyses, to projects. Our professionals have experience with the US EPA’s functional guidelines for data validation and have provided data validation services for hundreds of Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), Resource Conservation Recovery Act (RCRA), Clean Air Act (CAA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), state-led, and due diligence environmental investigations. Environmental Standards’ work with private industry, engineering firms, laboratories, and other environmental contractors encompasses every US EPA Region.
Levels of Data Validation
Environmental Standards offers several levels of data validation – the level depends on individual client needs and the available laboratory data deliverables. The review levels range from data qualification based on tabulated quality control (QC) summaries to rigorous validation of raw analysis data. In addition to the manual data validation performed by one of Environmental Standards experienced Quality Assurance chemists, Environmental Standards offers an automated review of the quality control data provided in the laboratory's electronic data deliverable; this review approach is performed independently or in combination with the more rigorous manual assessment depending upon project needs.
Data Validation Procedures
The intensive data validation procedures developed by Environmental Standards are strictly followed by our chemists to assess the validity of an analysis relative to compliance with client, QAPP, method, and regulatory agency specifications. We determine if an analysis was performed correctly (e.g., holding time and QC criteria met, appropriate documentation of manual integrations, etc.), if the results are usable (for their intended purpose), and if the results could withstand rigorous litigation proceedings and agency scrutiny.
Our expertise has helped to change the outcome of an environmental investigation such that our clients saved significant time and money. Clients have seen benefits in the rebuttal of HRS scores (Superfund site listing), the selection of Remedial Investigation/Feasibility Study indicator chemicals, the assessment of liability or endangerment, compliance with state-specific due-diligence property transfers, and risk analysis of potential liabilities.
A valid justification for the usability of non-conforming data has benefited our clients by allowing projects to remain on schedule and within budget. An even more important benefit of validation is the reassurance that data presented to a regulatory agency or submitted in litigation proceedings are defensible because the data have undergone intense scrutiny by a critical third party.