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March 2020 – The Delicate DoD

The Delicate DoD/DOE Subcontracting Web Apparently Requires Gatekeeping

In December of 2019, the Chair of the U.S. Department of Defense (DoD) Environmental Data Quality Workgroup issued a memorandum to the Environmental Laboratory Approval Program (ELAP) Accreditation Bodies stipulating that the outsourcing of management system activities to any entity (or facility) beyond the entity that physically receives samples for analysis must be identified and meet the requirements for subcontracting, and those entities/facilities must have prior written approval and authorization from the DoD/U.S. Department of Energy (DOE).  From this new requirement, it appears likely that potentially unacceptable (for whatever reason) lower tier subcontractors were previously being used under the DoD/DOE’s radar for rather important technical functions like data acquisition/processing, data review (validation) and support.

This is an excerpt from the memorandum:

This memo is to provide clarification on DoD/DOE QSM Version 5.3, clauses 4.5.9 and 4.5.10 regarding the classification of outsourced management system activities. DoD/DOE consider activities in support of the management system as tasks such as sample processing, sample analysis, data acquisition, data review, data processing, project management, and IT support. If any of these activities are performed at facilities or locations other than the physical location where the original sample(s) are received, that is considered “subcontracting” by DoD/DOE. As such, all applicable activities shall meet the requirements for subcontracting and prior written approval and authorization from the DoD/DOE customer is required.
Note: a different facility or location is considered one that is not in a contiguous property parcel to the receiving facility.

Environmental Standards provides important third-party data validation and data management support for a variety of high-profile environmental programs. For more information contact Rock J. Vitale, CEAC.

Gary Yakub