THE STANDARD – September 2017
Organic Extraction Methods – Seriously, Who Cares Anyway?
For routine analytical requests for semivolatile organics in solids, most investigators specify the analytical method, but rarely specify the preparatory extraction method. Untrained data users might consider that omission trivial, assuming that: a.) the laboratories know what they are doing/they are accredited, b.) those methods are not terribly important, or c.) all the US EPA extraction methods are of similar efficiency. In fact, there are very large differences with regard to solid sample extraction efficiency between the US EPA-approved methods, particularly when solid samples contain more than 5% moisture. In addition to the extraction method, the election of a single solvent versus a polar/non-polar solvent mixture can also have extraordinary impacts on the efficient extraction of semivolatile organics in field-moist solid samples.
Just Compare Two Methods
Consider SW-846 Method 3550 – basically, 30 g of a field-moist solid sample is mixed with anhydrous sodium sulfate to form a free-flowing powder. The mixture is extracted with solvent three times, for 3 minutes each, using ultrasonic extraction. The extract is separated from the sample by filtration and is ready for final concentration, cleanup, and/or analysis. Section 1.4 of the method states that, “Because of the limited contact time between the solvent and the sample, ultrasonic extraction may not be as rigorous as other extraction methods for soils/solids.”
By comparison, for Method 3540, 10 g of a field-moist solid sample is mixed with anhydrous sodium sulfate, placed in an extraction thimble and solvent extracted in a Soxhlet extractor, for 16 – 24 hours. The extract is then dried, and ready for final concentration, cleanup, and analysis. Section 1.1 of the method states, “The Soxhlet extraction process ensures intimate contact of the sample matrix with the extraction solvent.”
With regard to these two US EPA-approved extraction technologies, given the wide range of possible matrices of environmental samples,
Method 3550 may often yield lower concentrations of target analytes than Method 3540, simply based on the difference in contact time between the sample matrix and the extraction solvent.
Another important aspect of ensuring efficient extraction of semivolatile organics in field-moist solids is the selection of an appropriate solvent mixture. In many cases, commercial laboratories left to their own devices opt for single-solvent extractions, regardless of whether they are using Method 3550 or Method 3540.
I Have to Select the Solvents Too?
Field-moist solid samples need to be extracted using a solvent system that gives optimum, reproducible recovery of the analytes of interest. The choice of extraction solvent depends on the analytes of interest, and no single solvent is universally applicable to all analyte groups. Method 3550 using a single solvent is fast and cheap, and
Method 3540 includes the option of using a single solvent. However, single-solvent extraction can often be less efficient at recovering semivolatile organics from wet solid samples (e.g., sediments) than a mixed-solvent extraction. This is particularly likely when both polar and non-polar analytes are of interest.
Often, for the routine semivolatile methods, commercial laboratories use a single-solvent extraction; again fast and cheap. However, for field-moist solid samples, optimal extractions use a combination of a water-miscible solvent, such as acetone, and a water-immiscible solvent, such as methylene chloride or hexane. The purpose of including acetone is to facilitate the extraction of wet solids by allowing the mixed solvent to penetrate the layer of water on the surface of the solid particles. The water-immiscible solvent extracts organic compounds with similar polarities. Thus, a nonpolar water-immiscible solvent such as hexane is often used for non-polar analytes, while a polar water-immiscible solvent like methylene chloride may be used for polar analytes.
For projects involving soils/solids of varying degrees of moisture, the selection of the semivolatile extraction methods and the selection of solvent mixtures can have a dramatic effect on the recovery of polar and non-polar target analytes. When data are being used for important risk, remedial, or engineering decisions, and/or contention of solid sample splits and/or historical data sets are being compared, it is critically important to consider the effects of the extraction method(s) and the solvent(s) used.
For more information, contact Rock J. Vitale, CEAC, Technical Director of Chemistry (firstname.lastname@example.org, 610.935.5577).
ASTM Update to Phase 1 Standard for Assessing Forestland or Rural Property
On June 20, 2017, the United States Environmental Protection Agency (US EPA) took direct final action to amend the Standards and Practices for All Appropriate Inquiries. The final rule amends the All Appropriate Inquiries Rule to reference ASTM International’s (ASTM’s) E2247-16 “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property” and allows for its use to satisfy the statutory requirements for conducting all appropriate inquiries under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The revised standard was published by ASTM on January 3, 2017, and replaces a version released in 2008 (E2247-08).
The revised standard is designed for use on large tracts of rural and forestland property and allows for less rigorous site reconnaissance versus the site visit requirements of the Phase I standard for assessing smaller commercial and industrial properties (ASTM E1527-13). The updated rural and forestland property standard includes updated language to mirror what is included in E1527-13. The new forestland and rural property standard contains some other changes, which include: elimination of the 120 acres or more size requirement and simply requires the property to be forestland or rural property; the definition of rural property is broader, allows for alternate sourcing for agency records, and some of the site visit criteria are relaxed. The revised rule also specifies a specific time limit of 20 calendar days for receipt of materials requested by the consultant. The 20-day limit ensures that the Phase 1 environmental site assessment will take at least 20 days to complete. A summary of how E2247-16 differs from E2247-08 is published by US EPA as part of the docket.
Brewers Join Forces for Clean Water
“You can’t make great beer without clean water.” This statement on the Brewers for Clean Water page on the National Resources Defense Council (NRDC) website sums up why so many brewers have banded together to oppose US EPA’s proposal to repeal the Clean Water Rule.
On Tuesday, June 27, 2017, a group of 48 craft breweries associated with the Brewers for Clean Water Campaign sent a letter to US EPA in defense of the Clean Water Rule. NRDC explains that in May 2015, US EPA and the Army Corps of Engineers issued the Clean Water Rule, which clarified that tens of millions of acres of smaller waterways across the United States were, in fact, eligible for protection under the Clean Water Act. Less than two years later, in February 2017, President Trump signed an executive order directing US EPA and the Army Corps of Engineers to begin the process of repealing the Clean Water Rule, with the aim of eliminating it altogether.
The plan to repeal the Rule concerns brewers for several reasons. The Brewers for Clean Water webpage states, “Of course, clean water is essential to more than a great-tasting pint—it’s also critical for our health and our economy at large. That’s why dozens of breweries have joined NRDC’s fight to protect the Clean Water Act. Responsible safeguards protect our product from upstream pollution and help us protect our downstream neighbors.”
In the letter, the brewers stated, “Brewers have been proud to support the Clean Water Rule since it was first proposed. Because the rule helped protect the sources of drinking water for 117 million Americans from pollution and destruction, it provided certainty that we would continue to have access to the clean water on which our livelihoods depend. Importantly, the rule was based on sound science. The record supporting the rule showed unequivocally that the waters it protected had biological, chemical, and physical connections to larger downstream waterways.”
For more information on the Brewers for Clean Water Campaign visit their website.
Cannabis Product Quality – The Dire Need for Process Control and Product Uniformity
The cannabis industry, once known as “the wild west” is finally coming out of infancy and out of the darkness of the black market. The lack of federal regulation and oversight of the cannabis market, coupled with individual states struggling to provide regulations under differing legalization constructs and timelines, has led to variation across state testing and monitoring programs and requirements. This has resulted in several product recalls and serious threats to human health and safety due to contaminated products being distributed to consumers. In addition to new and evolving state regulations that are meant to protect public health, patients and consumers are demanding that products be consistent in efficacy and appearance from batch to batch. Due to the lack of standardized testing methods, and the lack of data resulting from its Schedule I status, state regulatory agencies have struggled to place action limits on everything from maximum THC (Tetrahydrocannabinol) required in an infused product to the amount of pesticides or solvents an extract can contain.
A 2017 investigation in California discovered that toxic pesticides (chemicals that scientists say could cause serious health problems) could be present in batches of marijuana legally sold in the state. In 44 marijuana products that were tested as part of this investigation, 93% (41 of 44) tested positive for pesticides at levels that would have banned those products for sale in some other states that currently regulate pesticides in marijuana (Grover and Glasser, 2017). One of the more commonly used pesticides in cannabis cultivation, myclobutanil, can turn to hydrogen cyanide when heated. Clearly hydrogen cyanide is quite toxic, as it has been used as a primary euthanizing agent in gas chambers! Obviously the lack of quality control and process testing throughout the industry is a serious matter, and as the cannabis industry continues its meteoric rise, the need for cultivating and manufacturing cannabis products (e.g., flower, extracts, etc.) of known quality is paramount.
The good news is that the cannabis industry is beginning to recognize that the standards and controls on these products do not need to be created from scratch. Proven national and international testing standards have been used in the pharmaceutical and food industries for years under current Good Manufacturing Practices (cGMP), Food and Drug Administration (FDA), United States Pharmacopeia (USP), European Pharmacopeia (EP), International Conference on Harmonization (ICH) and International Organization for Standardization (ISO) platforms. Many states are requiring laboratory accreditation to ISO 17025, the standard for calibration and testing laboratories. Some states, such as Oregon, have adopted an accreditation approach that encompasses The NELAC Institute (TNI) Standard, an environmental industry version of ISO 17025. The state of California has proposed standards “substantively similar to cGMP” as noted in their rules summary and FDA has confirmed in industry presentations that these standards will be enforced when they have federal oversight.
A voluntary standard such as ISO 9001:2015 ensures that an organization can operate consistently to known procedures and keep records for traceability related to product optimization; whereas a cGMP-compliant system will establish product specifications and strive to meet those specifications by collecting and monitoring scientific data throughout the manufacturing process. Normally required in pharmaceutical and food manufacturing, these systems will address the issues that currently plague the cannabis industry such as the lack of product uniformity, unidentified contamination, contaminant carryover in equipment, and consistency of active ingredients.
As cannabis moves forward into regulated markets, these practices should be implemented for all organizations producing and/or distributing product to consumers, in order to ensure proper implantation and establishment of cGMP practices. Safety and product testing should not be a setback for the industry; rather, these practices should be the benchmark and be used to promote optimal and consistent safety throughout the industry. Vitale Scientific Associates, LLC. (VSA) has years of experience designing quality systems and process control strategies utilizing ISO 9001:2015, cGMP, and quality principles such as Quality by Design (QBD). With proper implementation of these systems, the standardization of parallel industry products and an overall reduction to public health risk can be achieved.
Pennsylvania Issues Medical Marijuana Licenses
In June of this year the Pennsylvania Department of Health issued 12 grower/processor permits and an additional 27 permits to entities that will serve as dispensaries, within the medical marijuana industry in the commonwealth. To capture the perspective of the market in Pennsylvania, 457 applications were received, of which 177 were prospective growers/processers and 280 applied as dispensaries. The permit awardees have 6 months to become operational. With VSA’s headquarters of in Valley Forge, Pennsylvania, VSA is geographically aligned and technically equipped to provide assistance to those permit awardees.
How to Avoid Getting Hacked
May 2017’s WannaCry and June’s Petya global ransomware cyberattacks crippled hundreds of thousands of computers in over 150 countries. Ransomware is malicious computer code that encrypts documents on infected computers and then demands a monetary ransom to decrypt the files using a digital key. Early evidence shows that these attacks spread rapidly through corporate Information Technology (IT) networks. For example, both attacks exploit vulnerabilities in Microsoft® Windows®; however, the Petya malware uses a cascade of options, first trying one and if it doesn’t work, trying the next, and so on, showing increased sophistication over WannaCry.
The best defense against these kinds of attacks is to remain actively vigilant. Here is a collection of tips from cybersecurity experts on how to protect your electronic assets in the modern information age.
1. Do not open an attachment or click on a link from a sender you do not know or are not expecting. These are classic phishing attempts and will almost always these lead to electronic infection.
2. Apply all current updates and patches for your electronic devices – do not wait until later. Most cyberattacks exploit weaknesses patched months or even years earlier.
3. Ask your IT Administrator about how e-mail, including attachments or outside links, is scanned for malicious content before it reaches your inbox. If there is no policy, suggest that one be set up.
4. Protect your passwords; think of them as toothbrushes – for personal use only and changed every couple of months.
5. Always ask yourself why a website, company, or person needs to know restricted company-based facts or something personal about you, before sharing that information. Knowing how (or IF) the entity protects that information may also influence your decision.
6. Do not use the “remember” feature for passwords on your favorite websites. Although convenient, one quick hack can compromise your computer.
7. Use reliable anti-virus software on your computer, keep it updated, and let it auto-scan at regular intervals. Check with your IT Administrator to ensure that all company electronic devices, servers, virtual machines, etc. also use anti-virus software.
8. When you travel, use a trustworthy Virtual Private Network (VPN) to access a public wireless internet. Check with your IT department to make sure your electronic device is prepared.
9. Do not run applications without first examining them through virus and malware detection software. Even authentic app stores can unknowingly download malware to your electronic device.
10. Do not connect external drives, especially thumb drives,from unknown sources, to your computer.
11. Some ransomware attacks require macros, so disable macros in Microsoft Office® applications to help prevent attacks. If it’s legitimate code, you can always turn the macro feature back on.
12. Make sure a robust firewall monitors your internet connection and ensure that it uses automatic subscriptions to update virus and malware definitions.
13. Restrict your online purchasing to one credit card that has a transaction limit. If the card is compromised, your financial risk is minimized for that one credit source.
14. Even if your IT department has a rigorous and thoroughly tested backup policy, backing up your most important files every day to a drive separate from your computer’s drives on your own is a good idea. If a malware infection occurs, data can be restored from those backups without relying on hackers. And having your own backup ensures that the most current files are restored.
As a user, you are an important part of keeping malware threats off your network. While your IT department might keep your operating system and security software updated, you need to ensure that the software you use for your work is authentic and up-to-date. Become knowledgeable about the anti-virus application on your machine and use it regularly – do not turn it off to “save time.” Do not open e-mail attachments or click on e-mailed links from senders you don’t know – call and verify. Most importantly, back up important data frequently and store the copies offline. To summarize, protecting against a cyberattack requires the implementation of basic IT compliance practices.
To learn more about implementing cybersecurity into your workflow or about Environmental Standards, Inc.’s cybersecurity auditing, please contact Dr. Michael Green.
VA DEQ Releases Draft PCB Total Maximum Daily Load Development Plan for New River and Tributaries
Section 303(d) of the Clean Water Act (CWA) and the United States Environmental Protection Agency’s Water Quality Planning and Management Regulations require states to develop total maximum daily loads (TMDLs) for waterbodies that exceed water quality standards (WQSs). TMDLs represent the total pollutant loading that a waterbody can receive without violating WQSs.
Sections of the New River watershed are impaired due to polychlorinated biphenyl (PCB) contamination. The goal of this project was to identify the sources of PCBs in the watershed, model the fate and transport of PCBs through the watershed, and propose PCB source reduction scenarios that would allow the watershed to return to an unimpaired state. These reduction scenarios establish the TMDL loads( i.e., the maximum quantity of PCBs that can enter the watershed without exceeding the PCB endpoints).
The PCB-impaired segment of the New River in Virginia begins where US Interstate 77 crosses the river, downstream to where it crosses the Virginia/West Virginia state line. The basin that drains into the studied section of the New River spans 2,352 mi2.
Virginia Department of Environmental Quality (VADEQ) originally provided PCB data from 36 permitted facility dischargers in the study area to use in establishing loads and waste load allocations: 10 municipalities, 20 industrial stormwater general permitted facilities (ISWGPs), and six individual industrial permitted facilities (IPs). As shown in the graph, in the case of the Lower New River work, data indicated that more than half of the PCB load was from permitted facilities.
Uncharacterized sources represented PCB loads from sources whose existence is supported by the elevated PCB concentrations in observed data, but whose specific locations have yet to be identified. VADEQ has established an ongoing effort to identify these unaccounted sources, and TMDL implementation will entail finding these sources, categorizing them as contaminated sites or point sources, and addressing their contribution to PCB impairment.
Virtually all of the New River PCB TMDL information is available for download at the following URL: https://www.deq.virginia.gov/Programs/Water/WaterQualityInformationTMDLs/TMDL/PCBTMDLs/NewRiverTMDLPCB.aspx. If you need assistance with your PCB Pollutant Minimization Plan, Environmental Standards can help with our extension experience in designing and implementing PMPs.
Cities and Corporations Step up to Support Sustainability
With the recent announcement that the United States would be withdrawing from the Paris Agreement (formal withdrawal will not occur until November 2020), many companies and cities have announced plans to put forth aggressive policies to cut greenhouse gas emissions, use 100% renewable energy, and ensure a sustainable future.
Environmental Standards, Inc.’s headquarters is located 30 miles outside of Philadelphia, Pennsylvania. Philadelphia’s Mayor, Jim Kenney, announced that the city is committed to transitioning to 100% clean energy by the year 2035. Philadelphia is 1 of 100 U.S. cities to make the 100% clean energy commitment. A total of 350 mayors from across the U.S. have joined together to sign the Climate Mayors agreement. This agreement has support from the top-10 largest cities in the U.S. Although the “Climate Mayors” cannot formally sign on to the Paris Agreement, the mayors for the 350 cities, joined with mayors from across the international community, to commit to limit the rise in global temperatures to 2.0 degrees Celsius.
Many companies, especially companies that compete in the global market, have made similar sustainability commitments. The car company Volvo has made a commitment that all new model cars released after 2019 will be electric or hybrid. Back in Philadelphia, SEPTA plans to install solar panels in some of its stations and Lincoln Financial Field, home of the Philadelphia Eagles, has 11,000 solar panels and
14 micro wind-turbines. Several other sports stadiums are powered by renewable energy, including NASCAR’s Pocono Raceway and Levi’s Stadium, home of the San Francisco 49ers. The home of the New York Giants and New York Jets, Metlife Stadium, was built in partnership with the United States Environmental Protection Agency. Just a few of the many initiatives of this stadium include, food composting, low-flow faucets and toilets, installation of solar panels, and aggressive recycling both in the stadium and by having used recycled products to build the stadium.
Many of the largest industry names are pushing sustainability initiatives. For example, renewable energy accounts for 100% of the energy used at Apple data centers. Even energy companies are looking for ways to be more sustainable and urge the United States to stick to the agreements of the Paris Accord. The CEO of Shell, Ben van Beurden, spoke to NPR and stated, “We believe climate change is real. We believe the world needs to go through an energy transition to prevent a very significant rise in global temperatures. And we need to be part of that solution in making it happen.” Shell is not the only energy company in favor of the Paris Agreement. Exxon Mobil, Chevron, and BP also spoke out in support of the agreement. Exxon Mobil’s CEO, Darren Woods, wrote the following in a blog post. “I believe, and my company believes, that climate risks warrant action and it’s going to take all of us – business, governments, and consumers – to make meaningful progress. At ExxonMobil, we’re encouraged that the pledges made at last year’s Paris Accord create an effective framework for all countries to address rising emissions, in fact, our company forecasts carbon reductions consistent with the results of the Paris Accord commitments.”
The Three R’s
It’s not just government’s and companies’ responsibilities to aim for a more sustainable future. All citizens have the responsibility as well. The three R’s – reduce, reuse, and recycle, are good to practice as we think of ways to cut our own carbon footprint. We may not all be able to make the capital investment into solar panels the way many cities and companies have, but that doesn’t mean we can’t work toward a more sustainable future. In Pennsylvania, you can shop for energy providers and select a plan that provides a portion of the energy from renewable sources. If you have a shorter commute, bike to work one day a week. Not only does this cut down on emissions, but you get a work out in at the same time (win-win)!
Reduce the items that you use on a daily basis, specifically single-use items that end up directly in the landfill. Cut back on single-use items such as paper plates, plastic dinnerware, plastic shopping bags, and plastic straws. More and more people are bringing reusable water bottles and coffee mugs to work every day. Carry reusable shopping bags in your car so that you always have them with you. If you use paper towels to clean, look into the microfiber cloths on the market. You may find you can cut your paper towel usage significantly.
We obviously can’t reduce or cut all items but we can find a way to reuse some items. Consider donating old items rather than throwing them away. The saying is true – one man’s trash is another man’s treasure. Not only will you be helping the environment by prolonging the life of an item, you may also be helping someone in need.
And last but certainly not least, recycle. Most cities and municipalities have made recycling so much easier by providing bins or totes and allowing all recycling to be commingled into one container. Strive each week to have more recycling than trash. Break down all food boxes, recycle paper towel and toilet paper rolls, all glass and plastic bottles, once rinsed, can go into the recycling bin. Recycling quickly becomes second nature and part of the daily routine.
Together we can work toward a cleaner, greener future.
Pace Acquires ESC
Pace Analytical Services, LLC (Pace) headquartered in Minneapolis, Minnesota, acquired ESC Lab Sciences (ESC) located in Mt. Juliet, Tennessee, on June 31, 2017. The ESC acquisition provides Pace with an additional, large full-service laboratory, which is centrally located in the southeastern United States. Additionally, ESC is accredited in 50 states, and that will provide Pace coverage over a wide geographic region. ESC will be a wholly owned subsidiary of Pace.
Alpha Certified for PFASs
Alpha Analytical of Westborough, Massachusetts, announced in early August that it has obtained Department of Defense (DOD), New Hampshire Department of Environmental Services, and New York State Department of Health certifications in aqueous matrix for per- and polyfluoralkyl substances (PFASs) by US EPA Method 537 Rev 1.15 and a proprietary liquid chromatography/tandem mass spectrometry (LC/MS/MS) isotope dilution technique.
Enthalpy Enters Dioxin/Furan Market
Enthalpy Analytical located in Wilmington, North Carolina, announced in early August that it had obtained National Environmental Laboratory Accredidation Program (NELAP) accreditation from the state of Louisiana for dioxin/furan analysis in air emissions, hazardous materials, solids, non-potable water and biological tissue; associated methods include Method 23, 0023A, 8290A, and 1613B. The Enthalpy dioxin/furan Ultratrace analysis program is led by Dr. Bryan Vining and Ms. Cindy Tondeur James. Enthalpy is a subsidiary of the Montrose Environmental Group.
Duke Admits to Data Falsification
Duke University admitted that a laboratory technician falsified or fabricated research data on respiratory illnesses that were used to get large sums of grant money from the US EPA. The admission was part of a federal whistleblower lawsuit in which Duke laboratory technician Joseph Thomas alleged that fake research data of Erin Potts-Kant, an 8 year Duke employee at the medical school laboratory, was used to obtain federal grants worth $112.8 million to Duke and another $120.9 million to institutions like University of North Carolina-Chapel Hill and North Carolina State University.
TestAmerica Acquired CH2M Applied Science Laboratory
In early June 2017, TestAmerica Laboratories, Inc. (TestAmerica) acquired the assets of the CH2M Applied Science Laboratory (ASL) based in Corvallis, Oregon. The ASL facility offers a diverse range of environmental testing services and increases TestAmerica’s capabilities in aquatic toxicity, and treatability and process engineering studies.
Environmental Standards Announces New Associate Principals
Environmental Standards today has announced three well-deserved promotions. These three professionals have joined our executive team and Environmental Standards will support their efforts as it continues to develop business lines, and expand its corporate footprint.
Shaun joined Environmental Standards in 2004 and has advanced through progressively more responsible positions in both the Geoscience Department and as a leader in our expanding compliance auditing practice. Shaun has played a key role in helping us land and deliver on several large client projects in our developing HSSE consulting/auditing practice.
A 2004 graduate of the University of Delaware, Shaun is a Certified Professional Environmental Auditor, and a certified Project Management Professional. In his new role, Shaun will continue to advance Environmental Standards’ capabilities in the geosciences and the environmental compliance market on both a national, and international basis.
Erin has been with Environmental Standards for more than 12 years and has worked in the Consulting Chemistry Department here at Valley Forge office since joining the firm. Erin earned her degree from West Chester University and came to us shortly after graduation.
During her tenure here, Erin has implemented and improved processes, which, in turn, have improved efficiency in the Chemistry Department. Erin has quickly has excelled in the company’s forensic practice. Overall, Erin has consistently been recognized by management, peers, and the firm’s clients for her outstanding achievements in her technical work, developing new clients/market sectors, and as a highly organized multi-tasking project manager.
Joining the firm with an impressive tenure of more than 25 years in both chemistry and geoscience, Lydia has been with Environmental Standards for over 3 years. Lydia is successfully managing some of our best client relationships and has been identifying and developing new clients in the chemistry and geoscience market – proving herself to be a committed company advocate.
Lydia came to Environmental Standards from another environmental consulting firm and brought with her energy and enthusiasm. She has continued to use this, while helping the firm to improve its sales and reputation in the Mid-Atlantic marketplace. Her background in environmental consulting gives her an in-depth understanding of the need to excel in customer satisfaction, and most importantly use this understanding to improve the satisfaction of our clients. Lydia is a Licensed Remediation Specialist in West Virginia and will be focusing on the firm’s business expansion in the Northeast, with immediate focus on the New Jersey and New York areas.
Where in the World?
Those of you working with members of the Environmental Standards, Inc. (Environmental Standards) HSSE (Health, Safety, Security, and Environmental) Compliance Group may have been hearing far-flung travel stories. Racking-up serious frequent-flyer miles, in the past 6 months, members of our HSSE Compliance Group have traveled from New Zealand to India, to the Netherlands, to Argentina to Ontario – working on five of the world’s seven continents. These travels may not seem like a big deal to multi-national mega-firms and corporations, but it is quite a feat for a domestic consulting firm with less than 100 employees. Looking forward, our HSSE Compliance Group has scheduled upcoming HSSE Auditing work in Africa, the Middle East, and Asia.
So why and how are the Environmental Standards HSSE Compliance Group members doing so much international traveling? It starts with a firm belief that our clients’ regulatory compliance demands shouldn’t be limited to support services based on geography. We strive to identify the best personnel fit for each project, assigning the appropriate subject-matter expert to meet compliance needs. With sufficient time to plan, we have been able to leverage existing travel schedules to offer clients a value-add approach – cost-sharing potentially expensive travel costs. With travel expenses rendered insignificant, we can provide a key personnel fit based on the scope of services. With the experience gained, our HSSE Compliance Group is beefing up the range and depth of regulatory knowledge to include various countries.
Much of the aforementioned work Environmental Standards is engaged in is related to ensuring foreign operations, vendors, and suppliers are meeting the same stringent criteria our clients have established here in the U.S. Building a working knowledge of foreign regulations is a key aspect to international HSSE compliance work; many firms that do not routinely perform this type of work can quickly find themselves out of their depth. Understanding that polychlorinated biphenyls (PCBs) in any form have been banned from the entire country since the end of 2016 is just as important as knowing California considers “Used Oil” a hazardous waste (the New Zealand government was disposing of PCBs for free through the end of 2016).
We encourage those with international HSSE Auditing and Compliance needs to contact Shaun Gilday, CPEA, Tim Cory or Michael Green, Ph.D., CPEA, for a current schedule of international travel.
Final 2017 Method Update Rule Approved for Publication
On August 7, 2017, US EPA Administrator Scott Pruitt signed the final Clean Water Act Methods Update Rule for the Analysis of Effluent (2017 MUR). Originally proposed on February 19, 2015, the rule was signed on December 15, 2016, by former US EPA Administrator Gina McCarthy. With the current administration’s ‘‘Regulatory Freeze Pending Review’’ action, the rule signed by Administrator McCarthy was never published, but Administrator Pruitt’s signature now clears the way for promulgation. It will be published in a future Federal Register (generally, it takes about a month between signature and publication), at which point the regulated community will have 30 days to implement the rule.
The 2017 MUR identifies acceptable analytical methods as well as collection, preservation, and holding time requirements for samples analyzed for compliance with National Pollutant Discharge Elimination System (NPDES) permits pursuant to the Clean Water Act. It accomplishes this by updating existing sections of 40 CFR Part 136.
Most of the changes engendered by 2017 MUR are minor, simply replacing currently approved versions of analytical methods with more recent versions. For example, many currently approved methods are published in the 1997, 1999, or 2000 editions of Standard Methods for the Examination of Water and Wastewater (SM). The 2017 MUR replaces these with the same method, but from the 2011 edition of SM. In most cases, the changes between editions are editorial in nature and not substantive; the underlying analytical procedures have not changed. Some of the more substantive changes included in 2017MUR are the introduction of new versions of US EPA Methods 608, 624, and 625; and a revision of the procedure used to determine the method detection limit (MDL).
Methods 608.3, 624.1, and 625.1 are specific about the discharger’s responsibility for providing the laboratory with sufficient volume to permit analysis of a matrix spike (MS) and matrix spike duplicate (MSD) periodically and instructing the laboratory to perform MS and MSD analyses on that specific sample. The new versions of the methods also require that, unless specified otherwise by a regulatory authority or in a discharge permit, results are to be reported down to the concentration of the minimum level (not the MDL). Finally, all three require that the result reported for an analyte be the result in a sample or extract that has been diluted to the least dilute level at which the measured concentration is within the calibration range. This may require combining results from analyses of diluted and undiluted samples to cover the entire list of parameters of interest for a given method.
The MDL procedure in 2017 MUR adds a component of temporal variability by requiring that the MDL be calculated based on standards prepared and analyzed in at least three batches on different calendar days. In addition, if a laboratory chooses to use a single MDL for all instruments used for a given analysis, the new procedure requires that the MDL standard be analyzed at least twice on each instrument, with a total of at least seven analyses. The analyses must be performed on different days, and with at least seven replicate standards that have been prepared (extracted/digested) in at least three different batches. The new procedure also requires that, in addition to calculating an MDL based on replicate analysis of spiked standards, a separate MDL be calculated based on method blank results. Once separate MDLs have been calculated for spiked standards and method blanks, the higher of the two are defined as the final MDL. Finally, the new procedure requires that the MDL be verified annually, based on measurements taken at least quarterly.