As reported in the last issue of the The Standard, labor markets remain tight in the laboratory testing marketplace (and elsewhere). Turnaround times are edging longer and longer, with many laboratories reporting significant delays in delivery of per- and polyfluoroalkyl substances (PFAS) testing results because of a massive surge in sample analysis requests for this class of compounds. A few newsworthy stories are summarized below.
Eurofins Burlington Fined for Hazardous Material, Air, Waste Violations
As reported by the Vermont Business Magazine, the Vermont Agency of Natural Resources Department of Environmental Conservation (DEC) fined the TestAmerica laboratories, Inc. facility in South Burlington, Vermont (Eurofins Burlington) a sum of $12,368 in mid-July 2022 for hazardous material, air, and waste violations following a routine DEC inspection. The DEC conducted a routine inspection of the facility on September 28, 2021, and found that filters used in the extraction/wet chemistry laboratory that contained solvents and methylene chloride were mismanaged. The filters or “puffs” (presumably polyurethane foam sorbent tubes) after use were ventilated to the outside air allowing the solvents to evaporate in violation of the Vermont Hazardous Waste Management Regulations. After the puffs were dry, they were disposed of as solid waste instead of as hazardous waste in violation of the Vermont Solid Waste Management Rules. The DEC inspection also revealed that the most current version of the facility’s contingency plan had not been submitted to the local police department, as well as some training and inventory violations.
Eurofins Burlington promptly discontinued the puff evaporation process and corrected the other violations following the inspection. Eurofins Burlington agreed to pay the fine of $12,368.00 as incorporated into a Final Order of the Vermont Superior Court, Environmental Division on July 13, 2022.
Phoenix Environmental Laboratories Fined for Workplace Safety Violations
On September 16, 2022, The U.S. Department of Labor issued a press release announcing that it has fined Phoenix Environmental Laboratories Inc. (Phoenix Environmental) of Manchester, Connecticut, $907,000 for workplace safety violations. An Occupational Safety and Health Administration (OSHA) investigation found 17 violations at the company’s East Middle Turnpike facility, including unsafe exposure to chemicals that management was aware of, but neglected to fix the problem. “Phoenix Environmental Laboratories knew of its employees’ exposure to a highly hazardous and carcinogenic chemical, yet chose to ignore their complaints and failed to take effective corrective action,” said OSHA Area Director Dale Varney in Hartford, Connecticut.
Phoenix Environmental is an environmental laboratory that conducts analysis of soil, water, air, sludge, and solids for businesses and governmental agencies. In a report dated Aug. 26, 2022, OSHA cited Phoenix Environmental Laboratories with 17 violations stemming from inspections conducted between February and April at the company’s facility. Department of Labor officials said employees complained to management about faulty ventilation systems and symptoms of exposure to methylene chloride, a chemical used in environmental analysis.
The OSHA report states that between Feb. 23 and May 6, employees reported symptoms including dizziness, nausea, unsteady walking, and lightheadedness in 13 instances.
On or about April 14, a measurement of methylene chloride taken in the facility showed average concentration in the air over the course of a shift at approximately 3.2 times the permissible exposure limit. The report states that inspections revealed improperly stored chemicals, unsuitable or missing safety equipment and procedures, and incidents during which employees were exposed to potential electrical shock or hazards as a result of an electrical fault. If the company does not correct the stated violations by Oct. 14, 2022, it will be subject to further penalties.
Change is Coming – Can you Believe it?
Polychlorinated dibenzo-p-dioxins (PCDDs, or commonly “dioxins”) and polychlorinated dibenzofurans (PCDFs, commonly “furans”) have been compounds historically analyzed by high-resolution gas chromatography/high-resolution mass spectrometry (HRGC/HRMS) with isotope dilution. US EPA Methods 23, 8290 and 1613 have used magnetic sector-type HRMS. Polychlorinated biphenyl (PCB) congeners are also analyzed (Method 1668) using the same type of magnetic sector-type HRMS. Unfortunately, the market is limited for these very expensive (and robust) mass spectrometers and instrument manufacturers and discontinuing production of new instruments. According to US EPA’s Clean Water Act Analytical Methods website:
“… EPA heard from instrument vendors and laboratories analyzing PCDDs/PCDFs for some time that there was likely to be little further development or support of the high-resolution mass spectrometers (GC/HRMS) required to run Method 1613B. Several vendors have ceased development of high resolution mass spectrometers, so it will become increasingly challenging for laboratories to obtain parts and supplies for specific instrument models from these vendors.”
Given the difficulties with maintaining magnetic section HRMS long term, laboratories are turning to triple quadrupole mass spectrometry (MS/MS) methods for compounds such as dioxins, furans, and PCBs. Per- and polyfluoroalkyl substances (PFAS) already make use of GC-MS/MS in methods such as Method 537.1.
So, what’s new? US EPA has reviewed Alternate Test Procedure (ATP) applications for dioxins and furans developed by SGS Axys (British Columbia, Canada) and Pace Analytical Services, LLC (Minneapolis, Minnesota) for use in wastewater. These methods are based on GC-MS/MS instrumentation. According to US EPA’s Clean Water Act Analytical Methods website the methods are:
- SGS AXYS Method ATM 16130 (ATP Case No. N18-0003), “Determination of 2,3,7,8-Substituted Tetra- through Octa-Chlorinated Dibenzo-p-Dioxins and Dibenzofurans (CDDs/CDFs) Using Waters and Agilent Gas Chromatography-Tandem-Mass Spectrometry (GC/MS/MS)” and
- Pace Analytical Method PAM-16130-SSI (ATP Case No. N21-0001), “Determination of 2,3,7,8-Substituted Tetra- through Octa-Chlorinated Dibenzo-p-Dioxins and Dibenzofurans (CDDs/CDFs) Using Shimadzu Gas Chromatography Mass Spectrometry (GC-MS/MS), Revision 1.1.”
US EPA has reviewed the validation data for these new methods and intends to include the methods in future promulgation actions under 40 CFR Part 136. As such, the methods are not approved without going through the rulemaking process, but users may on a facility-by-facility basis seek approval of US EPA to use these methods via the ATP process.
Oddly, PFAS analysis by draft Method 1633 seems to have a different set of rules applied to its use by US EPA under the Clean Water Act than these new GC-MS/MS methods. See our previous article on Method 1633 in our December 2021 Newsletter.