As discussed in Part 1 and Part 2 of our three-part series on laboratory auditing, an on-site third-party laboratory audit is an important tool for the petroleum sector to monitor and ensure compliance with a benzene waste operations NESHAP (BWON) consent decree and to assess data accuracy and defensibility in addressing corporate environmental liabilities.
Laboratory audits are not only a requirement of consent decree compliance, but also serve to ensure that samples are properly analyzed and that results are accurately reported. Thoroughness of an audit is a critical factor in identifying issues and implementing documented corrective actions. Inter-laboratory and intra-laboratory practices are observed during on-site audits for analytical and non-analytical activities within commercial environmental laboratories. Buyers of laboratory services should prepare technical specifications for analytical and associated peripheral non-analytical activities.
Environmental Standards’ quality assurance chemists conduct hundreds of benzene NESHAP audits every year on behalf of industrial clients. Our auditors recently shared significant findings.
Top Findings from Recent BWON Audits
- Samples were left on a desk at the refinery unrefrigerated for almost 14 days prior to being sent to the laboratory for analysis. Although samples were analyzed outside of the method specified holding times, these exceedences were not noted in the laboratory case narrative
- Chain-of-Custody documentation was noted as being incomplete; custody was broken for the sample collected
- Sample storage temperatures were not monitored or corrective action was not taken when temperatures exceeded acceptance criteria
- Samples received at improper temperatures and containing significant headspace
- For an alarming number of on-site evaluations, the corrective actions based on failing QC samples were variable from analyst to analyst and included repeating only the failing QC samples and not the associated batch samples
- During an on-site data review, misreported results were detected. Upon recalculation by the auditor, it was determined that results were off by a factor of 100 due to calculation errors.
About the Author
Rock J. Vitale, CEAC, is the Technical Director of Chemistry/Principal and a founding partner of Environmental Standards, Inc. Rock has 30 years of analytical quality assurance experience, performing hundreds of rigorous laboratory audits. When he’s not traveling for business, Rock spends his free time fishing, hunting, and hiking.