Concerns

[WAS]

The accreditation programs for the air markets have not been as wide spread as the soil/water markets, partly due to the relatively high variability of many of the matrices. Some sample have no "air" in them but are still gas samples, for example. We have been involved in some type of program for quite some time, mainly because we cajoled an agency into including us in their program.

However, recently I was surprised to be told by a NELAC body of their retroactive change to accreditation certificates going back over two years to add methods/analytes which should have been included initially. The question had been raised by a reporter from a major news organization about some analytical reports he had been given. The question led to the discovery of certificates of accreditation which did not list the methods/analytes but which were supposedly covered under the NELAC program.This ability to retroactively change the official documents of a program such as this really concerns me at the moment. Is this more common that I know or is it a concern for others?

[lschantz2]

What you describe is certainly confusing. Could you provide a bit more details on: 1) what methods/analytes were added retroactively; 2) What nelap body; 3) how did a news organization get involved; 4) was there a change in an EPA reg that precipitated these actions??

Len

[WAS]

The reporter was the one who brought part of the issue to my attention. He had a report he wanted to know if it followed the correct protocols. There evidently had been some suggestion of some type of question concerning the quality landfill gas monitoring, possibly related to carbon emissions another reporter posed just prior to this. It was only a single page of results and a cover/comments page so there was nothing to determine. In checking into it the issue with accreditations came up.

The State of Louisiana had originally had the submission for Methods RM3-C and RM25-C (40CFR append. A) for landfill gas analysis in early 2007. They had issued a certificate of accreditation in July of that year listing on RM25-C and listing the analytes for RM3-C under that method, which is not possible due to the differences in columns, detectors, and procedures. It took some digging to find this as the NELAP site does not list methods/analytes, the state site did not list the methods/analytes, and the lab site did not list the Louisiana accreditation at all. Once the certificate was finally found it raised the question of whether there was a valid accreditation, especially given the cover letter sent by the State of Louisiana with the certificates stating no methods/analytes were accredited unless they were listed on the certificate even if they were applied for by the laboratory. It all seemed fairly cut and dried until the state was questioned about the issue. They determined they made a mistake by not including the correct methods and analytes as their corrective actions had all been met at the time.

They reissued the previous certificate in October of this year with the correct methods/analytes backdated to 2007. They claimed that is the required action by their regulations under the NELAP program. The whole official document aspect requirement seemed to be ignored in favor of pretending it did not make any difference.

No EPA regulations were changed, in fact the regulations for the RM25-C allow only one column set which would preclude any modification to try to include the second method.

I just recently contacted the reporter to give him copies of the correspondence between myself and the State of Louisiana and the attorneys for the lab, which decided my questioning of their accreditation was a slander against their reputation. That aspect has been resolved but it raised some legal questions concering the accreditation process and program.

[lschantz2]

This is a bizarre story. Maybe I shouldn't have asked for more details. I'm far from an expert in this stuff but I will try again to bring your question to the attention of people that are fluent in NELAC / NELAP. It may be a simple case of the State making a typo error when they listed RM3-C analytes with the RM25-C method. I've seen that type of thing happen before. If that was the case, then it would also seem reasonable, to me anyway, that there should be a process whereby one could re-issue certificates that were issued with the original error. I'm not sure of the answer, but good question.

[WAS]

It is bizarre and more so that it was essentially ignored for so long. The errors went well beyond a typo as the last certificate had the methodology references changed so the time span for the certificate started at that point. There was a caveat of the change in reference not representing the total period of certification, which seemed to be more of a cover than a correction of error. In any case it does raise the question of how any accreditation is known if an error on the documentation is propagated over a period of years. Is the method/analyte accredited or is it just a typo? Is there a method/analyte which is not listed but is actually accredited? That would seem to be a critical failure as far as any outside review would go.