NOTE: There will be a series of SLAG presentations at the August TNI/NEMC Forum in Bellevue Washington. They will be Wednesday, August 17th in the afternoon. Hope to see you in Bellevue (right next to Seattle). Keith
Small Laboratory Call Meeting Minutes
April 20, 2011
Keith Chapman called the meeting to order on Wednesday, April 20, 2011 at 1:00pm. 13 participants, including the following members, were present:
“Lab Only” call. Discussion of issues private commercial labs (and public labs, too) – have with the TNI program improvements we’d like to see, etc.
Sue Boutrous/Keith – would help other state programs if there was a comparison of what fees other labs were paying? Labs could also compare to find the most cost effective place to have your primary accreditation – a lot of work to compare since you have to search the AB websites separately.
What improvements would we like to see in the TNI Standard?
John – two cycle thing ( only two corrective action responses allowed )that TX has got – if you don’t do it the second time, you flunk. Had gone through 7 – 8 rounds with previous organization (asbestos testing) in order to get it right. Difficult to do in 2 x when you have a small 1 or 2 person lab. “Can’t answer that – that’s part of what you’re supposed to be responding to.” “Hired” inspector flunked me on the spot – no uniformity in inspections/inspectors. Effective of an assessment on a small lab – things can grind to a halt as they try to respond to inspection findings. Charges for small labs the same as charges for large labs for tests run.
Curtis Reed – started small lab in 1988. Lots of inspections thru State. Tried to get NY certification. Every state is a little different in how they institute the guidelines (every TNI State? – don’t know) Guidelines have gotten stricter over the years. Want to catch you on new little things. Costs keep rising. I.e., NY wants to charge per analyte, not per methods, every year for accreditation. Restricts ability for the small lab to make any money. Almost running smaller labs out of business. Requirements for recordkeeping and requirements for paying for certs - favors the large labs. No leeway for the smaller lab. Result: more and more consolidation and loss of local labs. Expense makes it hard to expand your testing ability. No consistency state to state; inspector to inspector – depends on who you get as to how you do.
Joanna – nothing yet. Lab doesn’t exist yet. New Standard should be fairly easy for me because I don’t have anything to compare it to. Have not yet been assessed.
Dave – Accredited strictly in NY. Lab = 10 people. Not seeing any real problem switching over to the new TNI standards. Not that much add’l to add. One advantage – have a half a person dedicated to maintaining the compliance so we may be in better shape than some of the smaller labs. “Need to understand what they want.” Have had 3 NELAC audits, same auditor, always willing to help us – relatively straightforward – our fault, not the auditor’s. Most of the stories seem to come from having different auditors come through. Has program improved labs quality? Yes. A lot more confidence in what we’re reporting. A positive experience. Upper mgmt gets concerned about costs but lab people taking things very well and happy.
Elizabeth Turner commented later that: I agree with the one caller that all the additional requirements of TNI didn’t necessarily improve the quality of the analytical work that my lab does. However, the TNI requirements certainly improved my ability to demonstrate the quality of our analytical work. As a water utility, if there are ever any data points that don’t meet the expected results, the lab is immediately blamed. “It must be analytical error.” However, with the added QC, training records, PT studies, etc, I am able to demonstrate that the unusual result is not the result of ‘lab error’ but that there was a problem at the treatment plant or the sample collection process. Again – I don’t think our quality of analytical work improved but our ability to prove to others the quality of analytical work was improved by complying with the TNI standards.
Consistent auditying and willingness to help important.
Myra – working on North Carolina application but have not been assessed yet. Planning to use NJ as primary. Have finished Quality Manual. Using 2009 Standard. Medium sized lab (35 people). A consolidation of 4 small utility labs, all of which did things a little differently.
Dottie – myself and 1 part time person only. Certified for most of the analyses here in new York. Drinking water city lab. Dottie wears all the hats. What gets hectic with TNI Standard? Just a lot of work to make sure everything gets done and correctly. Used to be a lab director here that d/n have everything up to date so working on correcting that. Last assessed 2 years ago.
AUGUST TNI MEETING
Will have about 1 ½ hours to discuss what SLAG is doing.
Hoping Small Lab Handbook will be presentable by the meeting.
How ABs and States can help Small Labs…
• Charging less
• Be more consistent
• Inspectors should/could be more helpful – less adversarial
• Be nice if there was some source of information that the small lab could draw on – a mentoring relationship?
Where have you found helpful info? New York, Florida have pretty good websites. Generally not a lot of stuff out there for smaller labs.
Private labs are more resented for trying to make money; more friendly with municipal entities. Assessors don’t seem to understand that findings could impact costs on a lab, especially a small lab. If this were taken into consideration, what would that mean? Finding a cost effective way to meet the findings is a challenge. TNI Standard will not be enforced the same way state to state.
If TNI was a national accreditation, then you get only assessed by one set of assessors.
Bill – working in lab 15 yrs – two people handling everything. Doing things the same way 15 years ago as we are doing them now. Were certified by a state agency then. Only diff under NELAC/TNI, just results in mountains of paperwork (takes me out of the lab) – no net worth in terms of the quality of data coming out of the lab. Chasing your tail – doing a lot of paperwork with no net benefit to lab quality. (KCH comment: this group seems to be on both sides of this issue.)
Every state has different requirements on electronic reporting formats. No consistency state to state. Have to customize each report. Need consistent, straightforward way to do electronic report, that is not burdensome to the labs. Is anyone at the states going to look at this stuff?
Labs also have to deal with State DW and WW reporting requirements that vary from state to state, not to mention TNI reporting criteria!
What about the cost of having to pay for 2 sets of PT year… what about the quality impact of only doing one pt per year:
Elizabeth—fine as long as if you fail, you have to do a make up PT.
Grimes - PTs – small labs – have to run it as though it just came in. We don’t have them come in often enough. Works fine for a big lab but not for a small lab that may run some analyses once a month or two. Texas assessors check this closely.
Elizabeth Turner comment:
On a separate note – Texas never had a state program for certifying labs for wastewater analysis. Labs had to do the DMRQA study but that was it. I cringe at how some of my waste water labs did things – no SOPs, only did QC on effluent samples since they were the compliance samples, never documented training and never did mdl studies. They would report results to the theoretical mdl without ever determining if the lab could actually detect anything that low. In addition, the lowest calibration standard would be much higher than what the lab report. For example, for ammonia, the lowest calibration standard would be 0.25 mg/L but the lab would routinely report results as < 0.05 mg/L without ever doing a mdl study or running a check standard at 0.05 mg/L. For this lab, going to the TNI standards did improve the quality of the sample analysis and significantly improved documentation of basic quality control.
NELAC Standard has increased:
Quality of data (“data of known quality”)
Confidence in your lab’s analytical abilities