SIR #: 212
Standard: 2009 TNI
Section: V1M2, Section 220.127.116.11 (a) and (b)
With respect to the wording about experience, paragraph A, sentence number one states ".....and at least two (2) years of of experience in the environmental analysis of representative inorganic and organic analytes for which the laboratory seeks or maintains accreditation." Paragraph b sentence 2 states.... " In addtition, such a person shall have at least two (2) years of experience performing such analysis".
Question #1 : What is the difference between "..experience in the environmental analysis of..." , as stated in paragraph a and "...experience performing such analysis", as stated in paragraph b.
Question #2 : relating to the interpretation of "representative organic and inorganic analytes".... to what degree does methodology/technology coming in to play. Can the word "representative" be better defined?
We do not find anywhere in the document that requires experience in multiple technologies. For example, if the director has experience with Analyte A using an automated inorganic method (such as segmented flow) and experience with Analyte B using a conventional wet inorganic method (such as titration) but the lab runs analyte A wet and analyte B automated, would this person have the requisite experience in that area?
TNI FINAL RESPONSE:
(Quality Systems Expert Committee and NELAP AC, 4-7-14)
Question 1 - There is no difference in the meaning of the wording of the two paragraphs. Each refers to two years' experience in the analysis of samples. (not oversight/management of sample analysis).
Question 2 - Representative - exemplifying a group or kind; typical: a representative selection of analytical methods. A Technical Director must have experience in the typical methods/technologies used by the laboratory.