SIR #: 81
Standard: 2003 NELAC
I am a project manager for Head Start child care centers in New York City. We needed samples of drinking water to be tested for lead. I was disturbed to to see xxxxxxx (NELAC certified) did not have a chain of custody form. I was concerned that there was an unsigned gap in the chain of custody when samples were delivered by FedEx courier to a lab nearby. The question is: isn't a complete continous, signed Chain of Custody form required so the sample could be accounted for specifically by a signed individual - in order to be in accordance with Nelac and the EPA method? Thank you in advance,
TNI FINAL RESPONSE:
(Quality Systems Expert Committee and NELAP AC, 4-7-14)
A complete, continuous Chain of Custody form is not required for samples submitted under NELAC, unless otherwise specified by the client. Note that NELAC 5.4.12 differentiates between sample handling and tracking and legal chain of custody protocols.
NELAC 220.127.116.11.5 requires that a record keeping system allow historical reconstruction of all laboratory activities. "The records shall include the identity of personnel involved in sampling, sample receipt, preparation, or testing." A laboratory that does not record the receipt of samples by a specified individual is not compliant with this aspect of the standard.
Note that TNI 2009 does not contain identical language to NELAC 18.104.22.168.5, so a laboratory that does not record the receipt of samples by a specified individual and that is accredited under TNI 2009 is not outside of compliance with regard to this issue.