CWEA Comments on ELAP Regulations Development and Laboratory Standard

In response to community requests, including CWEA’s comment letter, the State Water Resources Control Board (State Water Board) has extended the comment period for the October 6thpublic workshop regarding the Environmental Laboratory Accreditation Program (ELAP) regulations development and preliminary recommendation for a laboratory accreditation standard to Thursday, October 20, 2016, by 12:00 noon.

On September 1, 2016 the ELAP informed the Environmental Laboratory Technical Advisory Committee (ELTAC) that ELAP will recommend to the State Water Resources Control Board (State Water Board) the adoption of the 2016 (The) NELAC Institute Standard (TNI 2016). This standard would be used to certify all wastewater labs in California to analyze their regulatory required samples. By recommending adoption of this standard, ELAP set aside the ELTAC recommendation to adopt a Quality Management System (QMS) building on the USEPA Quality Management System guidelines and adding in elements that the agency partners desired, referred to as “California Plus.”

On September 6, 2016 the State Water Board sent a notice of opportunity for public comment and notice of public workshop for October 6, 2016 regarding ELAP regulations development and preliminary staff recommendation for laboratory standard. The deadline to submit California State Water Resource Control Board Members was 9/15/16.

CWEA submitted a comment letter to the State Water Board requesting a comment period of at least 30 days to allow sufficient time to obtain and review this newly published document.

CWEA also addressed the lack of technical certification recognition in the TNI document. Technical certifications are a critical component in any standard for wastewater labs the state adopts to ensure that lab staff have the requisite knowledge, skills and abilities in the very specific field of wastewater analysis.

CWEA also feels that the existence of more labs, not fewer, is better for the environment. The TNI standard is overly complex for California’s hundreds of small labs. CWEA feels the adoption of this standard will force the closure of labs due to increased (unattainable) staffing needs, as has been documented in the few states that have adopted TNI standards without exception for non‐ commercial municipal laboratories. This is a major reason why the ELTAC recommended the “California Plus” option to ELAP at the August 24th ELTAC meeting and rejected the TNI standard.

View CWEA’s comment letter here.

The NELAC Institute (TNI) Standard, Volume 1, Management and Technical Requirements for Laboratories Performing Environmental Analysis (2016) is a copyrighted document, and is being made available by TNI for evaluation during this comment period in the following ways:

  1. A non-downloadable version will be available for viewing online by Monday, September 26, 2016, at http://www.nelac-institute.org/.
  1. A printed copy will be available for viewing beginning Wednesday, September 21, 2016, at all Regional Water Quality Control Board Offices  and Division of Drinking Water District Offices during normal business hours. Contact the office to schedule an appointment.
  1. A discounted version of the document is available for purchase by choosing one of the following two options:
  • Option 1: Purchase the document at a discounted member rate of $75. Request this by phone at (817) 598-1624 or by email to jerry.parr@nelac-institute.org and receive a free three-month membership to TNI, which will allow purchase of the document at the discounted member rate from the organization’s website.
  • Option 2: Receive a free evaluation copy. Request this by phone at (817) 598-1624 or by email to jerry.parr@nelac-institute.org to receive an electronic copy of the document for evaluation purposes only. The laboratory will be required to attest that the document will not be reproduced while in their possession. Failure to abide by the requirement to not reproduce the document could result in penalties for copyright infringement.

For questions regarding this announcement, email ELAP at elapca@waterboards.ca.gov.

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Megan Barillo

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