CWEA together with five other clean water associations, known as the Summit Partners, are calling on the State Water Board to offer two options for laboratory accreditation. We would like to see both TNI and State accreditation options.
The reason? TNI accreditation only will raise the cost of lab administration for all CA water and wastewater laboratories. It may even cause some labs in smaller communities to shutdown and drive up their costs to outsource lab testing. As California’s clean water professionals we want to focus on improving water quality, not adding administrative expenses.
We have reached the conclusion that requiring TNI for all labs in the state would cause a significant shift in investment from scientific personnel to administrative staff. As we have mentioned in previous comments, this places a substantial burden on all water and wastewater labs, particularly smaller labs with fewer resources, and does little for the protection of water quality and public health.
We believe that the hundreds of laboratories that our member agencies represent should be governed by the accreditation system that works best for their services to public health and the environment. Larger labs with a wider range of responsibilities and sufficient resources to implement the administrative burdens of TNI should be free to pursue that course. Other labs should be allowed to seek state accreditation without undergoing all of the steps required by TNI.
We implore you to revise current draft regulations to be in alignment with the ELAA and feature a dual accreditation system that can be supported by the water and wastewater community. The agency members and laboratories represented by the Clean Water Summit Partners are engaging in cutting edge science that will be needed to meet the water quality requirements of the future.