As many of you know, I am an old guy when it comes to environmental laboratories. To put it in perspective, the 13th edition of Standard Methods was in; the hip new thing was flame AA; and there were only 6 pesticides and 2 herbicides in the world. Both the Safe Drinking Water and Clean Water Acts were brand new. There were no hazardous wastes anywhere although rivers caught fire. That was February 1973.
There was a laboratory certification program then managed by Department of Health Service’s Sanitation and Radiation Laboratory. In those days, the program offered certification for drinking water and wastewater; certificates were for three years; renewal was automatic; and it was free. There were two designated assessors, one at each end of the state although sometimes others were brought in. In my first 8 years, I had the privilege of participating on the side of the laboratory in 5 onsite assessments (same company, 3 different labs) and awaiting those proclamations from Berkeley.
It can be said that lab certification nationwide began with the advent of the Safe Drinking Water Act and Primacy. However, even in 1973 it was clear that certification began in California long before even my appearance. In doing some research I have found regulations for laboratory certification from 1951. There existed in CCR Title 17 rules vaguely like what we have today. Some interesting things: labs were split into Commercial and Noncommercial labs however the only difference was that Noncommercial labs could get approved for specific tests. Commercial labs were all chemistry, all microbiology, or both. PT samples were called Check Specimens. Just to give you a perspective, CCR section 1178 covering facilities said, “Approval shall be granted only after housing, equipment, and supplies have found to be adequate.”
Those rules lasted until 1979 when new rules replaced them in Title 22, 64481. Those rules changed a few things. There no longer existed Commercial and Noncommercial categories and the method categories expanded to 9. Performance Evaluation samples replace Check Specimens. But the language had not improved much. Section 64485.(a).(2) covering facilities now said, “Physical facilities, equipment and related appurtenances are adequate for accuracy and precision of analyses within the categories of tests for which application has been made.”
Those rules lasted until 1989 with the advent of ELAP. ELAP brought together the existing drinking water and hazardous waste programs and reintroduced wastewater back into the mix. Not many remember that wastewater was part of Health Service’s program. It was handled via a contract between Health Services and the State Board. In 1981 someone decided that they needed the money more and cancelled the contract. Health Services stopped visiting labs and issuing certificates for wastewater. This was my introduction to lab assessments as I had just started working at Regional Board 7 in 1981. This choice wasn’t without issues and the State Board even investigated starting their own program when they go word of ELAP in 1988.
So how does this historical view compare with ELAP today. To begin, the world is a bigger place with respect to lists of analytes and things to test. Of, course, people miss the “free” part of certification, but it is no longer possible for government to survive on general taxes alone. There has been an increase in quality control procedures and more methods are incorporating those into their procedures.
With the imminent implementation of TNI standards, laboratories face a significant task to create and implement not only the policies and procedures required by the standard; but also, the record keeping system that comes with the standard. Laboratories will find that paper (records and documents) will be the focus at onsite assessments. Now is the time to format plans to create missing and revise current analytical SOPs; and formulate training and demonstrations of capability processes.
There is much more to tell such as the beginnings of laboratory quality assurance/control but space is limited. If you are interested, I have copies of these older regulations and I always love telling stories.
The Analyst’s Notebook was a publication of the CWPCA Lab committee. The first editors were Bev Franza of the City of San Mateo and Scott Quandy of Las Virgenes Water District. It started in December 1984 and ran quarterly until 1998. There was a short-lived revival in 2007, but it has since disappeared. The focus was on current events and topics of interest to the lab community. It became one of the means of spreading the word about ELAP when it was created in 1989.