A Private Laboratory Perspective on Environmental Regulation.
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Transcript of A Private Laboratory Perspective on Environmental Regulation.
Introduction to CCIL• CCIL represents the independent testing
laboratories sector.• Part of a $2.3-billion-dollar-a-year industry that
employs 20,000 skilled workers.• Members operate more than 330 lab facilities, • We work collaboratively with Government.
Canadian Council of Independent Laboratories
• Represents the interests of the private laboratory community.
• Two divisions• Environmental• Geotechnical
Environmental Division•100 Accredited Labs Across Canada
•$350 MM in annual revenue
•4500 knowledge based jobs
•Our members do the vast majority of testing in support of Federal and Provincial Environmental Regulation
Concerns
• Guidelines at or below laboratory method detection limits (MDLs)
• Widely differing Guidelines between agencies
• Lack of notice when new Guidelines are introduced.
• Inconsistent or no Data Quality Objectives
Guidelines Below MDLs
• CCME Reactive Chlorine Species 0.5 ug/L MDL 3 ug/L
• CCME Toxaphene Soil 0.0001 mg/kg MDL 0.005 mg/kg
• Frustration with the data user
• Makes the Lab look incompetent
Guidelines at MDLs
•ESRD Agricultural Guideline: • Vinyl Chloride 0.34 ug/kg MDL 0. 33 ug/kg
•Measurement Uncertainty at the MDL ± 60% - 100%• 19 of 20 measurements at 0.34 will fall between 0.13 and
0.43 ug/kg in the best case• We measure 0.4 ug/kg. Is it really above the Guideline?
Widely Differing Guidelines
• Labs often don’t know source of sample• Guideline may impact method choice• Can there not be consensus?
CCME OMOE ESRD BCCSR
Xylenes mg/kg
2.4 0.05 15 0.1 - 20
Lack of Notice New Chemicals Revised Values
• Hydrazine: FEQG published Feb 2013 also adopted by ESRD 2014 surface water quality guidelines
• No lab analyzing currently• Preservation problematic (degrades up to
100% in 4 days (FEQG factsheet)
Lack of Data Quality Objectives (DQOs)
• Lab Methods Performance based
• How do we ensure consistent data between labs ?
•What are DQOs?• Lab QC samples run with every batch carried
through the whole process + LRLs• Blank, blank spike, matrix spike, duplicate• Guidance on acceptable values
• E.g. Blank < LRL, blank spike 80% - 120%
Lack of Data Quality Objectives (DQOs)
• OMOE and USEPA have historically provided DQOs
• CCME Analytical Methods Compendium recently developed also contains DQOs
• Concerted effort to make CCME and OMOE consistent
CCIL strongly supports adoption of consistent, reasonable DQOs across Canada
• Best practice to ensure consistent data between labs