Accreditation 101

1. Accreditation 101 Paul Bergeron, LELAP Supervisor LDEQ Laboratory, Baton Rouge LA December 8, 2008

2. The NELAC Institute • 501(c)3 non-profit organization with members, managed by a Board of Directors • Organized into Programs that focus on the mission and vision of the organization

3. Current Status • The national program has achieved the following goals: • 13 AB’s • > 2000 accredited laboratories • Recognized competency standard • The transition continues……

4. 10 9 11 3 7 13 4 1 8 12 5,6 2 The NELAC Institute (TNI) NELAP Accreditation Bodies 1 CA Environmental Laboratory Accreditation Program 8 NJ Dept. of Environmental Protection 2 FL Dept. of Health, Bureau of Laboratories 9 NY State Dept. of Health 3 ILEPA, Div. of Lab., QA Section 10 OR Health Division 4 KS Dept. of Health and Environment 11 PA Bureau of Labs., Dept. of 5 LA Dept. of Health and Hospitals Environmental Protection 6 LA Dept. of Environmental Quality 12 TX Commission on Environmental 7 NH Environmental Lab Accreditation Program on Environmental Quality 13 UT Department of Health

5. NUMBER OF NELAP-ACCREDITED LABORATORIES BY STATE There are over 2000 laboratories in the continental US, Alaska, Hawaii, Iceland, Canada, and Europe participating in NELAP.

6. Who Are Our TNI Members? • Organizations that accredit laboratories • Accreditation Bodies • States that are not Accreditation Bodies • Federal Agencies that operate Accreditation Programs • Accredited laboratories • Commercial, Municipal, University, State, Federal, etc. • Others • State and Federal Agencies that do not operate accreditation programs • Data users, consultants, PT providers, vendors, etc. • Anyone interested in laboratory accreditation

7. TNI Board of Directors • 10 -18 Directors • Balanced Stakeholder representation • At least 3 Accreditation Bodies • At least 3 Accredited Laboratories • Others • Election for three vacancies was held in February 2008

8. What is the NELAP Board? • Representatives (and alternates) of the AB’s who are appointed by their respective state agencies • Tasked with 3 objectives: • Adopting an accreditation system • Adopting acceptance limits for PTs • Recognizing other accreditation bodies • Board is governed by a chair and assisted by a TNI program administrator

9. The NELAC Institute PO Box 2439, Weatherford TX 76086 Jerry Parr, Executive Director Phone: 817-598-1624 Email: jerry.parr@nelac-institute.org URL: http://www.NELAC-Institute.org

10. LDEQ-LELAP 602 North 5th Street, Baton Rouge LA 70802 Paul Bergeron, Supervisor Phone: 225-219-3247 Email: Paul.Bergeron@LA.GOV

11. LELAP

12. Accreditation Application • Electronic copy available on website • Must include application fee • Must include copy of Quality Assurance Manual and list of SOPs • Must include proficiency test results

13. Analytical Data Packages • Submitted in lieu of proficiency test results when there are no approved proficiency test samples • Defined as including all analytical method, technical information, and quality assurance results • If facility is not performing the method, it must provide data as specified by the reference method calibration or quality control requirements at a minimum

14. Confidential Business Information • See LAC 33:I.503 • Must be declared before an assessment begins • Materials granted CBI status will be locked with restricted access • Request must be renewed every two years

15. Renewal vs. Annual Fees • All fees are non-refundable • 3 year application renewal fees--$660 submitted with the renewal application • Annual Membership Fees--$594 to $1980/Major or Minor Test Category dependent

16. Test Categories • Metals • Microbiology • Biomonitoring • Classical Wet Chemistry (nutrients, minerals, ions, demands, and coliforms) • Minor conventional parameters • Organics (semi-volatiles, volatiles, pesticides, herbicides, and PCB’s) • Dioxins and Furans • Radiochemistry • Asbestos • Geotechnical Soil Testing • Air Pollutants

17. Minor Conventional Parameters • BOD5, Hexane-Extractable Material, TSS, Fecal & Total Coliform, and Residual Chlorine ONLY • Cost--$264

18. Schedules • Renewal Application—every 3 years • Annual Fees—every year • Assessments—every two years • Stack tester assessments include home base and field assessments • Field assessments may be static (demonstration only) and combined with home base. Assessment possible @ LDEQ Laboratory • Proficiency Tests and Analytical Data Packages—Twice a year~6 months apart

19. ASSESSMENT TEAMS • Assessment teams are comprised of assessors from LELAP and/or contract companies. • Third party assessments will be assigned at random. • Most assessments require at least two assessors.

20. Pre-Assessment Materials • Includes checklists, standard operating procedures, and data packages • Facilities are requested to complete and return the checklist prior to assessment • Offsite reviews reduce travel time to assessor and visiting time for laboratory

21. LELAP STANDARD OPERATING PROCEDURES (SOP’s) • LELAP staff meet with contractors to ensure consistency in assessments. • Upon recommendations from the meetings, LELAP revises its SOP’s. • Changes are made based on issues discussed during the meetings.

22. Method Update Rule (MUR) • Promulgated on March 12, 2007 by EPA • Took effect April 12, 2007 • Published in the 40 CFR 136. • Removed approximately 200 old EPA methods from the list of approved methods for the Clean Water Act and Safe Drinking Water Act. • Approved the use of Standard Methods 18th, 19th and 20th editions and Standard Methods online. • Addendum to rule recognized equivalency of selected Standard Methods from 21st edition and Standard Methods online.

23. Scope Amendments • Free of charge, unless a new test category is requested • Request must be submitted in hard copy, accompanied by one round of proficiency test results (state) or two (NELAP) • No addition amendments are allowed during the assessment process

24. eNewsletter • LELAP posts a quarterly newsletter with topics of interest to accredited laboratories and clients of the LDEQ laboratory

25. Intense Management • For facilities with largely unapproved first draft of corrective action plan • Conducted by teleconference or meeting • Goal is to eliminate repeat findings and more than two drafts of corrective action plan

26. The Next Accreditation 101 • “Accreditation 101” is accepting reservations—please contact LELAP • Location and month to be determined

27. Questions?

28. Preparing for and Responding to Accreditation Audits & Recurring Findings of Accreditation Audits Paul Bergeron LELAP Supervisor LDEQ Laboratory, Baton Rouge, LA December 8, 2008

29. Common Findings • Failure to have correct and up-to-date standard operating procedures (SOPs) • Failure to document required information in Quality Assurance Manual (QAM)

30. Common Findings (cont) • Failure to demonstrate method proficiency by the analyst • Failure to establish quality control acceptance criteria

31. Common Findings (cont.) • Failure to notify the Department of modifications to methods • Failure to maintain training records

32. Common Findings (cont.) • Failure to conduct annual management reviews and internal audits • Improper error correction technique

33. Common Findings (cont.) • Failure to submit analytical data packages in lieu of proficiency test results when proficiency tests are not available • Failure to implement corrective action plan

34. Corrective Action Process Resolving findings and non-compliance the first time and eliminating recurring findings

35. Recurring Findings • Assessments are a snapshot of the laboratory operation--They are not intended to find everything • Recurring findings are a big problem • Accreditation Bodies (AB’s) do not take kindly to laboratories not taking comprehensive corrective actions • The Quality Systems (QS) approach to corrective actions requires that findings be addressed in all areas of the laboratory

36. Recurring Findings (cont.) • It is management’s responsibility to address each finding and make sure that it is not occurring in any other area of the laboratory. • Corrective action must address the problems in all areas and for all staff.

37. Recurring Findings (cont.) • Standard Operating Procedures (SOPs) are technically incorrect, do not follow the reference method, or are not implemented. • Lack of training of management and staff to • The 2003 NELAC standard • The Louisiana Administrative Code (LAC) • The laboratory quality system documentation

38. Recurring Findings (cont.) • Lack of documentation of • Training • Demonstrations of Capability • Corrective Actions • Internal Audits • Annual Reviews by Management • Lack of implementation of corrective action and occurrence of recurring findings.

39. Assessment Sequence • Quality System • SOPs and Methods • Review of 1) and 2) • Compliance

40. Quality System Tools • Include • Annual Management Review • Internal Audits • Proficiency Testing • Training • Corrective Action • Internal audits are one of the most important tools that management has to determine how the operation is functioning.

41. QS Tools (cont.) • Corrective actions are the best mechanism for • Continuous improvement • Assuring that you are not fixing the same problems time after time after time—re-inventing the wheel • Spotting trends and establishing a preventative action process • Maintaining accreditation requirements • Using the corrective action plan (format provided in assessment report) is mandatory—it is not optional

42. Corrective Action Process The problems with most corrective action processes are • only address the short term—the quick fix • these “solutions” don’t last (Recurring Findings) • process is not used for all corrections—lacks a comprehensive approach • only used by select management—not a “grass roots” program • does not address the root cause • all staff are not trained and encouraged to use the process • no follow through and monitoring

43. Closing Corrective Actions • Analyze—identify the root cause: people • Update the QS document • Train • Implement Corrective Action (CA) • Verify compliance

44. Symptoms vs. Root Cause Symptoms Root Cause Management and staff are not familiar with standards or regulations Analysts are not trained to QS documents • Facility has not performed proficiency tests • Non-compliant data set is missing data qualifiers

45. Root Cause Analysis Clearly define the non-conformance. Refer to the Standard. • Ask some questions… • Why did this occur? • How did this happen? • Has this occurred before? • Where did the previous solution fail? • Which of the foundation systems is affected? • Fix the symptom…or fix the problem? • Is the solution documented? • Is the change monitored?

46. Root Cause Analysis • Error corrections are not performed according to the quality manual and the NELAC Standard in the QA department, metals extractions and sample receiving. • Two of the four analysts in the volatile organics area do not follow the requirements of the SOP. The analysis does not match the test method requirements.

47. Corrective Action Plan Examples: Approved • The Finding: “Management has failed to implement processes/procedures for establishing that personnel are adequately trained or experienced in the duties they are expected to perform. The training program is not well-defined and has little structure. Training to perform test methods is inconsistent as a result. Training to perform a test method is dependent on the individual abilities, knowledge, and memory of the analyst providing the training without any program details. “

48. Corrective Action Plan Examples: Approved • The Finding (cont’d.) • Analysts are not qualified on the basis of education or experience or skill; • Management does not formulate goals with respect to education, experience, and skill; • There is no procedure for identification of training needs; • The laboratory fails to maintain adequate job descriptions for each laboratory position. • Records of relevant qualifications are not maintained;

49. Corrective Action Plan Examples: Approved • The Finding (cont’d.) • The Quality Manager: • is not knowledgeable in the quality system as defined under NELAC (5.4.1.5.i), • Does not have a general knowledge of the analytical test methods for which data review will need to be performed. The acting Quality Manager is familiar with inorganic methods, but not organic methods or microbiology methods, • does not have a knowledge of the LIMS audit trail, and • Does not have a knowledge of the LIMS sample processing que.

50. Corrective Action Plan Examples: Approved • The Finding (cont’d.) • The analysts responsible for performing Method 8310 have not been provided training in the operation and maintenance of HPLC, HPLC theory and principles, troubleshooting, or the use of the software, including the ability to perform manual integrations when the HPLC software improperly identifies a peak or improperly integrates a peak; • The new organic section manager has also not been trained in the software for organics analysis regarding the ability to manually integrate peaks when necessary; • Analysts have not been properly trained regarding the calibration and quantification of target analytes