The Future of ORELAP OELA Annual Workshop Michael Skeels, PhD, MPH
ORELAP Statutes (excerpts): “Accrediting authority” means the official accrediting authority for the Oregon environmental laboratory accreditation program comprised of the Director of Human Services or designee, the Director of the Department of Environmental Quality or designee and the Director of Agriculture or designee.
438.610 Standards for accreditation; rules. (1) The Department of Human Services, in concurrence with the accrediting authority, may adopt by rule standards for any laboratory seeking accreditation and performing environmental testing for a fee or for determining compliance with environmental statutes, rules or regulations. (2) In developing standards under subsection (1) of this section, the department shall cooperate with and may seek advice from the United States Environmental Protection Agency and any other state or federal agency that may have adopted rules or regulations for environmental monitoring.
(3) The standards adopted under this section may address testing and sampling procedures or methods, record keeping, disposal or retention of testing materials or samples, or any other practice related to work performed by an environmental laboratory. [1999 c.1063 §2] 438.615 Environmental laboratory accreditation program; rules. The Department of Human Services, in concurrence with the accrediting authority, shall establish by rule and implement an environmental laboratory accreditation program.The standards for accreditation may be equivalent to, but may not exceed, standards adopted by national accreditation programs. [1999 c.1063 §3]
ORELAP Work Group 2009 Purpose of ORELAP Characteristics of a Successful ORELAP Current Problems with ORELAP Solutions Next Steps Beth Meyers Bert Seierstad Bill Michalek John Neilson Keith Chapman Dave Leland Dan Hickman Irene Ronning Rita Youell Greg Pettit Mike Skeels
Purpose of ORELAP Improve quality of laboratory testing Improve the quality of information for policy & decision making Give consumer & the public protection, & confidence in test results so regulatory actions are appropriate & the public is protected.
Characteristics of a Successful ORELAP Private laboratories can be competitive for out-of-state business Encourage development of statewide lab capacity Create a level playing field for statewide lab quality Support EPA drinking water certification with primacy & future program mandates Beneficial to Oregonians Oregon labs can use or refer to out-of-state labs recognized by ORELAP to offer all services for testing
Characteristics of a Successful ORELAP Efficient, timely, responsive, simple & effective Comprehensive but flexible Mandatory compliance monitoring for permitting programs & official reporting programs Viewed as value added for the participating laboratories A functional & effective appeals process Consistent with national standards Money is well spent and program is cost effective for accrediting body, labs & consumers Offer training to labs
Current Problems with ORELAP Turn around Time (TAT) & responsiveness ORELAP does not follow its own timelines for audit response or corrective action response During the exit interview not all deficiencies are explained to the lab manager & staff so that they can start working on corrections Auditing consistency between survey years, laboratories & surveyors Fiscal sustainability Overly prescriptive standards and/or interpretation
Current Problems with ORELAP The first answer is usually “no” when alternate options are asked to be considered E-mails and phone calls are not always answered or returned An effective appeals process is needed; an interactive, mutually respectful interchange with no fear of retaliation. OTAC has a process for participating laboratories to bring technical & other issues for review but it is not very effective. Wrong mix of representation on OTAC.
Current Problems with ORELAP Process for applications, adding methods & generating fees is inefficient & cumbersome Unkept promises related to efficiencies & electronic application. Program has lost credibility with the participating labs Poor communication Program is very complex for the small lab ORELAP is not always consistent with EPA requirements
Solutions Look for system solutions Better communication between ORELAP & labs TAT from ORELAP; approval is automatic if state does not meet their deadlines Consequences for the state if they fail to meet deadlines The lab should not be penalized if state fails to meet deadlines Grant interim accreditation based on completed application & acceptable proficiency testing performance
Solutions • Improve role for OTAC with better representation from accredited labs Reduce cost of program by fewer individuals on survey & less time spent writing up findings Consider tiered accreditation Differences between EPA, ORELAP & NELAP need to be identified & shared Improve access to ORELAP staff Improve program management & oversight
Solutions Automate & streamline on-line application & other program functions Use alerts, out-reach & education to inform of changes in standards Independent appeals process Regular evaluation of the ORELAP QM process by participants
Financial Issues ORELAP Financial Update April 2009 July 1, 2007 – February 28, 2009 (20 months) Expenditures In-state labs $ 401,682 Out-of-state labs 161,495 TOTAL $ 563,177 Revenue ORELAP in-state fees $ 108,756 ORELAP out-of-state fees 243,933 Federal Drinking Water funds 180,054 TOTAL $ 532,743 Difference ($ 30,434)
Next Steps Create a balanced & sustainable budget Decrease expenses for on-site assessments Continue drinking water federal funding Increase fees for out-of-state labs Reduce personnel expenses through administrative efficiencies Eliminate DEQ subsidy of DW primacy
Next Steps Create dynamic website linked to database Improved service to labs Significant administrative streamlining Improve communications with labs Revamp and revitalize OTAC Better responsiveness and TAT More proactive communication with labs Improve management oversight & QA