Department of Defense BEST PRACTICES FOR DATA QUALITY OVERSIGHT OF ENVIRONMENTAL SAMPLING AND TESTING ACTIVITIES - IMPROVING POLICY, GUIDANCE, AND DOCUMENTATION

Extensive guidance developed both by DoD and other agencies is in widespread use throughout DoD'S environmental programs. As guidance is refined and updated, DoD issues policy and adapts the program to accommodate the updates. Best Practices include:

DEVELOP DoD POLICY AND GUIDANCE DOCUMENTS

Best Practice: DoD policy and guidance documents provide thorough and extensive program guidance. DoD updates these guidance documents as environmental programs develop to reflect new standards and innovative methods.

Implementation Status: Each DoD Component develops and maintains policy and guidance documents tailored to its individual needs to ensure effective and efficient compliance with environmental regulations. Examples of these documents include:

• U. S. Army Corps of Engineers EM 200- 1- 1, Validation of Analytical Chemistry Laboratories, 1 July 1994

• U. S. Army Corps of Engineers EM 200-l-6, Chemical Quality Assurance for HTRW Projects, 10 October 1997

• HQ Air Force Center for Environmental Excellence, Quality Assurance Project Plan Version 3.0, March 1998

• Chief of Naval Operations OPNAVINST 509O.lB CH- 1 of 25 August 1997, Chapter 25 "Sampling and Laboratory Testing," 2 February 1998

• Naval Sea Systems Command, Navy Environmental Compliance Sampling and Field Testing Procedures Manual, NAVSEA T0300-AZ-PRO-010, 10 June 1997 Navy Installation Restoration Laboratory Quality Assurance Guide, February 1996

Discussion: The DoD EDQW has established a library of information, policy, and guidance documents related to environmental sampling and testing. These documents are updated regularly to accommodate program changes and have the flexibility to accommodate new information. Policy and guidance documents are vital to execution because they direct the individuals who implement and carry out quality assurance programs within each of the components.

Recommendations: The EDQW should continue to update and/or develop policy and guidance. The process should include a review of all DoD environmental guidance documents to determine the best approach to developing documents for DoD-wide use. DoD-wide Sampling and Laboratory Quality Assurance Procedures Manuals should be a top priority.

IMPLEMENT ISO GUIDE 25

Best Practice: Adopt a policy to require personnel, equipment, and a quality system that meet IS0 Guide 25 General Requirements for the Competence of Calibration and Testing Laboratories for environmental testing activities; this policy will include field analysis.

Implementation Status: The DoD EDQW has recommended the adoption of IS0 Guide 25 as a uniform quality system standard for testing. A promulgation letter is currently in draft form and is being reviewed. In the interim, DoD component services are implementing IS0 Guide 25 for both laboratory and field testing on an individual basis. For example, the policy to implement IS0 25 was recently issued in Chief of Naval Operations Environmental and Natural Resources Program Manual, OPNAVINST 5090.lB CH-1 of 2 February 1998, Chapter 25, "Sampling and Laboratory Testing."

Discussion: A comprehensive consensus standard such as IS0 Guide 25 is useful as the basis for producing program policy, guidance, and sampling and analysis plans for environmental data gathering. IS0 Guide 25 sets general criteria to ensure the competence of testing laboratories (mobile and fixed). The criteria compliment the DQO process and provide uniform, minimum requirements for testing laboratories. Uniform requirements set a "level playing field" and facilitate compliance assessment activities. Use of IS0 Guide 25 for field testing activities also assures that important quality systems are in place for activities that are often considered the weakest link in the data collection process.

Recommendations: The EDQW should officially implement a policy to require that laboratories performing environmental testing for the DoD comply with IS0 Guide 25. The EDQW should develop an overarching quality system for all DoD environmental sampling and testing to unify existing component programs, and use this as a basic criterion for laboratory assessment. The quality system, method specific criteria, and related documents and checklists also provide a platform for a DoD-wide laboratory approval or accreditation program. Use of IS0 Guide 25 is also consistent with the quality system defined in the USEPA's National Environmental Laboratory Accreditation Program (NELAP).

IMPLEMENT ISO GUIDE 58

Best Practice: All DoD component and private environmental laboratories supporting DoD environmental restoration and compliance activities need credentials to perform testing. Accreditation programs should be based on an IS0 Guide 25 quality system, and operated and recognized per criteria in IS0 Guide 58, Calibration and Testing Laboratory Accreditation Systems, General Requirements for Operation and Recognition.

Implementation Status: DoD is moving from individual laboratory approval programs to broad-spectrum environmental laboratory accreditation programs conforming to IS0 Guides 25 and 58 Standards. DoD supports the development of a National Environmental Laboratory Accreditation Program (NELAP) to demonstrate laboratory competency and is considering becoming an Accreditation Authority for in-house laboratories under the NELAP.

Discussion: Accreditation programs should grant formal recognition of laboratories that have been assessed against the "general requirements" specified in IS0 Guide 25. The accreditation program should also address "specific requirements" in evaluating the scope of testing performed by the laboratory and accommodate both prescriptive and performance based QA approaches, including the EPA PBMS initiative. For DoD, the accreditation should document and attest to conformance of the laboratory quality system to all elements of IS0 Guide 25, as well as any DoD component-specific elements.

The scope of the laboratory assessments should include:

• Review of current/historical Proficiency Testing (PT) sample results

• Review of laboratory quality assurance plans and standard operating procedures

• Performance of on-site laboratory audits.

Use of IS0 Guides 25 and 58, for assessing laboratory competence and laboratory accreditation system comparability, will facilitate a level playing field for sharing assessment information. As a result, laboratory evaluations (laboratory audit reports, PT results, and other internal and external documented assessments) can be used by all components and should be available throughout the DoD user community.

Recommendations: Until a national program is developed and implemented, the EDQW is working to unify component programs to promote uniform standards of quality for laboratory assessment and approval/accreditation. The EDQW should continue to support development of the NELAP and consider becoming an Accreditation Authority under the National Environmental Laboratory Accreditation Conference (NELAC) which will oversee the NELAP. Component laboratory evaluation systems could supplement the NELAP system for use in accrediting laboratories and focus on overall DoD and project specific requirements.

IMPLEMENT ANSI/AS&C E4

Best Practice: Use ANSIIASQC E4- 1994, Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs as the basis for an over-arching system for quality management of environmental data collection and evaluation activities. Use related IS0 standards, such as IS0 25, 58, and IS0 9000 (international standards on quality management and quality assurance) and IS0 14000 (environmental management systems) series standards, as appropriate, for more specific or supplemental guidance.

Implementation Status: In the United States Environmental Protection Agency (EPA) Quality System Series, QA/G-0, EPA provided an overview of the policy and philosophy behind EPA's Quality System, the Quality System's components and their interrelationships. In QA/G-0, EPA noted the adoption of E-4 as the basis for EPA's Quality Manual. In a companion document, EPA QAIR-1, EPA Quality Systems Requirements for Environmental Programs, EPA noted that QAR-1 would be the external policy document by which EPA announces its implementation of E4. Currently, EPA is sponsoring an Intergovernmental Data Quality Task Force (IDQTF), under the direction of OSWER/FFRRO, to attain a set of mutually accepted systems requirements for the management of environmental data quality related to all environmental media, beginning with hazardous wastes. The IDQTF is using E-4 as a model for developing more specific system requirements. The DoD EDQW plans to recommend adoption of the E4 Standard to parallel EPA implementation.

Discussion: A consistent DoD quality system will provide the needed management and technical practices to assure that environmental data used to support decisions are of adequate quality and usability for their intended purpose. The DoD quality management system needs to describe policies, objectives, principles, organizational authority, responsibilities, accountability, and an implementation plan for ensuring an appropriate level of quality for environmental data collection and evaluation.

Recommendations: Based on the decision by EPA to implement E-4, this standard should be used as a guide for development of the DoD environmental data quality management plan. The EDQW should continue to participate in the IDQTF to define an agreement as to what constitutes an acceptable quality system. The EDQW has recommended that EPA include in the IDQTF other government agencies who are involved in environmental sampling and testing, in addition to DOE and DoD.

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