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Planning
It is the policy of NRMRL that systematic planning shall occur for all NRMRL
research products. Depending on the scope of research, as well as on any
contractual or Agency requirements, planning documents (including QAPPs)
appropriate to the scope are developed. The NRMRL DQA and Division QAMs
participate in NRMRL and Divisional planning meetings as directed by senior
management.
NRMRL has established minimum QAPP requirements for various research types
(see Appendix B). As described in Chapter 2, a graded approach is in place,
and is used for both intramural and extramural activities. The overall intent
is to allow flexibility, while still meeting NRMRL's interpretation of Agency
policy for QA.
Effective quality planning requires clear identification of project goals and
intended use of data. The EPA TLP for the project in consultation with project
participants, and division QA personnel as needed, determines the appropriate
QAPP requirements to be used.
The process for identifying the QA requirements for extramural projects was
described in Chapter 4 of this QMP. The Management Controls presented in Appendix A require the generation of a project tracking list by each branch
for all their TLPs and includes both intramural and extramural projects.
This tracking list is reviewed and updated every six months to ensure that
all projects are identified. This procedure helps to ensure that all projects
are identified and have appropriate documentation of their systematic planning
process. For intramural projects, the Quality Assurance Review Form
(Appendix D) is also used to document the QA requirements.
It is the NRMRL TLP's responsibility to identify and involve any and all appropriate
sponsoring organizations, responsible official(s), project personnel, stakeholders,
scientific experts, etc. (e.g., all customers and suppliers) in the planning of
the project. This is true for both intramural and extramural projects. Once
the planning is complete, project documentation should include (at a minimum)
a complete description of the following:
- the project's goals, objectives, questions, and issues to be addressed,
- the project's schedule, resources (including budget), milestones, and
any applicable requirements (e.g., regulatory requirements, contractual
requirements),
- the type of data needed and how the data will be used to support the
project's objectives,
- the quantity of data needed and the specification of performance
criteria for measuring data quality,
- how, when, and where the data will be obtained (including existing
data) and identification of any constraints on data collection,
- specifications of needed QA/QC activities to assess the quality
performance criteria (e.g., QC samples for both the field and laboratory,
audits, technical assessments, performance evaluations, etc.), and
- how the acquired samples will be analyzed (either in the field or the
laboratory), evaluated (i.e., QA review, validation, verification), and
assessed against the quality performance criteria and for its intended use.
Once all project planning is complete and documented, it is the NRMRL TLP's
responsibility to submit the QAPP to the designated QA Manager within each
Division. The QA manager performs a review against QAPP requirements and
issues documentation to indicate whether planning requirements have been met
and an assessment of whether project goals can be met. The documentation from
the QA manager shall include either an approval or a non approval. Approval
shall include concurrence by the TLP's Branch Chief as indicated by their
signature on the QAPP signature page or the document indicating approval by the
QAM. In the case of non approval, detailed review comments shall be provided
to the TLP. Resolution of all findings shall be accomplished and documented
before any research is started.
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