Procedures for Detection and Quantitation

Environmental Group Perspectives on Detection/Quantitation Level issues - An Informal Survey

Robert Moore, Environmental Advocates of New York; Michael Murray, Ph.D., National Wildlife Federation; Richard Rediske, Ph.D., Grand Valley State University; Barry Sulkin, Environmental Consultant

Federal Advisory Committee on Detection and Quantitation Procedures

September 29-30, 2005

Approach

Written survey of environmental group representatives and others asked several questions, with general topics including:

Familiarity with general detection limit (DL)/ quantification limit (QL) issues
Whether DL/QL issues have arisen in their work, and if so how
Recommendations for environmental group representatives to bring to FACDQ
Identifying any other scientists and engineers who may have an interest in these issues

Results - Some Multiple Themes

14 respondents, majority at least somewhat familiar with issues, and approx. one-half have had DL/QL issues arise in their work
Current DL/QLs are not necessarily protective of the environment, in particular for persistent, bioaccumulative, toxic chemicals
Development and implementation of DLs and QLs need to be consistent with requirements of Clean Water Act
Current approaches to determining DLs and QLs are flawed, with varying abilities of labs to measure and report values near the DL or QL

Results - Additional Issues Identified by Respondents

Intersection of DL/QL issues with analytical/sampling method issues (e.g., total recoverable vs. dissolved metals; need to have approved methods for chemicals of emerging concern)
Situations where there are a limited number, if any, local analytical laboratories with capabilities for more sensitive measurements or methods, leading to avoidance of using such methods
Challenges in approaches to summarizing monitoring data (e.g., averages) when some values are not detected/quantified

Some Respondent Recommendations

Consider DL/QL issues in context of sampling/analytical issues
Although FACDQ focus is on DL/QL issues, several respondents emphasized analytical methods issues, including:
- Need for improving (or approving newer) analytical methods
- Improve/revisit methods on more timely basis (given cycles of triennial review of WQS, permitting, etc.)
Consider alternative approaches in some cases where monitoring close to DL/QL levels (e.g., biocriteria, whole effluent toxicity)

Some Respondent Recommendations - 2

On resources for DL/QL issues:
- Would be helpful to have federal funds to support method (including analytical) development
- Shifting more of burden to develop more sensitive methods to industry
Consider alternative approaches to regulation/compliance in cases where regulatory limits are below detection or quantification limits