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Procedures for Detection and Quantitation
Policy Workgroup
Federal Advisory Committee on Detection and Quantitation Approaches and Uses in Clean Water Act (CWA) Programs
Summary of Policy Work Group Conference Call #5
December 19, 2005
1:00 – 2:05 p.m. EST
The Policy Work Group agreed to the following schedule of calls before the March FACDQ meeting, all of which will be on Mondays beginning at 1:00 PM EST:
- January 9, 2006
- January 23
- February 6
- February 27
- March 6
The call-in number for all calls is 1 866 299-3188. The participant code is 2025661045#.
- Welcome and Introductions
- Meeting Summary Review and Approval
- Policy Work Group Comments on the December 8-9 FACDQ Meeting
- Assignments
- Wrap-up and Closing
- Attendance
Welcome and Introductions
Facilitator Alice Shorett convened the conference call at 1:05 PM EST and called the roll of participants. She briefly reviewed the topics for the call: comments on the December 8-9 FACDQ meeting, a schedule for Policy Work Group calls leading up to the March FACDQ meeting, and assignments/responsibilities.
Meeting Summary Review and Approval
It was agreed that the draft summary of the November 21 Policy Work Group call would be sent out with the draft summary of the December 19 call and both would be reviewed on the January 9 call.
Policy Work Group Comments on the December 8-9 FACDQ Meeting
Ms. Shorett initiated a round robin of comments from Policy Work Group members on the December 8-9 FACDQ meeting.
- EPA: Mary Smith indicated that it had been a good meeting where a lot of issues had emerged. She said she sensed a tension between committee members who wanted to go more slowly and those who wanted to go faster.
- States: Dave Akers agreed that it had been a good meeting. He also agreed that issues had emerged as well as different ways the caucuses viewed them. He acknowledged that he was one of those who favored delaying a March meeting but he recognized that there were a lot of issues that needed to be discussed, to get a better sense of how to approach the policy issues, how to get the pilot study going, and how the policy and pilot study would work together.
Tom Mugan also noted that differences in perspective had emerged at the meeting and thought it had been productive, if also somewhat painful. He noted that while much had been made of the issue of uses, the advisory committee's main goal was to come up with one or more procedures, and it seemed that Committee members were struggling with how to proceed with a pilot and to develop an approach on how to use the results. He said he was glad the focus was on measurement quality objectives (MQOs), including α (false positives), β (false negatives), accuracy and precision to help the committee make decisions. - Utilities: Chris Hornback agreed that the meeting had been productive. He felt it had been useful to get the issues out on the table and to know where everyone was. In his opinion, measurement quality objectives (MQOs) and data quality objectives (DQOs), α, β, precision and accuracy were the next big things to accomplish. He indicated that the Utility group would be fine with the whole process, including proceeding with pilot testing, as long as the MQOs and DQOs -- which would differ based on different uses -- were sorted out so his group could evaluate them based on their objectives. He thought that this might be accomplished by having the Policy Work Group and the Technical Work Group work jointly in advance of the March meeting so the committee would be able to set a baseline for the pilots and agree on how to evaluate the results.
(Bob Wheeler commented that the Technical Work Group had had a call the previous week and it understood that it might be working with the Policy Work Group in a back-and-forth manner leading up to the March meeting.) - Environmental Labs: Cary Jackson said he thought the December meeting had been more productive than the first two. He said he was uncomfortable proceeding with the pilot study in March because he didn't think the interests had yet been fully captured and discussed. He felt that another meeting would be needed before beginning the pilot study. He said he also felt that some information presented at the meetings was not true or correct and it was hard to counter it in the space of the meeting.
Nan Thomey said her concerns related to taking the right questions into the pilot. She also noted that MQOs/DQOs were a very important part of the process and that they might have implications beyond the FACDQ. For example, she noted that ELAB had worked on the PBMS issue and information from the FACDQ MQOs/DQOs could be useful on the PBMS issue. - Environmental Community: Barry Sulkin said that he thought it was a sign the committee was making progress when everyone on the committee was unable to agree. He said he thought there were some uses the committee should avoid because the states and EPA would use them differently. He encouraged the committee to avoid being too prescriptive. With respect to deciding on the readiness to conduct the pilot study, he suggested that perhaps each caucus should have a discussion rather than asking the Policy Work Group to make that call.
Assignments
With respect to the Policy Work Group's workplan prior to the March FACDQ meeting, Ms. Shorett asked the Policy Work Group for suggestions of a reasonable goal for the next call (January 9), given the upcoming holidays.
During the discussions that followed, it was agreed that focusing on MQOs and DQOs made sense for the next call. The following assignments were agreed to:
- Noting that EPA has a number of programs that care about these issues, Mary Smith said that she would lay out current EPA practice for discussion on January 9. Because of holiday schedules at the agency, she said it was likely that she would send the draft report out shortly before the call.
- Larry LaFleur agreed to contact Jim Pletl for more information about Mr. Pletl's suggestion (on the Technical Work Group call of December 14) that the committee not limit itself to the four MQO/DQO parameters it had agreed to at the December meeting but that it also consider how "robust," representative and comparable procedures were.
- Triangle will send the revised framework from the December meeting to committee members before the January 9 call.
Suggestions and comments about Policy Work Group topics beyond January 9 and other issues included the following:
- Larry LaFleur recommended that the Policy Work Group pose precise questions to the Technical Work Group to make interactions between the two groups productive. He also recommended that the Policy Work Group review the narrative documents to determine the next logical set of issues to address.
- As a way to make progress on MQOs, Bob Wheeler suggested two options for the Policy Work Group to consider:
- asking the caucuses (other than industry which had stated its preferences at the December meeting) to identify what they wanted for MQOs and/or
- asking a subgroup to explain why the MQOs are important, to identify the range of options and their ramifications, and to show how the MQOs related to the existing procedures.
- Nan Thomey commented that the issue of accuracy and precision of MQOs was likely to get complicated because they depend on what's achievable for a given analyte and technology. The reality is, she said, that for many analytes and technologies, they aren't feasible. She also said that the environmental lab caucus would support defining MQOs if that would eliminate procedures that can't meet the committee's needs before it initiates a pilot study.
- Cary Jackson recalled that John Phillips had said his industry should be regulated on the basis of Lq because it is defensible whereas regulating below Lq is not. Mr. Jackson commented that developing an Lq that approaches the WQBEL, in other words, improving methods for certain analytes, was an approach that the committee hadn't yet discussed. If the WQBEL is less than Lq, he said that methods are needed to fix that problem. Barry Sulkin said he thought that situations where Lq was less than WQBELs were the reason the committee had been convened. He said the committee should not be afraid to set limits down to the WQBEL for Clean Water Act programs. He also said that, as far as he knew, no one was facing compliance fines for WQBELs so perhaps it was not as big a problem as was perceived.
Ms. Shorett asked Bob Wheeler to describe the difference between prescriptive and descriptive approaches. He responded that a prescriptive approach sets a number that every lab must meet so, in effect, it becomes a national standard. Mr. LaFleur added that some states like Florida and Wisconsin regulate at the lowest possible number any lab can achieve. A descriptive approach lets every lab do the best it can. For the pilot, Mr. Wheeler said, the committee had decided that both approaches needed to be tested. To help the committee's deliberations, it was suggested that it would be useful to look at specific examples and that they would become clear as the decision tree was fleshed out.
Wrap-up and Closing
The Policy Work Group agreed to a schedule of calls that is roughly bi-weekly, on Mondays, on the following dates: January 9, 23, February 6, 27, and March 6.
Policy Work Group members concluded the call by exchanging holiday greetings.
Attendance
- Policy Work Group Members
- States: Dave Akers and Tom Mugan
- Environmental Laboratories: Cary Jackson and Nan Thomey
- Environmental Community: Barry Sulkin
- Public Utilities: Chris Hornback
- Industry: Larry LaFleur
- US EPA: Mary T. Smith
- Triangle Associates
- Alice Shorett, Bob Wheeler, and Vicki King
- Observers
- Marion Kelly
- Meghan Hessenauer