Procedures for Detection and Quantitation
Policy Workgroup
Federal Advisory Committee on Detection and Quantitation Approaches and Uses in Clean Water Act (CWA) Programs
- Action Items
- Welcome and Introductions
- Discussion of Recommendations on Measurement Quality Objectives
- Meeting Summary Review and Approval
- Updates on Outstanding Assignments
- Wrap Up and Adjourn
- Attendance
Summary of Policy Work Group Conference Call #21
November 01, 2006
1:00 – 3:00 p.m. EST
Calls will be held from 1:00 to 3:00 PM, Eastern Time, on the following dates: November 9, 15, 17 and 29, 2006.
The call in number is 1-866-299-3188, and the access code is 202-566-1000#.
Action Items
A subgroup on data quality objectives (DQOs) (Mary Smith/Brian Englert, John Phillips, Jim Pletl) was tasked with reviewing an initial list of fundamental questions related to DQOs and developing a product for the PWG to develop a recommendation around this issue. Michael Murray, Dave Akers, Tom Mugan and Nan Thomey all offered to review a draft product before sending to the PWG, but said their availability to participate in the development of a product was limited.
Triangle will:
- Work with Michael Murray to incorporate the discussion of the Great Lakes Initiative into a revised draft of the October 26 meeting summary.
- Send the final version of the straw proposal related to the use of 303(d) listings to the State and Environmental Community caucus representatives.
- Develop an initial list of fundamental questions for the DQO subgroup to address in developing a product for the PWG to send to the committee for its December meeting.
- Establish a dialogue between David Kimbrough and Richard Burrows to frame the issue of on-going verification for the PWG.
Welcome and Introductions
Facilitator Alice Shorett convened the conference call at 1:00 PM ET and called the roll of participants. She briefly reviewed the agenda with participants, saying she wanted to get right into the discussion of measurements quality objectives (MQOs). She suggested holding the discussion of the draft summary from the October 26 meeting until the end of the meeting.
Discussion of Recommendations on Measurement Quality Objectives
Alice Shorett said that Mary Smith had the opportunity to connect with Jim Pletl on the issue of setting MQOs. Mary Smith said that she wanted to hear Mr. Pletl's perspective on setting MQOs in light of the sample spreadsheets EPA assembled reflecting results for a couple of existing analytical methods.
Jim Pletl said that since he was one of the earliest proponents in the process of establishing MQOs he wanted to spend a few minutes describing his point of view. He hoped that he could clarify his belief of how the PWG and committee should proceed on the issue.
Ideally, the committee will develop recommendations around an acceptable precision and accuracy for the quantitation limit (QL) and an acceptable false positive and false negative rate for the detection limit (DL). In a broader context, he hoped the committee could develop recommendations that EPA could put into guidance on a level of error that is acceptable to make a decision for a given analytical method. If that acceptable level of error is not met, an analyst in a lab could mitigate - through MQOs, uncertainty, analytical processes or some other measure - that level of error for decision-making. For example, to adjust for uncertainty from the perspective of sampling (i.e. sample size), a permittee could reduce uncertainty by collecting more samples or using more data.
Mr. Pletl said this was just a suggestion to illustrate his main point, which is to focus the committee more globally on the issue of setting some data quality objectives around analytical methods. He said he was not originally advocating that the committee should seek consensus on numbers for specific MQOs.
The PWG discussed for a moment Mr. Pletl's vision for addressing the issue of MQOs. Initially, there was some confusion of how committee recommendations on the subject could translate into EPA guidance if the committee did not agree to specific numbers. Mr. Pletl suggested that his approach does not prohibit the committee from seeking consensus on numbers. However, the fundamental issue that first needs to be addressed is to say that limits need to be established with accuracy and precision taken into account, not that we just need better precision and accuracy.
Nan Thomey used the example, to illuminate Mr. Pletl's thinking, of a lab that reports a number with its associated accuracy. However, many times that number is treated as though it is 100% accurate, which is almost never the case. Guidance from the committee may simply be text that says bias has to be taken into account in the decision-making process, and may even go as far as systematically relating decision-making to levels of accuracy or bias.
The group generally agreed with the suggested approach. Instead of spending time trying to reach consensus around specific numbers for the four MQOs, the committee's time will be better spent trying to address the issue more holistically, from a data quality objective perspective. MQOs then become a subset of this larger issue.
The group spent some time trying to identify some of the fundamental questions that might be addressed by the committee. They came up with the following list.
- What DQOs are applicable to the different identified uses?
- What are the goals for method performance?
- How do we account for uncertainty in methods (e.g. sampling, testing)?
- Does bias have to be taken into consideration in the decision process?
- Can representative data be defined? What about a robust reasonable potential process?
- Should error rates be considered for different uses?
- What is an acceptable level of decision error, taking into account MQO's and uncertainty?
- If data do not meet specified accuracy, how should they be used (Should data be ignored or should the uncertainty be factored in?)?
- How do we account for MQO's in reference matrices and in real world matrices?
- If matrix effects have a huge percent range, then do we recommend matrix specific spikes?
- If MQOs are set, how do you verify that those MQOs are achieved?
- If MQOs are set, what should be done with those numbers?
A subgroup was then assigned the task of sifting through this initial list and developing a product for the PWG to send to the committee for its December meeting. The subgroup consists of Mary Smith and Brian Englert, John Phillips and Jim Pletl. Tom Mugan, Nan Thomey, Michael Murray and Dave Akers also volunteered to review the product before it is sent to the PWG, but said they would have very little time to participate in the preceding discussion and development of the product. Alice Shorett said Triangle would pull together the initial list of fundamental questions and circulate that to the subgroup to get it started.
Meeting Summary Review and Approval
Ms. Shorett asked for comments to the draft summary from the October 26 PWG meeting. Chris Hornback made a few suggestions for minor revisions that were accepted by the group.
Michael Murray asked to add some language to the summary about the discussion of the Great Lakes Initiative that took place at the end of the last meeting.
Ms. Shorett said Triangle would revise the summary. Given that the group would need to see the revisions again before approving the draft summary, she suggested the group review two summaries (from 10/26 and from this meeting) at the November 9 meeting. The group agreed to that approach.
Updates on Outstanding Assignments
Ms. Shorett reviewed with the group the outstanding assignments. She identified the following:
- An update from Mary Smith regarding the transition to ICIS, the new EPA compliance database. Ms. Smith said she had gathered information about ICIS in a recent meeting with representatives from the Office of Enforcement and Compliance Assurance. She pledged to write a summary of the information she gathered, but quickly shared that ICIS overall has more capacity for text than did PCS. ICIS, like PCS, has two fields for reporting data - one field is numeric and the other coded (e.g. values less than the DL, between DL and QL, or DNQ). Both fields cannot be used at the same time. ICIS does have substantially more character capacity in these fields, including up to 4000 characters for the "open field." The schedule is to have ICIS fully implemented by 2009; it is currently operational in 21 states, 9 territories and 2 tribal lands.
- An update from Cary Jackson on developing language around note #1 in the "merged hybrid" document regarding the alternative test procedures (ATP) program. Mr. Jackson said the Environmental Lab caucus was working on two products to address this request. He said the note would have some recommendations on how to make the ATP process more efficient. He also said he was going to produce a separate background document on the existing ATP process for the committee's edification in making a decision around this topic.
- An update from David Kimbrough on framing the issue for the committee of on-going verification. Bob Wheeler, facilitator, said that Richard Burrows - an Environmental Lab caucus member and participant in the Technical Work Group - would work with Mr. Kimbrough on framing this issue for the PWG. Mr. Wheeler said that Triangle would work to get a dialogue going between the two.
- A request to re-examine the discussion in uses of 303(d) listings and ambient water monitoring. Barry Sulkin briefly reported on a conversation he had with a regulator from Rhode Island. Tom Mugan said he also spoke with the individual. The issue was that the committee agreed in July not to address the use of 303(d) listings, but it was unclear whether in doing so the committee also dismissed the idea of ambient water monitoring. Mr. Sulkin said that would not have been his intention and that he would like to bring the topic back into the discussion of uses, but outside of the topic of 303(d) listings.
Wrap Up and Adjourn
Alice Shorett briefly summarized the meeting and said the next meeting is scheduled for Thursday, November 9 from 1:00 - 3:00 PM, ET. She also suggested adding an additional meeting to the schedule to finalize details before the December committee meeting. The group agreed to add a conference call on Friday, November 17 from 2:00 - 4:00 PM, ET.
Ms. Shorett reviewed the schedule of remaining calls with the group. She said it was important to come to each meeting prepared to move forward in an effort to develop products that could be distributed to the committee well before the December meeting. Ms. Shorett thanked all for their participation and concluded the call at 2:55 PM (ET).
Attendance
- Policy Work Group Members
- States: Dave Akers and Tom Mugan
- Environmental Laboratories: Nan Thomey and Cary Jackson
- Environmental Community: Michael Murray and Barry Sulkin
- Public Utilities: Chris Hornback and David Kimbrough
- Industry: John Phillips (alternate)
- US EPA: Mary T. Smith
- Triangle Associates
- Alice Shorett, Bob Wheeler and Derek Van Marter
- Observers
- Brian Englert, EPA Office of Water
- Jim Pletl, Public Utilities Caucus member
![[logo] US EPA](http://www.epa.gov/epafiles/images/logo_epaseal.gif)