Superfund CLP Procedural Enhancements and Milestones
EPA's analytical services provide chemical analytical services as well as the development of electronic delivery of analytical data; the provision of flexible, analytical services that contain modifications from existing statements of work; and processes and applications that save both time and money. Examples of our role in advancing the processes of procurement, delivery, validation and payment of analytical services include:
EPA has been on the cutting edge of electronic data delivery for decades. When the Superfund law was passed in 1980, the EPA wanted to access the growing capacity of commercial laboratories to process trace level analytical services and data management. In the early 1980s, we created an electronic data deliverable (EDD) that mirrored every entry in a hardcopy deliverable (Format A) so laboratories that were beginning to use basic data systems and mainframes could submit and validate large amounts of data electronically instead of handwriting everything. Later in the 1980s, we created Format B, which used a delimiter format (information separated by commas). Most spreadsheet and statistical applications could use this format and thus was more readily available to more laboratories.
By the 1990s, personal computers were becoming more common in the workplace, and computing capacity was also improving. ASB again led the way toward a more robust, technologically advanced EDD. Working with other leading federal government agencies at the forefront of technological innovation, including the Department of Defense and the Department of Energy, we helped to develop a new “universal” EDD standard, referred to within the EPA as the Agency Standard and was the first to adopt it within the EPA. This new standard could manage large amounts of analytical data and could verify and validate data without the intensive labor requirements of translating the data into various formats.
By 2005, EPA partnered with the U.S. Army Corps of Engineers to expand on the EDD standard. They created the Staged Electronic Data Deliverable (SEDD), which standardized the superset of all data that might be required by environmental data users across all agencies and developed “stages” or formats that users could choose that met their individual data reporting and validation needs. SEDD allowed systems to automate much of the process and improved data quality while reducing the costs of reviewing data.
EPA knows how important flexibility is to its customers, and has worked consistently to provide this. Over two decades ago, our customers often requested changes to the statement of work (SOW) in order to complete their analytical services; we created the Flexible Analysis, or Flex Clause, allowing customers to modify their analytical parameters. The Flex Clause was so successful that we instituted formal modified analysis capabilities in the early 2000s.
A Modified Analysis (MA) is a request for analytical services that contains requirements that differ from the existing SOW. Customers may request MAs for all existing analytical services. Modified analyses that may be requested include, but are not limited to, adding additional compounds, adjusting Contract Required Quantitation Limits (CRQLs) for target analytes, and making minor adjustments to specific analytical protocols to enhance method performance. More than one third of CLP analyses use MAs and the most highly used MAs (such as the ones under the program-wide solicitation) have been considered and ultimately included in new SOWs. This recently happened with TCLP, SPLP, and 1-4, Dioxane by SVOA. There is also a Modified Analysis Database application available that allows customers to search the database based on a previously established MA number, or by various criteria including target compounds and CRQLs. The MA process has been so successful that at times, half the analyses performed have been MAs.
Business processes such as invoicing for laboratory analytical services are critical, and we have worked to ensure that information is readily available to customers and that the amount of paper used is reduced or eliminated. ASB identified an innovative approach to move from hard copy invoice processing to electronic processing to save time and money, and improve laboratory cash flow. In 1994, they developed and implemented a web-based electronic invoicing system, the first of its kind, which enables laboratories to generate, submit, and resubmit invoices via a secure web site. The Web-based Invoicing System (WIS) minimizes the need for resubmission by providing access to previously submitted analytical results, allowing laboratories to create invoices based on those results. Disallowed invoices were reduced by 85 percent, resulting in a savings of labor costs as well as the elimination of multiple copies assists in meeting the goals of the Government Paperwork Reduction Act and the elimination of mailing costs.