The Value of Uniform Accreditation
A White Paper developed by the
Methods and Data Comparability Board
Federal, state, and tribal agencies, as well as the private sector, collect large amounts of environmental data under various statutory and regulatory requirements, much of which is shared with the public. Many laboratories provide data across the country using a variety of methods and a wide range of quality assurance and quality control procedures. The National Water Quality Monitoring Council, and its predecessor, the Interagency Task Force on Monitoring, recognized that poor or unknown data quality impedes our ability to use environmental information effectively. For example, unreliable data can raise uncertainties concerning wastewater or drinking water facility compliance with environmental regulations. Furthermore, the Clean Water Action Plan recognized that unknown data quality is a major factor limiting our ability to distinguish regional or national trends in water resources in the U.S. As a result, unknown and/or uncertain data quality affects our ability to make sound decisions, take appropriate remedial action, and protect human health and the environment.
Accurate, precise laboratory results are vital to ensure that sound information is being used for decision-making. There has been the notion that “following the method” (e.g., an EPA method for cyanide in water) ensures accurate data. A method is simply one key component of generating reliable data. The laboratory's personnel, calibration practices, quality assurance and quality control procedures, data review processes, and instrumentation are equally important. As an analogy, consider a recipe from a famous chef. In the hands of a skilled, experienced cook, using fresh ingredients and with all the right equipment, a wonderful outcome will result. The same recipe in the hands of an inexperienced cook on a chuck wagon, with only an iron skillet and an open fire, is a risky proposition. Both cooks, however, may be following the same “method”.
An objective assessment of laboratory competence, including personnel training and experience, is therefore an essential element for ensuring high quality data. A rigorous laboratory accreditation program has been identified as one tool to meet this goal. Laboratory accreditation is the independent assessment of a laboratory's technical competence and quality system. Many aspects of the laboratory, including its facilities, equipment, personnel, methodologies, and record-keeping systems, may be evaluated by an independent party during the accreditation process. The purpose of an independent accreditation is to ensure that adequate quality systems are in place, so that the laboratory meets established standards for competence. Accreditation of laboratories, using international standards, is an effective way of ensuring this competence in a comprehensive and uniform manner across all laboratories generating data.
There are presently more than 75 Federal and State environmental laboratory accreditation programs in the U.S., many of which, are not recognized by other State accreditation agencies. Unfortunately, most of these accreditation programs do not have identical requirements. In some cases, the requirements from different agencies may actually conflict with one another, thereby requiring the laboratory to perform a particular procedure several different ways in order to satisfy the requirements of each program.
Furthermore, at the present time, many states operate only a drinking water laboratory certification program. A laboratory performing other types of environmental work in the state may elect to obtain a drinking water certification even though the methodology actually used by the laboratory for a particular test may be completely different than that used for accrediting the laboratory. This form of accreditation can lead to a false sense of security concerning the quality of data generated by the laboratory in question.
Redundant, and sometimes conflicting, requirements pose a significant burden on laboratories and their customers, while providing very little, if any, improvement in data quality. Many federal and private environmental laboratories perform testing in multiple states. Such organizations have expressed concern that a high percentage of resources are required just to ensure compliance with these multiple accreditation programs. It is not unusual for a modest sized laboratory to incur costs of $75,000 - $100,000 per year for various accreditations. Such costs are usually passed on to the customer through higher charges for analytical services.
In addition, the lack of uniform, comprehensive laboratory accreditation standards in the U.S. results in potentially large disparities in the quality of data generated under different regulatory programs (e.g., safe Drinking Water Act, NPDES, RCRA) and within a single program. As a result, there may be a false sense of known comparability across laboratories. Rigorous, consistent laboratory accreditation standards are one important means to ensure that comparable data are available to resource agencies in evaluating the performance of environmental programs.
It is understood that uniform accreditation standards are one important means towards obtaining laboratory data of known and comparable quality. Other factors, such as the quality of sampling, are also necessary to ensure reliable environmental data. However, more comprehensive, uniform laboratory accreditation is likely to improve present quality assurance programs in the U.S., by going beyond current regulatory-based inspection programs. Such accreditation efforts are likely to eventually support the implementation of performance-based approaches to monitoring, thereby increasing flexibility in appropriate methods, while requiring specified data quality characteristics.