Member Column: So Much Accomplished in Four Years

Regulations

Coverage of new ELAP regulations supported by LabWorks, waterLIMS™

By Stephen Clark
Past-Chair, SWRCB ELTA Committee

After the Environmental Laboratory Accreditation Program (ELAP) was moved from the California Department of Public Health to the State Water Board, the Environmental Laboratory Technical Advisory Committee (ELTAC) was re-formulated.

Updated bylaws required ELTAC to be comprised of ELAP’s Program Officer and approximately 15 members comprised of voting representatives appointed to speak on behalf of groups that have interests in matters before ELTAC, including CWEA and the Lab Committee. In addition, there were non-voting State Regulatory Agency Employees (SRAEs) appointed to represent a state agency or department.

The newly comprised ELTAC had 14 representatives and four SRAE members. The first ‘new’ ELTAC meeting occurred in March 2016 and the final meeting for this appointed group occurred in August 2018. Over this period of time, 16 ELTAC meetings were held during which a wide variety of subjects and issues were addressed.

Maybe the most important issue addressed by ELTAC was to provide input on a laboratory accreditation standard/quality management system to be used by labs accredited by CA-ELAP, with options ranging from the creation of ELAP’s own State-specific standard, to modification and adoption of an existing standard, or adoption of an entire existing standard. Following much input and consideration, a majority vote of ELTAC supported a standard based on numerous modifications to the NELAC Institutes (TNI) 2016 standard.

ELAP also received input from their State Agency Partners (SAP) committee, who supported the use of the 2016 TNI standard but only with changes to the frequency of proficiency testing and the education requirement of laboratory technical directors.

CA-QMS

At a 2017 State Water Board meeting, ELAP presented the input from ELTAC and the SAP and recommended that the 2016 TNI with the two modifications supported by the SAP be applied in California and moved forward with developing regulations based on that plan.

However, California lab accreditation was discussed during a 2018 State Water Board meeting, where a number of members of the laboratory community voiced support for a laboratory accreditation framework that did not include a number of the administrative requirements in 2016 TNI.

One Board member indicated an interest in seeing such a standard presented to the State Water Board. Following that input, ELTAC approved the formation of a subcommittee to develop the framework for such a standard. After numerous subcommittee meetings and two ELTAC meetings, ELTAC voted 9-4-1 in support of the ‘California Quality Management System’ (CA-QMS), which is based on 2016 TNI but with a number of modifications, as the standard for labs accredited by CA ELAP.

At the time of drafting this article, a formal response to ELTAC’s vote has not been received from ELAP. ELAP management has previously indicated that they would only support the 2016 TNI standard with the two modifications. Given the differences between ELTAC and ELAP on this issue, I expect that it will be resolved by the State Water Board members.

ELTAC Moved the State Forward

Although the laboratory standard was a very important issue addressed at ELTAC, I think it is important to highlight a number of other activities.

• ELTAC developed a framework for State agencies to engage with ELTAC and ELAP when they need new analytical methods and/or lower reporting limits. Over the last 3+ years, there has been a significant increase in State agencies sharing their needs with ELTAC and positive outcomes through ELTAC workgroups.
• ELTAC provided valuable input on several draft versions of ELAP regulations, and we expect the release of the most recent version for public comment in the coming month(s).
• An ELTAC workgroup has provided input to ELAP on addressing problems encountered by the laboratory community with the fields of testing/fields of accreditation checklists.
• Another workgroup has been engaged with ELAP staff to improve the proficiency testing framework. And yet another workgroup provided input to ELAP on options for new fee structures. 

I was honored to be appointed to serve on ELTAC for nearly 4 years, and honored to serve with a tremendously dedicated group of representatives and SRAEs members. I hope that you will all be engaged as the new ELTAC is formed, as the laboratory community must continue to be involved in this process.

I also encourage CWEA to continue with their workshops and educational efforts on TNI 2016 Standard. They have been instrumental in educating laboratories about applying this system to laboratory management and operation.

For 30 years, Stephen Clark has been directing and participating in research and testing in the areas of aquatic ecotoxicology and environmental chemistry. He is Vice President for Pacific EcoRisk based in Fairfield.