Joint Comments on Environmental Lab Accreditation

  • May 1, 2017
  • Comment Letters

Agency: State Water Resources Control Board

Subject: Association of California Water Agencies’ and California Municipal Utilities Association’s Comments regarding the Progress Assessment and Final Recommendations in the Year Two Final Report by the Expert Review Panel for the State Water Resources Control Board’s Environmental Laboratory Accreditation Program

Other signatories: California Municipal Utilities Association

Letter excerpt:

ACWA and CMUA refer to concerns raised by our joint comment letter dated September 16, 2016. ACWA and CMUA are concerned about the ERP’s recommendations to develop regulations based on The NELAC Institute’s (TNI’s) 2016 accreditation standards and to include third-party, private-sector assessor contracting as elements of ELAP. These recommendations do not directly address the core issue of ensuring ELAP’s effectiveness as a state program. The costs and complexity associated with implementation of a TNI-based standard would create a significant burden for small laboratories and jeopardize the ongoing viability of many smaller laboratories around the state. On the issue of third-party assessors, the ERP recommendation to allow laboratories to contract with third parties would raise those laboratories’ costs. These cost increases would occur in the wake of two ELAP fee increases that have been implemented in the past 18 months. ACWA and CMUA stand ready to assist State Water Board staff in addressing these concerns.

Ensuring that any new accreditation standard and regulations are workable will require the State Water Board to continue to engage with representatives from laboratories of all sizes. ACWA and CMUA believe that with continued leadership and effort on the part of State Water Board management and staff, ELAP will be able to fulfill the Program’s vital mission and mandate through the adoption of a laboratory accreditation standard and regulations that work for laboratories of all sizes.

Download joint comment letter

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