Joint Comments on Preliminary Draft Regulations for Environmental Lab Accreditation Sep 7, 2017 Comment Letters Agency: State Water Resources Control Board Subject: Environmental Laboratory Accreditation Program Preliminary Draft Regulations Comments Other signatories: California Municipal Utilities Association Letter excerpt: Policy-Based Comments 1. ACWA and CMUA continue to oppose the incorporation of The NELAC Institute’s (“TNI”) requirements because the requirements will not ensure high-quality data and results. In the preliminary draft regulations, ELAP staff has chosen to incorporate the 2016 TNI Standard, Volume 1 requirements into the state’s accrediting program. These requirements largely pertain to record keeping and reporting procedures by laboratories. They do not advance improved performance by laboratories or a more robust and effective accreditation program. As stated in the joint ACWA-CMUA comment letters dated September 16, 2016 and May 1, 2017, we continue to oppose this incorporation because the costs and complexity associated with implementation of a TNI-based accreditation program would create substantial burdens for small laboratories and jeopardize the ongoing viability of many smaller laboratories around the state. Many parties echoed these significant concerns regarding the cost of compliance during the State Water Board’s ELAP Workshop on May 3, 2017. Many laboratories, particularly those owned and operated by small public utilities, operate on a non-profit basis with little or no marginal fiscal buffer. The costs associated with complying with TNI requirements in the short- and long-term could be overwhelming, posing a real risk of laboratory closures, especially for laboratories serving disadvantaged communities. High-quality drinking water laboratory data and results are vitally important to the protection of public health and the environment. We believe that it is essential that ELAP be able to ensure that laboratories are providing public health officials and other data users with high-quality results to enable informed decision-making. The incorporation of TNI-based requirements will not advance this goal. Download joint comment letter
