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Spring 2017 News

New Analytes Available

In order to meet the needs of laboratories and data users, MNELAP added several new analytes to the list of available analytes for accreditation.  The department reviewed the list of  requested analytes and added Anthanthrene (CAS # 191-26-4), Available Cyanide, Benzo[c]fluorine (CAS# 205-12-9), Cyclopenta[c,d]pyrene (CAS# 27208-37-3), Dibenzo[a,l] pyrene (CAS# 191-30-0), 5-Methylchrysene (3697-24-3), 6-Nitrochrysene (CAS# 7496-02-8) and Residual Range Organics to the list previously published.

Requests to add fields of testing for new analytes in response to this notice of availability, do not require payment if the laboratory holds valid accreditation for the changed test category and applies for additional analytes within the same test category, and the lab applies no later than 180 days after the notice of availability is posted. Please see the official notice in the Minnesota State Register for additional information and details.

USBank Electronic Payment System and your Checking Account

The Environmental Laboratory Data Online (ELDO) system now accepts online electronic payments for laboratory accreditation fees. Electronic checks and savings account payment transfers do not incur a transaction fee.  Paying by electronic transfer is easy and convenient.  Please see the example below:

Example check with numbers needed for electronic payment. User enters the Bank Routing Number and Bank Account Number, then re-enter the Bank Account Number and the Bank Account type of checking or savings.

USBank does not charge convenience fees for checking or savings account transfers using this method of payment, but a convenience fee will be charged for debit/credit card payments. Convenience fees, if applicable to your payment type, will be clearly displayed on the screen for review and confirmation prior to submission of payment.

Calculator for Relative Standard Error Available from TNI

TNI has posted two documents to help labs calculate Relative Standard Error as required by the Chemical Testing Standard of the 2009 TNI Laboratory Accreditation Standard (V1M4, Section 1.7.1.1).  A document outlines the procedure and links to a companion Excel spreadsheet to simplify the calculation process.  TNI made this tool available to assist laboratories with meeting the requirements in this area of the TNI standard, use of this tool is not a TNI Standard requirement.

Winter 2017 News

Method Update Rule (MUR) 2016-Federal Activities

The Environmental Protection Agency (EPA) is proposing changes through the Method Update Rule (MUR). The 2016 MUR includes updates to methods approved for testing under the Clean Water Act (i.e. NPDES permits) and to the procedure for determining the Method Detection Limit (MDL).  The EPA is in the final stages of preparing and promulgating these changes to the regulations; however, the federal regulatory freeze has put the MUR on hold for now.

The MUR and all methods within are not effective until published in the Federal Register. The final rule becomes effective 30 days after publication.  After the MUR becomes effective, MNELAP will work with our state program partners to determine implementation dates for laboratories to gain accreditation for the newer versions of the methods, and to implement the revised MDL procedures.   In the meantime, please continue to follow the current promulgated Clean Water Program (40 CFR Part 136) Laws and Rules and seek out any needed information or training opportunities your laboratory may be interesting in obtaining about the MUR and its implementation in your laboratory.  The EPA maintains a webpage dedicated to the Method Update Rule-2016 and The NELAC Institute (TNI)  offers training materials on the proposed rule changes, approved methods and updated versions of methodology.

2016 TNI Standard Clarification- State Activities
Currently, the 2016 TNI Standard is available for sale on The NELAC Institute (TNI) website. The 2016 Standard is approved as an ANSI standard; however, the National Environmental Laboratory Accreditation Program (NELAP) States has NOT approved the 2016 TNI Standard for use. The 2016 TNI Standard, specifically the Chemistry Testing module (Volume 1 Module 4), is undergoing revision in order to meet the requirements of the NELAP States.  Once the NELAP States approve the revisions, the NELAP States will adopt 2017 TNI Standard.  Your laboratory can start preparing for any required changes found throughout the other module revisions, but MNELAP requires your laboratory to continue to follow the 2009 TNI Standards until officially announcing the 2017 TNI implementation dates and timelines.

Spring 2015 News

2015 Selection Committee Members

New selection committee members representing five of the seven constituencies have been appointed for 2015. Two constituencies, 1) professional organization with a demonstrated interest in environmental laboratory data and accreditation, and 2) a non-governmental client of environmental laboratories, are vacant. If interested in representing one of the vacant constituencies or know of someone you would like to recommend, please contact Lynn Boysen at lynn.boysen@state.mn.us.

MNELAP intends to conduct selection committee meetings quarterly to develop administrative procedures, revise application and forms if necessary, and review assessor and assessment body applications for approval by the commissioner. We intend to use web-conferencing to conduct these tasks. Committee appointments begin on January 1 and end on December 31 of the same year.

Proposed Clean Water Act Methods Update Rule

The United State Environmental Protection Agency (USEPA) proposes specific changes to analytical test procedures that are used by industries and municipalities to analyze the chemical, physical, and biological components of wastewater and other environmental samples that are required by regulations under the Clean Water Act.  The USEPA is proposing a methods update rule.  Please see the USEPA website for more information.

Methods Update Rule - 2015 Proposed

The Federal Register Notice, includes details of the proposed methods update rules and information on the commenting procedure.  Comments on this proposed rule must be received on or before April 20, 2015.

Federal Register Notice

The proposed rule will not impact the regulated community and laboratories using the approved methods for compliance until it has been finalized and published as a Final Rule Publication in the Federal Register.

Updated Fields of Proficiency Testing Tables

The NELAC Institute (TNI) released updated Fields of Proficiency Testing (FoPT) tables for the approved Non-Potable Water Chemistry and Microbiology analytes for proficiency testing.  Please review the updated tables for any changes that may affect your laboratory’s proficiency testing requirements. The new requirements go into effect on March 16, 2015.

TNI FoPT Tables

MNELAP Will Accept Applications for Third Party Assessors and Assessment Organizations Quarterly for 2015

MNELAP is now accepting applications from assessment organizations and individual assessors interested in performing environmental laboratory assessments for compliance with our state laws and rules, including the 2003 NELAC Standard and the 2009 TNI Standard. If you are interested in applying, please see the MNELAP Assessor Information page.

MNELAP Assessor Information

Invalidation of Total Coliform Samples

Invalidation of total coliform samples collected under 40CFR141 can happen in one of two ways depending on the analytical result.  If the result is total coliform present (TC+), the State must be the entity that invalidates the sample; under no circumstance is the public water supply and/or laboratory to invalidate a TC+ sample result.  If the result is total coliform absent (TC-), the laboratory is the entity with the authority to invalidate these results.

The first is in regards to TC+ sample results.  Under 40CFR141.21(c)(1), a State may invalidate a total coliform sample only if one of the following three circumstances is observed:

  1. Improper sample analysis
    1. The laboratory may reject the sample if the sample is received in a leaking/broken contain or hold time has been exceeded.  Once analysis has begun, the laboratory does not have the authority to invalidate a result.

    2. The State may invalidate a result if the laboratory qualifies the result in such a manner that shows that the laboratory erred.  Examples of when a result should be qualified are: if there is contamination of a negative-control sample, if a temperature range violation has been observed, or incubation time has been exceeded. The state will then determine if the result is invalidated or not.

  2. Results of repeat samples suggest the problem is associated with a domestic or non-distribution system-plumbing problem.

    1. The State may invalidate a sample if the repeat sample at the original positive sample is total coliform present (TC+) but all other repeat samples are total coliform absent as there is a reasonable probability that a domestic/plumbing system or non-distribution problem exists.  By no means is the State to invalidate a TC+ based on all repeat samples being TC absent (TC-).  In addition, if the distribution system consists of a single service connection, invalidating a TC+ sample as a plumbing system problem is prohibited.

  3. There are substantial grounds to believe that the result is due to a condition, which is not reflective of the water quality in the distribution system.

    1. The State may invalidate a sample if there is significant evidence that the sample was collected at a tap that was not representative of the distribution, the integrity of the sample was jeopardized, or other reasons that can be documented to show the sample is not representative of the distribution water quality.  The State must be able provide adequate documentation and rationale in writing as the decision must be technically justifiable and supported.

The second is in regards to total coliform absent (TC-) sample results.  Under 40CFR141.21(c)(2), a laboratory must invalidate a TC- sample result if one of the following two circumstances is observed:


If using analytical method SM9221A or SM9221B which depends upon the production of acid or gas from lactose to indicate the presence of total coliform and the result is turbid without acid or gas production.

  1. If using analytical method SM9222A, SM922B, or SM9222C (membrane filtration) and the resulting filter does not exhibit any TC+ colonies but is overgrown with non-coliform colonies.

Who is Responsible for What?


Minnesota Department of Health(MDH) Responsibilities

MDH will provide guidance for sample collection and sample results.  For systems less than 1,000 in population, the state will take the required repeat samples.

Public Water System (PWS)Responsibilities

If PWS is ≥ 1,000 in population, the PWS must collect samples ASAP and consecutive systems must notify the wholesaler about the positive if the wholesaler has a well.  The wholesaler is responsible for collecting samples from their wells.

Lab Responsibilities

Notify the PWS and MDH about the positive sample ASAP.  For sample procedures and rule requirements, refer the PWS to the designated state contact.

 

Important to Note


150 mL Bottles

It is recommended that bacteriological bottles be 150 mL in volume vs. 120 mL. When 120 mL bottles are filled passed the 100 mL mark, there is not enough headspace to do the analysis.  This requires another step to decant the sample into a larger container.  The 150 mL bottles offer a range from 100 mL to 120 mL to fill and will still meet the necessary headspace.

Lab-to-State

MDH is making an effort to make 100% of data submittals electronic. Training on how to use data submittal software will be offered in the future.

30 Hour Hold Time

The maximum holding time for bacteriological samples is 30 hours. Systems need to use a method of delivery that will ensure the samples arrive on time.  Sampling right before pick-up time is recommended.

Ground Water Rule

Groundwater Rule sampling requirements need to be followed. For every routine sample positive for total coliform or E. coli a sample must be taken from each well in use at the time of the positive. Sampling from each well in use in the past week is recommended.  If a system has more than one routine positive, only one sample from each well in use needs to be taken. If a system is a consecutive system, then the wells from the wholesaler must be sampled.

Total Coliform Rule

All routine samples positive for total coliform or E. coli need to be reported to the state ASAP.  All positives require repeat samples taken at the original positive site, at an upstream and downstream site within five service connections from the original site, and one taken at a random location that is representative of the system.

Upcoming Training

The 2015 Proposed EPA Method Update

NELAC Institute, in cooperation with Catalyst Information Resources and TestAmerica Laboratories, will provide webinars on the proposed Method Update Rule published by EPA on February 19, 2015. This proposed rule, that approves new methods or changes to existing methods, affects over 100 EPA methods, Standard Methods, ASTM methods, and other test procedures in 40 CFR Part 136.

The rule also contains a number of clarifications relating to approved methods, sample preservation and holding times, and method modifications. Among the more significant changes are updated versions of Methods 608, 624 and 625 and revisions to the MDL procedure in Part 136.

The first webinar, March 26, 2015 (Part 1: 2015 Proposed EPA Method Update Rule) will focus on the method changes.  The second webinar, April 8, 2015 (Part 2: Working with the New MDL Procedure) will be devoted to the proposed changes to the Method Detection Limit procedure.  This presentation will discuss the reasons for the changes and examine practical ways in which laboratories can efficiently comply with the new requirements.

Part 1: 2015 Proposed EPA Method Update Rule - Registration

Part 2: Working with the New MDL Procedure - Registration


Updated Friday, 05-May-2017 14:13:10 CDT