Is Your Laboratory EPA Certified?
This is one of the most commonly asked questions we receive from homeowners. The following information provides an explanation of the different types of certifications and the requirements needed to achieve certification. There are many forms of certification based upon the type of laboratory. For example, wastewater laboratories are certified to meet the Clean Water Act (CWA) requirements; whereas, drinking water laboratories are certified to meet the Safe Drinking Water Act (SDWA) requirements. In most cases, the EPA does not directly certify laboratories. They have assigned this responsibility to states that have primacy. In order for a state to have primacy, they need to prove to the EPA that they are capable of adopting or setting standards as well as enforcement of the standards. Wyoming and the District of Columbia are regulated directly by a Regional EPA office as they do not have primacy in their state/district. Another exception for the EPA directly approving laboratories includes certification under the Information Collection Requirements, because the EPA directly implements this rule. This includes the Unregulated Contaminant Monitoring Rule, which assists the EPA in determining what contaminants may be considered for monitoring based upon potential occurrence in water sources, available testing methods and technology available for removal or reduction of contaminants.
There are several options for obtaining certification: direct state certification, state reciprocity or NELAP (National Environmental Laboratory Accreditation Program), as well as other accreditations such as International Organization of Standardization commonly referred to as ISO.
The certification process typically requires a laboratory to submit an application directly to the state agency overseeing the certification program. A typical application includes legal name of the laboratory, location, personnel educational qualifications and experience, analytes/contaminants and methodology for which they are seeking certification, and their quality assurance plans. Direct certification means the lab will apply for certification directly from the state agency. Reciprocal certification is when a state will accept another state’s certification, which usually requires some type of application and exchange of paperwork. The drawback to reciprocal certification is the lab will only have certification for the analytes/contaminants covered by the original state’s certification, and some states regulate different contaminants. For example, some states will not certify for secondary contaminants that cause aesthetic issues, while some states do. This can be challenging for laboratories to manage.
NELAP was developed for laboratories looking for multiple state certification. It was meant to include all the states and US Territories, but currently only 14 states have accepted NELAP. Those states include California, Florida, Kansas, Illinois, Louisiana, Minnesota, New Jersey, New Hampshire, New York, Oregon, Pennsylvania, Utah, Texas and Virginia
In order to receive and maintain certification, laboratories must submit Performance Evaluation (PE) studies for the applicable analytes. The PE samples, which the laboratory must purchase from a state approved vendor, have a known concentration of the analyte. The laboratory must analyze and report the results to the state agency. The state has specified ranges for each analyte or method in which the laboratory’s reported results must fall into, in order to pass. Depending on the state’s requirements, the lab must pass one or more of these PE studies. Some states can have differing requirements for PE samples in terms of schedule and frequency, which can make it complicated when dealing with various state requirements. Many states require on-site auditing of the laboratory, where their auditors inspect and verify that the laboratory is following all applicable procedures. The state will determine how often the laboratory must be audited in order to maintain their certification.
Finally, the laboratory must pay all the applicable fees, which may include travel expenses for the on-site audits. Some states charge as much as $10,000 in fees, which can ultimately affect the price of testing services. A big advantage to reciprocal certification is the cost savings of additional on-site audits, since the state offering reciprocity will rely on the original state’s audit.
As you can see certification can get complicated. Our representatives understand the purpose of certification and can assist you with meeting your regulatory or legal requirements by ensuring we have the proper certification for your project. NTL is ISO 17025:2005 accredited and holds certifications across the country; visit our certification page for more information.