PWS Ref (e) Office of Assistant Secretary of Defense Memo_01May2024.pdf
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This is a Department of Defense memorandum issued by the Assistant Secretary of Defense for Energy, Installations, and Environment on May 1, 2024, establishing standardized requirements for analysis of Per- and Polyfluoroalkyl Substances (PFAS) in environmental matrices other than drinking water. The memorandum supersedes the August 7, 2023 guidance and applies to the Assistant Secretary of the Army, Assistant Secretary of the Navy, Assistant Secretary of the Air Force, the National Guard Bureau, and the Defense Logistics Agency.
DoD Components must use U.S. Environmental Protection Agency (EPA) Method 1633 (Analysis of Per- and Polyfluoroalkyl Substances in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS) for definitive PFAS analysis, with all versions of the method deemed acceptable by the DoD Environmental Data Quality Workgroup. Project-specific analyte lists shall include all PFAS identified in EPA Method 1633 unless the project's conceptual site model eliminates a substance as a contaminant of concern; additional PFAS may be added as necessary. All PFAS analysis must be conducted by laboratories accredited through the DoD Environmental Laboratory Accreditation Program (ELAP), with accredited laboratory listings available at www.denix.osd.mil/edqw/accreditation/accreditedlabs. Alternative screening methods may be used to determine presence or magnitude of PFAS concentrations but not to confirm absence; such methods require approval from a DoD project representative and cannot be used for regulatory compliance, risk assessment, or comparison to screening or action levels. Project planning documents developed after the memorandum's signature date should incorporate quality control measures and acceptance criteria from the final version of EPA Method 1633 and Table B-24 of the DoD/DOE Quality Systems Manual for Environmental Laboratories Version 6.0. The point of contact is Mr. Brian Jordan at 703-409-8657 or brian.d.jordan6.civ@mail.mil.
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ASSISTANT SECRETARY OF DEFENSE
3400 DEFENSE PENTAGON
WASHINGTON, DC 20301-3400
May 1, 2024ENERGY, INSTALLATIONS, AND ENVIRONMENT
MEMORANDUM FOR ASSISTANT SECRETARY OF THE ARMY (INSTALLATIONS,
ENERGY AND ENVIRONMENT)
ASSISTANT SECRETARY OF THE NAVY (ENERGY,
INSTALLATIONS AND ENVIRONMENT)
ASSISTANT SECRETARY OF THE AIR FORCE
(INSTALLATIONS, ENVIRONMENT AND ENERGY)
DIRECTOR, NATIONAL GUARD BUREAU (JOINT STAFF, J8)
DIRECTOR, DEFENSE LOGISTICS AGENCY (INSTALLATION
MANAGEMENT)
SUBJECT: Establishing a Consistent Methodology for the Analysis of Per- and Polyfluoroalkyl Substances in Matrices Other than Drinking Water
This policy identifies requirements for sampling of Per- and Polyfluoroalkyl Substances (PFAS) in environmental matrices other than drinking water. This memorandum supersedes and cancels the Assistant Secretary of Defense for Sustainment memorandum, Update for Establishing a Consistent Methodology for the Analysis of Per- and Polyfluoroalkyl Substances in Media Other than Drinking Water, August 7, 2023.
For definitive analysis of PFAS in matrices other than drinking water, the DoD Components will use U.S. Environmental Protection Agency (EPA) Method 1633, Analysis of Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS.1 The DoD Environmental Data Quality Workgroup (EDQW) has determined that all versions of EPA Method 1633 (i.e., draft and final versions) meet the precision, accuracy, and limits of quantitation needed to support definitive decision-making.
Project-specific analyte lists shall include all PFAS in EPA Method 1633, unless the project conceptual site model eliminates a PFAS as a contaminant of concern. Additional PFAS may be added to the analyte list as necessary.2 DoD Components will only use a laboratory accredited by the DoD Environmental Laboratory Accreditation Program (ELAP) for all PFAS analyzed in each matrix. Laboratories capable of meeting the DoD ELAP requirements applicable to EPA Method 1633 can be found at www.denix.osd.mil/edqw/accreditation/accreditedlabs, under “Draft EPA Method 1633” or “EPA 1633” in the Method dropdown box.
1 The DoD Components may still use a method compliant with Table B-15 of the DoD/DOE Quality Systems Manual for Environmental Laboratories for definitive analysis of PFAS in matrices other than drinking water if required by contracts awarded before January 2022.
2 The laboratory must validate performance, and establish quality control criteria for any additional PFAS, as required by DoD ELAP. This information must be documented in the laboratory’s procedure.
www.denix.osd.mil/edqw/accreditation/accreditedlabs dkluzik Cleared
Other methods for analysis may be considered for screening samples to determine the presence or magnitude of PFAS concentration, but not to confirm absence. The use of alternative screening methods for a location must be approved by a project representative from the DoD (e.g., chemist). Methods other than EPA Method 1633 shall not be used to analyze samples for regulatory compliance, risk assessment, or comparison to a project screening or action level.
Although laboratory accreditation under the DoD ELAP is not required for a screening method, it is highly recommended that an accredited laboratory is used to help ensure a minimum level of quality assurance and quality control.
Project planning documents developed after the signature date of this memorandum should incorporate the quality control measures and acceptance criteria from the final version of EPA Method 1633 and the requirements of Table B-24 of the DoD/DOE Quality Systems Manual for Environmental Laboratories (QSM) Version 6.0, regardless of the version of the method on the laboratory’s scope of accreditation. Projects may include additional quality control measures and/or stricter acceptance criteria as needed to meet project data quality objectives.
The point of contact for this matter is Mr. Brian Jordan at 703-409-8657 or brian.d.jordan6.civ@mail.mil.
Sincerely, Digitally signed byOWENS.BRE OWENS.BRENDAN.M.1
NDAN.M.1030 030451844
Date: 2024.05.01451844 13:16:40 -04'00'
Brendan M. Owens https://2024.05.01 mailto:brian.d.jordan6.civ@mail.mil
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