Technical_Exhibit_2.pdf

Department of Defense (DoD)

Department of Energy (DOE) Consolidated

Quality Systems Manual (QSM) for

Environmental Laboratories

Based on ISO/IEC 17025:2005(E) and

The NELAC Institute (TNI) Standards, Volume 1, (September 2009)

DoD Quality Systems Manual Version 5.1

DOE Quality Systems for Analytical Services Version 3.1

Environmental Laboratories

The NELAC Institute (TNI) Standard, Volume 1, (September 2009)

DoD Quality Systems Manual Version 5.1

Environmental Laboratories

Version 5. 1

COATS.KEVIN.H.1231359792

Kevin Coats

Army Principal

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Cornell Long Date

Air Force Principal

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Date: 2017.01.04 10: 12:22 -05'00'

Jordan Adelson , Ph.D. Date

Navy Principal, EDQW C hair

Quality Systems for Analytical Services

The NELAC Institute (TNI) Standards, Volume 1, (September 2009)

DOE Quality Systems for Analytical Services Version 3.1

Quality Systems for Analytical Services

(QSAS)

Version 3.1

DoD/DOE QSM 5.1

Page i

Preface The Department of Defense (DoD) Environmental Data Quality Workgroup (EDQW) and the Department of Energy (DOE) Consolidated Audit Program (DOECAP) Operations Team developed this manual called the DoD/DOE Quality Systems Manual (QSM) for Environmental Laboratories. The QSM provides baseline requirements for the establishment and management of quality systems for laboratories performing analytical testing services for the DoD and the

DOE.

This manual is based on Volume 1 of The National Environmental Laboratory Accreditation Conference (NELAC) Institute (TNI) Standards (September 2009), which incorporates International Organization for Standards (ISO)/International Electrotechnical Commission (IEC) 17025:2005(E), General requirements for the competence of testing and calibration laboratories. Conformance to the requirements contained in this manual is mandatory for any laboratory that is 1) seeking or maintaining accreditation in accordance with the DoD Environmental Laboratory Accreditation Program (ELAP) or 2) seeking or maintaining qualification in accordance with the DOECAP and DOE related contract awards. Laboratories that comply with the requirements of this manual must also comply with the TNI standards (September 2009) and ISO/IEC 17025:2005(E) unless specific provisions in those standards are superseded by this document. All references to the term “accreditation” in this manual refer to the DoD ELAP only.

To alleviate issues of copyright and provide a manual that is freely available to all, this manual is presented in a format which must be used in conjunction with the TNI and ISO/IEC 17025:2005(E) standards. DoD/DOE specific language is presented as text and appendices in the order in which topics are addressed in the TNI standards. DoD/DOE text contains additional requirements, clarifications, and guidance to supplement the TNI and ISO/IEC language.

Information that may be beneficial to a laboratory, but is not required, is marked as guidance.

To the extent possible, DoD and DOE requirements have been consolidated. Text or appendices that are unique to either DoD or DOE are marked as such.

The DoD/DOE QSM is international in scope and applies to all laboratories regardless of size or complexity. Nothing in this document relieves any laboratory from complying with more stringent contract specifications, host-nation final governing standards, or federal, state, tribal, and local regulations. Current accreditation to DoD QSM Version 5.0 is considered equivalent to accreditation to this manual. DoD ELAP Accreditation Bodies (AB) will accredit laboratories to this version of the standard during their normal accreditation cycles.

This manual was created in the spirit of cooperation between agencies for the purpose of consolidating and improving quality systems. The DoD and DOE expert committee members wish to thank the many volunteers that provided insight and guidance into the resolution of complex scientific issues that are now a part of this document. Moving forward, the goal of

Page ii continued data quality improvement will always be at the forefront of both the DoD EDQW and DOECAP team.

Page iii

Table of Contents

PREFACE ................................................................................................................................... I

VOLUME 1, MODULE 1: PROFICIENCY TESTING (PT)

1.0 INTRODUCTION

2.0 REQUIREMENTS FOR ACCREDITATION (Section 2: DoD Only)

2.1 Initial Accreditation

2.2 Continuing Accreditation

3.0 REQUIREMENTS FOR PARTICIPATION (Section 3: DOE Only)

3.1 Initial Inclusion

3.2 Continued Participation

VOLUME 1, MODULE 2: QUALITY SYSTEMS GENERAL REQUIREMENTS

1.0 INTRODUCTION, SCOPE, AND APPLICABILITY

1.1 Introduction

1.2 Scope DoD/DOE (Clarification)

2.0 NORMATIVE REFERENCES (ISO/IEC 17025:2005(E), Clause 2)

3.0 TERMS AND DEFINITIONS

3.1 Additional Terms and Definitions

3.2 Sources

3.3 Exclusions and Exceptions

4.0 MANAGEMENT REQUIREMENTS

4.1 Organization (ISO/IEC 17025:2005(E), Clause 4.1)

4.2 Management (ISO/IEC 17025:2005(E), Clause 4.2)

4.3 Document Control (ISO/IEC 17025/2005(E), Clause 4.3)

4.4 Review of Requests, Tenders and Contracts (ISO/IEC 17025/2005(E), Clause 4.4)

4.5 Subcontracting of Environmental Tests (ISO/IEC 17025/2005(E), Clause 4.5)

4.6 Purchasing Services and Supplies (ISO/IEC 17025/2005(E), Clause 4.6)

4.7 Service to the Client (ISO/IEC 17025/2005(E), Clause 4.7)

4.8 Complaints (ISO/IEC 17025/2005(E), Clause 4.8)

4.9 Control of Nonconforming Environmental Testing Work (ISO/IEC 17025/2005(E), Clause 4.9)

4.10 Improvement (ISO/IEC 17025/2005(E), Clause 4.10)

4.11 Corrective Action (ISO/IEC 17025/2005(E), Clause 4.11)

4.12 Preventive Action (ISO/IEC 17025/2005(E), Clause 4.12)

4.13 Control of Records (ISO/IEC 17025/2005(E), Clause 4.13)

4.14 Internal Audits (ISO/IEC 17025/2005(E), Clause 4.14)

4.15 Management Reviews (ISO/IEC 17025/2005(E), Clause 4.15)

4.16 Data Integrity Investigations (TNI Section 4.16)

5.0 TECHNICAL REQUIREMENTS

5.1 General (ISO/IEC 17025/2005(E), Clause 5.1)

5.2 Personnel (ISO/IEC 17025/2005(E), Clause 5.2)

5.3 Accommodation and Environmental Conditions (ISO/IEC 17025/2005(E), Clause 5.3)

5.4 Environmental Methods and Method Validation (ISO/IEC 17025/2005(E), Clause 5.4)

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5.5 Calibration Requirements (ISO/IEC17025:2005(E), Clause 5.5)

5.6 Measurement Traceability (ISO/IEC 17025:2005(E), Clause 5.6)

5.7 Collection of Samples (ISO/IEC 17025:2005(E), Clause 5.7)

5.8 Handling Samples and Test Items (ISO/IEC 17025:2005(E), Clause 5.8)

5.9 Quality Assurance (QA) of Environmental Testing (ISO/IEC 17025:2005(E), Clause 5.9)

5.10 Reporting the Results (ISO/IEC 17025:2005(E) Clause 5.10)

6.0 HAZARDOUS AND RADIOACTIVE MATERIALS MANAGEMENT AND HEALTH

AND SAFETY PRACTICES (Section 6: DOE Only)

6.1 Radioactive Materials Management and Control

6.2 Toxic Substances Control Act (TSCA) Material

6.3 Laboratory Safety and Health

6.4 Waste Management and Disposal

VOLUME 1 MODULE 3: QUALITY SYSTEMS FOR ASBESTOS TESTING

1.0 ASBESTOS TESTING

1.1 Introduction

1.2 Scope………………………………………………………………………………………… 55

1.3 Terms and Definitions

1.4 Method Selection

1.5 Method Validation

1.6 Demonstration of Capability (DOC)

1.7 Technical Requirements

VOLUME 1 MODULE 4: QUALITY SYSTEMS FOR CHEMICAL TESTING

1.0 CHEMICAL TESTING

1.1 Introduction

1.2 Scope………………………………………………………………………………………… 58

1.3 Terms and Definitions

1.4 Method Selection

1.5 Method Validation

1.6 Demonstration of Capability (DOC)

1.7 Technical Requirements

VOLUME 1, MODULE 5: QUALITY SYSTEMS FOR MICROBIOLOGICAL TESTING

VOLUME 1, MODULE 6: QUALITY SYSTEMS FOR RADIOCHEMICAL TESTING

1.0 RADIOCHEMICAL TESTING

1.1 Introduction

1.2 Scope………………………………………………………………………………………… 71

1.3 Terms and Definitions (DoD/DOE Clarification)

1.4 Method Selection

1.5 Method Validation

1.6 Demonstration of Capability (DOC)

1.7 Technical Requirements

1.8 Method Specific Directions DoD/DOE Requirements

VOLUME 1, MODULE 7: QUALITY SYSTEMS FOR TOXICITY TESTING

APPENDIX A: REPORTING REQUIREMENTS

1.0 COVER SHEET

2.0 TABLE OF CONTENTS

Page v

3.0 CASE NARRATIVE

4.0 ANALYTICAL RESULTS

5.0 SAMPLE MANAGEMENT RECORDS

6.0 QC INFORMATION

7.0 DATA REPORTS FOR THIRD PARTY REVIEW OR VALIDATION

APPENDIX B: QUALITY CONTROL REQUIREMENTS

Table B-1. Organic Analysis by Gas Chromatography (GC) Table B-2. Organic Analysis by High-Performance Liquid Chromatography (HPLC) .. 113 Table B-3. Nitroaromatics, Nitramines, and Nitrate Esters Analysis by HPLC, LC/MS, or LC/MS/MS (Method 8330B) ............................................ ……..119 Table B-4. Organic Analysis by Gas Chromatography/Mass Spectrometry

(GC/MS)

Table B-5. Dioxin/Furan Analysis by High-Resolution Gas Chromatography/Low-

Resolution Mass Spectrometry (Method 8280) Table B-6. Dioxin/Furan Analysis by High-Resolution Gas Chromatography/High-

Resolution Mass Spectrometry (Method 8290) Table B-7. Inorganic Analysis by Atomic Absorption Spectrophotometry (AA) Table B-8. Inorganic Analysis by Inductively Coupled Plasma Atomic Emission

Spectrometry (ICP/AES) Table B-9. Trace Metals Analysis by Inductively Coupled Plasma/Mass

Spectrometry (ICP/MS) Table B-10. Inorganic Analysis by Colorimetric Hexavalent Chromium Table B-11. Cyanide Analysis Table B-12. Common Anions Analysis by Ion Chromatography (IC) Table B-13. Perchlorate by Mass Spectrometry Methods Table B-14. Chemical Warfare Agents by GC/MS Table B-15. Per- and Polyfluoroalkyl Substances (PFAS) Using Liquid

Chromatography Tandem Mass Spectrometry (LC/MS/MS) With Isotope Dilution or Internal Standard Quantification in Matrices Other Than Drinking Water

Table B-16. Alpha Spectrometry Table B-17. Gamma Spectrometry Table B-18. Gas Flow Proportional Counting Table B-19. Liquid Scintillation Counter Analysis Table B-20. Radon Scintillation (Ra-226 by Lucas Cell) Table B-21. GC/MS Analysis of Air Samples Table B-22. Organic Semi-Volatile Analysis by GC/MS in SIM Mode Table B-23. Incremental Sampling Methodology (ISM) Soil Preparation for Large

Volume (1 kg or greater) Samples

APPENDIX C: LABORATORY CONTROL SAMPLE (LCS) CONTROL LIMITS AND

REQUIREMENTS…………………………………………………………………...272

1.0 INTRODUCTION

2.0 LCS LIMIT TABLES

Table C-1. Method 1668 Solid Matrix Table C-2. Method 1668 Water Matrix Table C-3. Method 6010 Solid Matrix Table C-4. Method 6010 Water Matrix Table C-5. Method 6020 Solid Matrix Table C-6. Method 6020 Water Matrix

Page vi

Table C-7. Method 6850 Solid Matrix Table C-8. Method 6850 Water Matrix Table C-9. Method 7196 Solid Matrix Table C-10. Method 7196 Water Matrix Table C-11. Method 7470 - 7471 Series Solid Matrix Table C-12. Method 7470 - 7471 Series Water Matrix Table C-13. Method 8015 (MOD) Solid Matrix Table C-14. Method 8015 (MOD) Water Matrix Table C-15. Method 8081 Solid Matrix Table C-16. Method 8081 Water Matrix Table C-17. Method 8082 Solid Matrix Table C-18. Method 8082 Water Matrix Table C-19. Method 8141 Solid Matrix Table C-20. Method 8141 Water Matrix Table C-21. Method 8151 Solid Matrix Table C-22. Method 8151 Water Matrix Table C-23. Method 8260 Solid Matrix Table C-24. Method 8260 Water Matrix Table C-25. Method 8270 Solid Matrix Table C-26. Method 8270 Water Matrix Table C-27. Method 8270 SIM Solid Matrix Table C-28. Method 8270 SIM Water Matrix Table C-29. Method 8290 Solid Matrix Table C-30. Method 8290 Water Matrix Table C-31. Method 8310 Solid Matrix Table C-32. Method 8310 Water Matrix Table C-33. Method 8321 Solid Matrix Table C-34. Method 8321 Water Matrix Table C-35. Method 8330 Solid Matrix Table C-36. Method 8330 - 8330B Series Water Matrix Table C-37. Method 8330B Solid Matrix Table C-38. Method 9010 - 9020 Series Solid Matrix Table C-39. Method 9010 - 9020 Series Water Matrix Table C-40. Method 9056 Solid Matrix Table C-41. Method 9056 Water Matrix Table C-42. Method RSK-175 Water Matrix Table C-43. Method TO-15 Gas Matrix

APPENDIX D: NON-DESTRUCTIVE ASSAY (NDA)

1.0 QUALITY ASSURANCE

1.1 NDA System Calibration

1.2 NDA Method Detection Limit

1.3 Infinite Thickness

1.4 NDA Measurement Uncertainty

1.5 NDA Measurement Traceability

1.6 NDA Measurement System Software

1.7 Acceptable Knowledge

1.8 NDA Data Reporting, Review, and Verification

1.9 NDA Measurement Performance Evaluation

2.0 NDA QUALITY CONTROL

2.1 QC Procedures

Page vii

2.2 NDA QC Requirements

3.0 QC ACTION LEVELS AND RESPONSE

Module 1

Volume 1, Module 1: Proficiency Testing (PT)

1.0 INTRODUCTION

This module provides baseline requirements for proficiency testing for laboratories performing analytical testing services for the Department of Defense (DoD) and the Department of Energy (DOE). This module supersedes the entirety of Volume 1, Module 1 of The NELAC Institute (TNI) standards (September 2009), which incorporates ISO/IEC 17025:2005(E).

2.0 REQUIREMENTS FOR ACCREDITATION (Section 2: DoD

Only)

2.1 Initial Accreditation

2.1.1 Initial Accreditation for DoD ELAP

To obtain initial accreditation for the Department of Defense Environmental Laboratory Accreditation Program (DoD ELAP), the laboratory shall analyze at least two Proficiency Testing (PT) samples for each combination of analyte-matrix-method (e.g., Trichloroethylene (TCE)-water-Method 624, TCE-water-Method 8260, TCE-soil-Method 8260, lead-soil-Method 6010, or lead-soil-Method 6020) that corresponds to its scope of accreditation. Laboratories that combine multiple methods into one Standard Operating Procedure (SOP) (e.g., SOP that combines Method 624 volatiles & Method 8260 volatiles) can report those methods with a single PT sample. All other analyte-matrix-method combinations require unique PT samples.

2.1.2 PT Samples for Initial Accreditation

The PT samples used for initial accreditation shall be obtained from PT providers that are accredited under International Organization for Standardization/International Electrotechnical Commission (ISO/IEC) 17043:2010(E) (General Requirements for Proficiency Testing) from an International Laboratory Accreditation Council (ILAC) approved signatory AB. Laboratories seeking DoD ELAP accreditation have the option to obtain PT samples from the Mixed Analyte Performance Evaluation Program (MAPEP). MAPEP is required for all laboratories that possess a radioactive materials license for analysis of radiological samples. MAPEP PT samples for analyte suites that do not contain radioactive materials can be accepted by laboratories without a radioactive materials license.

2.1.3 PT Samples not from ISO/IEC 17043:2010(E) Accredited PT Provider

When PT samples cannot be obtained from an ISO/IEC 17043:2010(E) accredited PT provider, the laboratory shall obtain permission to use non- ISO/IEC 17043:2010(E) PT providers from their AB prior to analyzing the PT sample. The requirements and criteria from the PT provider must be met by the laboratory for the PT sample to be considered successful.

2.1.4 PT Samples for Analyte-matrix-method not from PT Provider

When PT samples for an analyte-matrix-method combination cannot be obtained from any PT provider, and the analyte-matrix-method combination is required for a scope of accreditation, the laboratory shall submit this fact in writing to their DoD ELAP Accreditation Body (AB). Other measures (e.g., precision, bias, and selectivity) as outlined in the appropriate 2009 TNI Standard Test Modules must be performed to satisfy the PT requirement until those PT samples are available.

2.1.5 Analysis Date of PT Samples

The PT samples analyzed by the laboratory for initial DoD ELAP accreditation shall be no more than 12 months old. The analysis date between PT samples shall be at least 15 calendar days apart if two or more successive PT samples are performed. The 15 calendar day requirement does not apply to the MAPEP. Laboratories that participate in the MAPEP shall follow the MAPEP program requirements.

2.1.6 PT Study Determination

The success or failure of any analyte-matrix-method combination for a PT study shall be determined by the PT provider under the requirements of the governing regulatory or ISO/IEC 17043:2010(E) statistically derived program.

2.1.7 PT Samples Same as Regular Environmental Samples

PT samples must be evaluated in the same manner as regular environmental samples. A laboratory shall employ the same quality control, sequence of preparation and analytical steps, and replicates as used when analyzing routine samples.

2.2 Continuing Accreditation

2.2.1 Maintaining Accreditation

To maintain DoD ELAP accreditation, the laboratory shall successfully analyze at least two PT samples per calendar year for each analyte-matrix-method combination on their scope of accreditation. Each PT sample shall be analyzed approximately six months apart (any time frame from four to eight months apart is considered acceptable) if two PT samples are analyzed. A PT sample for Whole Effluent Toxicity (WET) testing is required at least once per year.

2.2.2 Laboratory PT History

The laboratory shall maintain a history of at least two (2) successful PT rounds out of the most recent three (3) attempts for each analyte-matrix-method combination on their scope of accreditation. If PT samples are required for corrective action to reestablish history of successful PT rounds, the analysis dates of successive corrective action PT samples shall be at least 15 calendar days apart. The 15 calendar day requirement does not apply to the MAPEP.

Laboratories that participate in the MAPEP shall follow the MAPEP requirements.

2.2.3 Failure to Meet Criteria

Analyte-matrix-method combinations that do not meet the above criteria must be removed from the DoD ELAP scope of accreditation.

3.0 REQUIREMENTS FOR PARTICIPATION (Section 3: DOE

Only)

3.1 Initial Inclusion

3.1.1 Initial Inclusion into the DOECAP Program

The laboratory shall demonstrate successful participation for a minimum of one year in an ISO/IEC 17043:2010(E) accredited PT program. The single blind studies must be related to regulatory or environmental programs, matrix types, or analytes for each of the analytical disciplines (i.e., inorganic, organic, radiochemistry) that each laboratory will perform in support of DOE field offices. A laboratory is only required to analyze samples containing analytes, and samples of matrices, applicable to data they report under DOE contracts.

3.1.2 PT Samples for Initial Inclusion

MAPEP is required for all laboratories that possess a radiological materials license and that perform inorganic, semi-volatile organic, or radiochemical analyses for DOE. Laboratories that perform volatile organic and wet chemistry analyses to DOE will be required to maintain proficiency in ISO/IEC 17043:2010(E) accredited PT program for all matrices that are included in the laboratory’s scope of work as defined in the subcontracts issued by DOE sites. A laboratory must possess a radioactive materials license from the Nuclear Regulatory Commission, an Agreement State, or a DOE exemption to receive MAPEP samples that contain radiological materials. However, MAPEP PT samples for organic analytes do not contain radioactive materials and can be accepted by laboratories without a radioactive materials license. Participation in MAPEP for laboratories that do not have a radioactive materials license is permitted at the request of the laboratory or as required by DOE subcontract requirements. In either case, the results submitted by the laboratories will be subject to the same evaluation criteria as used for laboratories that have a radiological materials license.

MAPEP samples are not provided for volatile organics or polychlorinated biphenyls (PCBs) in any matrix. The laboratories must obtain volatile and PCB PT samples from other ISO/IEC 17043:2010(E) accredited suppliers.

Other programs (such as Drinking Water) require program-specific PT samples. The following are required ISO/IEC 17043:2010(E) PT providers for these other programs:

- RadCheM™ PT Program, conducted by Environmental Resource Associates (or equivalent programs offered by other commercial suppliers if such suppliers become

ISO/IEC 17043:2010(E) accredited in the future), for radioactivity measurements in drinking water.

- NELAC Fields of Testing for CWA-Water (formerly known as WP). Under the terms of this manual, a laboratory may participate in two single blind, single concentration PT studies provided by an approved supplier. The PT suppliers must be approved by the Proficiency Testing Oversight Body/Proficiency Testing Provider Accreditor (PTOB/PTPA) administered by the NELAP.

- NELAC Fields of Testing for SDWA-Water (formerly known as WS). Under the terms of this manual, a laboratory must participate in two single blind, single concentration PT studies provided by an approved supplier. The PT suppliers must be approved by the PEOP/PEPA administered by the NELAP.

- AIHA Proficiency accreditation for Asbestos and Beryllium (if applicable).

Other Recommended Programs include:

- Discharge Monitoring Report-Quality Assurance (DMR-QA) program for NPDES analysis.

- NELAC Fields of Testing for RCRA Solid. Under the terms of this manual, a laboratory may participate in two single-blind, single-concentration Proficiency Evaluation (PE) studies provided by an approved supplier. The PE suppliers must be approved by the PTPA/PTOB administered by the NELAP.

3.2 Continued Participation

3.2.1 Maintaining Participation

The laboratory shall demonstrate continued proficiency throughout the term of the contract award. In addition, the client reserves the right to submit blind PT samples. Each laboratory shall continue to participate in all applicable rounds of external PT programs. The results of all PT programs will be utilized in the reports produced for DOE laboratory users. Therefore, DOE will provide the laboratories operating to this manual instruction for ensuring the results of commercial PT studies are made available to DOE and the sites that have contracts with the laboratories.

3.2.2 Failure to Meet Criteria

Reporting an unacceptable value, as calculated by the PT program, may result in a probationary period until the next reporting period for that analyte. Any applicable analyte for which individual laboratory results are entered as NR or “not reported” will not be considered an acceptable result. Any individual analyte failures must be corrected within the next PT program performance cycle period. If the laboratory fails two consecutive evaluations, the laboratory may not receive samples for analysis by the failed method until an acceptable PT score has been achieved. The decision to withhold sample shipments will be at the discretion of the individual DOE contract holder. The laboratory can demonstrate proficiency in remedial MAPEP PT studies by acceptable performance in an unscheduled evaluation by the same PT program or by participation in the next regularly scheduled MAPEP study.

For two or more consecutive failed (Not Acceptable) MAPEP results, the laboratory may not receive samples for analysis by the failed method until an acceptable remedial MAPEP PT sample score has been achieved. The decision to withhold sample shipments will be at the discretion of the individual DOE contract holder.

For all PT studies other than acceptable results, the following will be considered when evaluating the reported results:

1) Consistent bias, either positive or negative, at the “Warning” level (greater than +/- 20% bias) for a targeted analyte in a given sample matrix for the two most recent test sessions (e.g., Sr-90 in air filter 13 “+W” (+26%), Sr-90 in air filter test 14 “+W” (+28%));

2) Quality issues (flags other than “Acceptable”) that were not identified by the above for a targeted analyte in a given sample matrix over the last three test sessions (e.g., Am-241 in soil test 12 “-N” (-47%), Am-241 in soil test 13 “+W” (+24%), Am-241 in soil test 14 “- N” (-38%)); and

3) Any other performance indicator and/or historical trending that demonstrate an obvious quality concern (e.g., consistent “False Positive” results for Pu-238 in all tested matrices over the last three test sessions).

The laboratory shall document the cause(s) for failed PT results and develop corrective action(s) to address the cause(s) within 21 calendar days from receipt of the results. These actions should then be available for DOECAP review upon request. In the event of multiple failures that result in the issuance of a DOECAP Priority I finding, the laboratory shall identify the root cause of the failure using a sample from a previous MAPEP study or the laboratory can request that DOECAP contact the MAPEP PT provider to provide a sample from previous MAPEP studies. The previous study samples are to be used to aide in the determination of the root cause of the unacceptable result(s). The samples from a previous round of testing will not be scored by MAPEP.

Laboratories that receive unacceptable results for consecutive rounds of MAPEP testing shall notify the DOECAP Operations Team and all DOE contract holders within 15 business days from the receipt of the second unacceptable result.

For non-MAPEP proficiency testing, the laboratories shall follow the TNI guidelines and must maintain proficiency for two out of three rounds of proficiency testing. Laboratories that do not meet the requirements for non-MAPEP proficiency testing shall notify the DOECAP Operations Team and all contract holders within 15 business days from the receipt of the third unacceptable result. The use of quick turnaround and remedial samples will be acceptable, but the samples are included in the number of possible attempts at maintaining proficiency (i.e., receiving acceptable performance in two out of the last three rounds of proficiency testing reported).

Once a laboratory has demonstrated that they can achieve acceptable results, based on the previously determined limits of the test session, DOECAP will contact the MAPEP coordinator to provide one new remedial PT sample to the laboratory for analysis. The laboratory will provide the results of the remedial study to MAPEP and the results will be evaluated using the same evaluation criteria that are used for the normal MAPEP studies. If the results are acceptable, the Priority I finding can be evaluated for closure by DOECAP. If the results are not acceptable, the laboratory will be encouraged to continue resolution of any technical problems and will not be provided a second remedial PT sample. The requests for remedial PT samples will be made solely at the request of DOECAP and not from the participating laboratories.

Module 2

Volume 1, Module 2: Quality Systems General Requirements

1.0 INTRODUCTION, SCOPE, AND APPLICABILITY

1.1 Introduction

No additions or clarifications were made to this section. TNI and ISO/IEC 17025:2005(E) standards shall be followed.

1.2 Scope DoD/DOE (Clarification)

The following is a clarification of TNI section 1.2:

The Department of Defense (DoD) Environmental Data Quality Workgroup (EDQW) and the Department of Energy (DOE) Consolidated Audit Program (DOECAP) Operations Team developed the DoD/DOE Quality Systems Manual (QSM). This manual provides baseline requirements for the establishment and management of quality systems for laboratories performing analytical testing services for the DoD and the DOE. This manual is based on Volume 1 of The NELAC Institute (TNI) Standards (September 2009), which incorporates ISO/IEC 17025:2005(E), General requirements for the competence of testing and calibration laboratories. Conformance to the requirements contained in this manual is mandatory for any laboratory that is 1) seeking or maintaining accreditation in accordance with the DoD Environmental Laboratory Accreditation Program (ELAP) or 2) seeking or maintaining qualification in accordance with the DOECAP and DOE related contract awards for analytical services and industrial hygiene testing. Laboratories that comply with the requirements of this manual must also comply with the TNI standards (September 2009) and ISO/IEC 17025:2005(E) unless superseded by this document. All references to the term “accreditation” in this manual refer to the DoD ELAP only.

This manual is presented in a format which is designed for use in conjunction with the TNI (September 2009) and ISO/IEC 17025:2005(E) standards. DoD/DOE specific language is presented as text and appendices in the order in which topics are addressed in the TNI standards. DoD/DOE text contains additional requirements, clarifications, and guidance to supplement the TNI and ISO/IEC language. Information that may be beneficial to a laboratory, but is not required, is marked as guidance. To the extent possible, DoD and DOE requirements have been consolidated. Text or appendices that are unique to either DoD or DOE are marked as such.

The DoD/DOE QSM is international in scope and applies to all laboratories regardless of size or complexity. Nothing in this document relieves any laboratory from complying with more stringent contract specifications, host-nation final governing standards, or federal, state, tribal, and local regulations.

To ensure that laboratories are capable of generating data that will meet project-specific requirements, the EDQW and the DOECAP Operations Team strongly encourages the involvement of project chemists and laboratories during project-planning activities.

DOE Only (Clarification): Laboratories must follow the requirements of DOE Order 414.1B, C, or D as part of the laboratory contract.

2.0 NORMATIVE REFERENCES (ISO/IEC 17025:2005(E),

Clause 2)

3.0 TERMS AND DEFINITIONS

3.1 Additional Terms and Definitions

The following are DoD/DOE clarifications and additions to TNI section 3.1:

Accreditation (DoD Only Clarification): Refers to accreditation in accordance with the DoD

ELAP.

Accreditation Body (AB) (DoD Only Clarification): Entities recognized in accordance with the DoD ELAP that are required to operate in accordance with ISO/IEC 17011, Conformity assessment: General requirements for accreditation bodies accrediting conformity assessment bodies. The AB must be a signatory, in good standing, to the International Laboratory Accreditation Cooperation (ILAC) mutual recognition arrangement (MRA) that verifies, by evaluation and peer assessment, that its signatory members are in full compliance with ISO/IEC 17011 and that its accredited laboratories comply with ISO/IEC 17025.

Aliquot: A discrete, measured, representative portion of a sample taken for analysis.

Analytical Method: A formal process that identifies and quantifies the chemical components of interest (target analytes) in a sample.

Analysis: A combination of sample preparation and instrument determination.

Analyte: The specific chemicals or components for which a sample is analyzed; it may be a group of chemicals that belong to the same chemical family and are analyzed together.

Assessment (Clarification): Assessment is an all-inclusive term used to denote any of the following: audit, performance evaluation, peer review, inspection, or surveillance conducted on-site.

Blank (Clarification): Blank samples are negative control samples, which typically include field blank samples (e.g., Trip Blank, Equipment (rinsate) Blank, and Temperature Blank) and laboratory blank samples (e.g., Method Blank, Reagent Blank, Instrument Blank, Calibration Blank, and Storage Blank).

Calibration Range: The range of values (concentrations) between the lowest and highest calibration standards of a multi-level calibration curve. For metals analysis with a single-point calibration, the low-level calibration check standard and the high standard establish the linear calibration range, which lies within the linear dynamic range.

Confirmation (Clarification): Includes verification of the identity and quantity of the analyte being measured by another means (e.g., by another determinative method, technology, or column). Additional cleanup procedures alone are not considered confirmation techniques.

Consensus Standard: A standard established by a group representing a cross-section of a particular industry or trade, or a part thereof.

Continuing Calibration Verification: The verification of the initial calibration. Required prior to sample analysis and at periodic intervals. Continuing calibration verification applies to both external standard and internal standard calibration techniques, as well as to linear and non-linear calibration models.

Correction: Action taken to eliminate a detected non-conformity.

Corrective Action: The action taken to eliminate the causes of an existing nonconformity, defect, or other undesirable situation in order to prevent recurrence. A root cause analysis may not be necessary in all cases.

Customer: Any individual or organization for which products or services are furnished or work performed in response to defined requirements and expectations.

Definitive Data: Analytical data of known quantity and quality. The levels of data quality on precision and bias meet the requirements for the decision to be made. Data that is suitable for final decision-making.

Demonstration of Capability (Clarification): A procedure to establish the ability of the analyst to generate analytical results by a specific method that meet measurement quality objectives (e.g., for precision and bias).

Detection Limit (DL): The smallest analyte concentration that can be demonstrated to be different from zero or a blank concentration with 99% confidence. At the DL, the false positive rate (Type I error) is 1%. A DL may be used as the lowest concentration for reliably reporting a detection of a specific analyte in a specific matrix with a specific method with 99% confidence.

Deuterated Monitoring Compounds (DMCs): SIM specific surrogates as specified for GC/MS SIM analysis.

Digestion: A process in which a sample is treated (usually in conjunction with heat and acid) to convert the target analytes in a sample to a more easily measured form.

Documents: Written components of the laboratory management system (e.g., policies, procedures, and instructions).

Environmental Data: Any measurements or information that describe environmental processes, locations, or conditions; ecological or health effects and consequences; or the performance of environmental technology.

Extracted Internal Standard Analyte: Isotopically labeled analogs of analytes of interest added to all standards, blanks and samples analyzed. Added to samples and batch QC samples prior to the first step of sample extraction and to standards and instrument blanks prior to analysis. Used for isotope dilution methods.

False Negative: A result that fails to identify (detect) an analyte or reporting an analyte to be present at or below a level of interest when the analyte is actually above the level of interest.

False Positive: A result that erroneously identifies (detects) an analyte or reporting an analyte to be present above a level of interest when the analyte is actually present at or below the level of interest.

Finding (Clarification): An assessment conclusion that identifies a condition having a significant effect on an item or activity. An assessment finding may be positive, negative, or neutral and is normally accompanied by specific examples of the observed condition. The finding must be linked to a specific requirement (e.g., this standard, ISO requirements, analytical methods, contract specifications, or laboratory management systems requirements).

Holding Times (Clarification): The maximum time that may elapse from the time of sampling to the time of preparation or analysis, or from preparation to analysis, as appropriate.

Improper Actions: Intentional or unintentional deviations from contract-specified or method-specified analytical practices that have not been authorized by the customer (i.e., DoD or DOE).

Incremental Sampling Method (ISM): Soil preparation for large volume (1 kg or greater) samples.

Initial Calibration Verification (ICV): Verifies the initial calibration with a standard obtained or prepared from a source independent of the source of the initial calibration standards to avoid potential bias of the initial calibration.

Injection Internal Standard Analyte: Isotopically labeled analogs of analytes of interest (or similar in physiochemical properties to the target analytes but with a distinct response) to be quantitated. Added to all blanks, standards, samples and batch QC after extraction and prior to analysis.

Internal Standard: A known amount of standard added to a test portion of a sample as a reference for evaluating and controlling the precision and bias of the applied analytical method.

Laboratory Information Management Systems (LIMS): The entirety of an electronic data system (including hardware and software) that collects, analyzes, stores, and archives electronic records and documents.

Limits of Detection (LOD) (Clarification): The smallest concentration of a substance that must be present in a sample in order to be detected at the DL with 99% confidence. At the LOD, the false negative rate (Type II error) is 1%. A LOD may be used as the lowest concentration for reliably reporting a non-detect of a specific analyte in a specific matrix with a specific method at 99% confidence.

Limits of Quantitation (LOQ) (Clarification): The smallest concentration that produces a quantitative result with known and recorded precision and bias. For DoD/DOE projects, the LOQ shall be set at or above the concentration of the lowest initial calibration standard and within the calibration range.

Linear Dynamic Range (LDR): Concentration range where the instrument provides a linear response.

Measurement Performance Criteria (MPC): Criteria that may be general (such as completion of all tests) or specific (such as QC method acceptance limits) that are used by a project to judge whether a laboratory can perform a specified activity to the defined criteria.

Measurement System (Clarification): A test method, as implemented at a particular laboratory, and which includes the equipment used to perform the sample preparation and test and the operator(s).

Measurement Uncertainty: An estimate of the error in a measurement often stated as a range of values that contain the true value within a certain confidence level. The uncertainty generally includes many components which may be evaluated from experimental standard deviations based on repeated observations or by standard deviations evaluated from assumed probability distributions based on experience or other information. For DoD/DOE, a laboratory’s Analytical Uncertainty (such as use of LCS control limits) can be reported as the minimum uncertainty.

Operator Aid: A technical posting (such as poster, operating manual, or notepad) that assists workers in performing routine tasks. All operator aids must be controlled documents (i.e., a part of the laboratory management system).

Preservation (Clarification): Any conditions under which a sample must be kept in order to maintain chemical, physical, and/or biological integrity prior to analysis.

Qualitative Analysis: Analysis designed to identify the components of a substance or mixture.

Quality System Matrix (Clarification): The matrix definitions in the TNI standard shall be used for purposes of batch and quality control requirements and may be different from a field of accreditation matrix.

Quantitation Range: The range of values (concentrations) in a calibration curve between the LOQ and the highest successfully analyzed initial calibration standard used to relate instrument response to analyte concentration. The quantitation range (adjusted for initial sample volume/weight, concentration/dilution and final volume) lies within the calibration range.

Quantitative Analysis: Analysis designed to determine the amounts or proportions of the components of a substance.

Records: The output of implementing and following management system documents (e.g., test data in electronic or hand-written forms, files, and logbooks).

Reporting Limit: A customer-specified lowest concentration value that meets project requirements for quantitative data with known precision and bias for a specific analyte in a specific matrix.

Selected Ion Monitoring (SIM): Using GC-MS, characteristic ions specific to target compounds are detected and used to quantify in applications where the normal full scan mass spectrometry results in excessive noise.

Signal to Noise Ratio (S/N): S/N is a measure of signal strength relative to background noise.

The average strength of the noise of most measurements is constant and independent of the magnitude of the signal. Thus, as the quantity being measured (producing the signal) decreases in magnitude, S/N decreases and the effect of noise on the relative error of a measurement increases.

Storage Blank: A sample of analyte-free media prepared by the laboratory and retained in the sample storage area of the laboratory. A Storage Blank is used to record contamination attributable to sample storage at the laboratory.

Surrogate: A substance with properties that mimic the analyte of interest. It is unlikely to be found in environmental samples and is added to them for quality control purposes.

Target Analytes: Analytes or chemicals of primary concern identified by the customer on a project-specific basis.

Test Method: A definitive procedure that determines one or more characteristics of a given substance or product.

Unethical Actions: Deliberate falsification of analytical or quality control results where failed method or contractual requirements are made to appear acceptable.

Validation: The confirmation by examination and provision of objective evidence that the particular requirements for a specific intended use are fulfilled.

3.2 Sources

3.3 Exclusions and Exceptions

4.0 MANAGEMENT REQUIREMENTS

4.1 Organization (ISO/IEC 17025:2005(E), Clause 4.1)

4.1.5 DoD/DOE Requirement

The following shall be implemented in addition to ISO Clause 4.1.5 j):

j) At a minimum, the following laboratory management staff (however named) shall be considered key managerial personnel:

i) Management (e.g., President, Chief Executive Officer, Chief Operating Officer, Laboratory Director);

ii) Technical Managers (e.g., Technical Director, Section Supervisors);

iii) Quality Managers;

iv) Support Systems and Administrative Managers (e.g., Laboratory Information

Management System (LIMS) manager, purchasing manager, project managers); and

v) Customer Services Managers.

4.1.7.1 DoD/DOE Requirement

The following shall be implemented in addition to TNI sections 4.1.7.1 a) through h):

i) implement, maintain, and improve the management system by using available tools such as audit and surveillance results, control charts, proficiency testing results, data analysis, corrective and preventive actions, customer feedback, and management reviews in efforts to monitor trends.

4.2 Management (ISO/IEC 17025:2005(E), Clause 4.2)

4.2.1 DoD/DOE Requirement

The following shall be implemented in addition to ISO Clause 4.2.1:

Copies of all management system documentation provided to DoD ELAP ABs, DOECAP Operations Teams, or to personnel on behalf of DoD/DOE shall be in English.

4.2.3 DoD/DOE Requirement

The following shall be implemented in addition to ISO Clause 4.2.3:

Top management shall be responsible for:

a) defining the minimum qualifications, experience, and skills necessary for all positions in the laboratory;

b) ensuring that all laboratory technical staff have demonstrated capability in the activities for which they are responsible. Such demonstration shall be recorded;

c) ensuring that the training of each member of the technical staff is kept up-to-date (on-going) by the following:

i) each employee training file must contain a certification that the employee has read, understands, and is using the latest version of the management system records relating to his/her job responsibilities;

ii) training courses or workshops on specific equipment, analytical techniques, or laboratory procedures shall all be recorded; and

iii) review of analyst work by relevant technical managers on an on-going basis is recorded or another annual demonstration of capability is performed by one of the following:

a. acceptable performance of a blind sample (single or double blind to the analyst);

b. at least four consecutive laboratory control samples with acceptable levels of precision and bias. The laboratory must determine the acceptable levels of precision and bias prior to analysis; or

c. if the above cannot be performed, analysis of authentic samples with results statistically indistinguishable from those obtained by another trained analyst.

d) recording all analytical and operational activities of the laboratory;

e) ensuring adequate supervision of all personnel employed by the laboratory;

f) ensuring that all sample acceptance criteria are verified and that samples are logged into the sample tracking system and properly labeled and stored; and

g) recording the quality of all data reported by the laboratory.

4.2.8.1 DoD/DOE Requirement

The following shall be implemented in addition to TNI sections 4.2.8.1 a) and b):

c) The laboratory shall have a documented program to detect and deter improper or unethical actions. Data shall be produced according to the project-specific requirements as specified in the final, approved project-planning documents, such as the approved Quality Assurance Project Plan (QAPP), when these documents are provided to the laboratory. Following are the minimum elements of an acceptable program for detecting and deterring improper or unethical actions:

i) an ethics policy must be read and signed by all personnel;

ii) initial and annual ethics training must be conducted as described in Section 5.2.7;

iii) analysts must record an explanation and sign off on all manual changes to data; and

iv) where available in the instrument software, all electronic tracking and audit functions must be enabled.

4.2.8.2 DoD/DOE Requirement

The following shall be implemented in addition to TNI section 4.2.8.2:

The quality manager shall review (or oversee the review of) the quality manual at least annually and update it if needed.

4.2.8.4 DoD/DOE Requirement

The following shall be implemented in addition to TNI sections 4.2.8.4 a) through r):

s) procedures for procurement of standards;

t) procedures for data management including validation, verification, and purging of electronic data and data systems;

u) procedures for manual entry of raw data from analytical measurements that are not interfaced to LIMS and the verification and records of the accuracy of manually entered data;

v) procedures for making changes to electronic data (including establishing the requirements for a hardcopy or electronic log to record all changes to electronic data that affect data quality);

w) procedures for how electronic data are processed, maintained, and reported;

x) procedures for ensuring that data review includes all quality-related steps in the analytical process, including sample preparation, dilution calculations, chromatography evaluation, and spectral interpretations. The SOP shall require that records of data review be maintained and available for external review;

y) a list of all current certifications and accreditations that the laboratory holds and the scope of certification or accreditation (with expiration date) for each;

z) health and safety (e.g., Chemical Hygiene Plan) (DOE Only Requirement); and

aa) materials (Waste) management; (DOE Only Requirement).

4.2.8.4 DoD/DOE Requirement

The following shall be implemented in addition to TNI section 4.2.8.4 p):

p) The procedures for audits and data reviews shall specify which records must be included in the review. Internal data reviews shall consist of a tiered or sequential system of verification, consisting of at least three tiers, 100% review by the analyst, 100% verification review by a technically qualified supervisor or data review specialist, and a final administrative review.

The analyst and verification review must include at least the following procedures:

i) determination of whether the results meet the laboratory-specific quality control criteria;

ii) checks to determine consistency with project-specific measurement performance criteria (MPCs) if available;

iii) checks to ensure that the appropriate sample preparatory and analytical SOPs and methods were followed and that chain of custody and holding time requirements were met;

iv) checks to ensure that all calibration and quality control requirements were met; and

v) checks for complete and accurate explanations of anomalous results, corrections, and the use of data qualifiers in the Case Narrative.

The final administrative review shall verify that previous reviews were recorded properly and that the data package is complete.

In addition, the quality manager or designee shall review a minimum of 10% of all data packages for technical completeness and accuracy on a quarterly basis. This review is considered a part of overall data review and does not need to be completed before the data package is issued to the customer. If data quality issues are discovered during the review, the client shall be notified within 15 business days of the discovery of the issue.

If electronic audit trail functions are available, they must be in use at all times, and associated data must be accessible. If the instrument does not have an audit trail, the laboratory must have procedures to record the integrity of the data.

4.2.8.5 DoD/DOE Requirement

The following shall be implemented in addition to TNI sections 4.2.8.5 a) through f):

g) All technical SOPs (e.g., sample preparation, analytical procedures, sample storage, or sample receipt) shall be reviewed for accuracy and adequacy at least annually and updated if necessary. All such reviews shall be conducted by personnel having the pertinent background, recorded, and made available for assessment.

h) The laboratory shall develop, maintain, and implement…