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ELAP Asks for Overdue Update to the State Accreditation System

An official notice has been released by the State Water Resources Control Board (State Water Board) proposing to amend, adopt, or repeal the Environmental Laboratory Accreditation Program (ELAP) regulations described in a formal Notice of Proposed Rulemaking released on October 11th, 2019.

The State Water Board considered two alternative accreditation standards to incorporate into the proposed ELAP regulations that were proposed and developed by three ELTAC members and five public participants. The first was a state-created accreditation standard and the second, a modified version of an existing accreditation standard. After reviewing the content of each, the State Water Board has found that, "the alternative accreditation standard developed by a Subcommittee of ELTAC lacked the necessary quality system requirements to ensure that data produced by laboratories was of known and documented quality." The State Water Board’s reasoning for rejecting these alternatives were, "that they a less effective than the 2016 TNI Standard in carrying out the purpose and objectives for which the action is proposed, represent the status quo, and lack credibility."

While this alternative was proposed at previous State Water Board meetings in full detail, "the alternative standard proposed by the ELTAC Subcommittee, which has not been reviewed or considered by the Environmental Protection Agency (EPA) as an alternative to the federal laboratory certification program [...] and is not comparable to the TNI Standard in effectiveness and acceptability by stakeholders."

Based on the results found by the Economic Impact Assessment, "the State Water Board estimates the cost to implement the proposed regulations for a typical laboratory ranges from $40,000.00 to $77,334.40."

The State Water Board will hold an Administrative Procedure Act (APA) public hearing during a Board workshop on Wednesday, December 18, 2019 – 9:30 a.m. to receive all written and oral comments regarding the proposed regulations. The hearing will include a presentation by State Water Board staff on the proposed regulations and a 3 minute session for public comments, unless additional time is approved by the board. The purpose of this hearing is for the public to provide comments in accordance with the APA, however, the State Water Board will take no formal action.

Any interested individual or authorized representative, may submit written comment that is relevant to the proposed regulatory action to the Clerk of the State Water Board by mail or email , which can be found the Notice of Proposed Rulemaking. All written comments pertaining to these regulations must be submitted and received by the Clerk to the State Water Board no later than 12:00 noon on Friday, December 20, 2019. Comments received after the deadline will not be considered timely. Please see notice for additional details on public comments.

After hearing and public comments have been made, the State Water Board will consider adoption of the proposed ELAP regulations at the Board’s State Water Board meeting on Tuesday, March 17, 2020 – 9:30 a.m. that include the TNI 2016 Standard. Please see notice for location and details.

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