Chain of Custody Records Proper Documentation Techniques Dr. Richard Medina Environmental Testing and Consulting, Inc.

Definition A legal document that demonstrates the progression of samples as they travel from the original sampling location to the laboratory or testing facility. It is the first piece of paper evidence, showing the capture, custody, control, transfer and eventual disposition of physical evidence from a predetermined sampling site.

Secondly………. It is a written concept of maintaining the integrity of a sample through its life history as a moving viable sample.

Capture Refers to the actual collection of a sample. It is the real-time snapshot of physical evidence, which at analysis will demonstrate the physical, chemical and biological properties of that sample at the time of capture. As the collection of evidence is the first step in determining the “condition” of that sample, the integrity of that sample must be maintained in order to accurately demonstrate its true characteristics.

Sample integrity is achieved by: Following the sampling plan detailing the collection of samples; Allowing only trained authorized personnel to perform sampling; Using appropriate collection techniques specific to the matrix and end-user’s purpose through guidance from the reference method or other mandated (permit) regulations; Preventing the contamination or adulteration of the sample and by using the appropriate containers and temperature and chemical preservations.

At collection, the documentation process begins. The sampler at that time must: Use the appropriate labeled container for sampling and record the field or sample ID assigned to each sample on the COC; Accurately and unambiguously record on the COC the date and time a specific sample was collected. This should be done immediately to prevent an estimation of collection or time-frame errors; Record the number of samples taken from the identified collection site; Indicate whether the sample is a grab or a composite and the matrix type (wastewater, sludge, stormwater, etc.); Always use inerasable ink; Sign the COC in the appropriate line or space.

Additionally,…….record…. Any anomalies observed during the sampling event. This might include a difference in color or ambient smell of the sample, variance in turbidity, visible solids or temperature. Include this information on the COC. If this is not possible, note in a field log and record these observances indicating the sample or field ID for the samples in question.

These actions therefore establish: The WHO (Authorized Person) The WHAT (Grab – Southside Effluent) The WHEN (Date and Time, use military time or standard time with a.m. or p.m. notation) The WHERE (Facility name AND location, ABC POTW – Pumping Station #3)

Custody

The concept of custody involves the physical secured maintenance of a sample. A sample is in custody if it is in physical possession or if it is in a designated and maintained area that is restricted to authorized personnel. Sample custody procedures are necessary to prove that the sample data generated corresponds to the unique sample collected. Custody includes the transfer of sample(s) from the sampling site to the field personnel and into the laboratory or testing facility. This may also include intralaboratory custody, that is, within the laboratory as well. Every transaction from the collection of the sample to its transfer to the testing site must be chronologically connected in order to withstand legal scrutiny as to the authenticity of that sample.

Proper custody procedures protects the interests of the client and that of the testing laboratory

Control In conjunction with custody procedures, control is the state of establishing documented traceability of a sample from the sampling site through analysis and into final reporting. It is the use of nomenclature or a unique identifier linking it between its origin to its use by the end-user. At collection every piece of evidence must be assigned a unique name and documented on the COC. This sample or field ID may be reassigned a tracking number upon introduction into the laboratory. Therefore a written, traceable unequivocal link is always required for establishing control.

(Ironically), you may have (physical) custody of a sample without having control…….but if you have (documented) control of a sample you have established custody.

Transfer

Proper chain of custody must be maintained when a person is transferring samples irregardless if the person is directly or indirectly related to the testing facility. Minimally, there must be two signatures on the COC. That is, the sampler, (who also is the courier) and the person in the lab receiving the samples. Every person who handles the samples whether relinquishing or receiving must be indicated by signature on the COC.

Required Elements on a COC Must contain the legal name, address and phone number of the testing facility AND that of the facility from which the samples were obtained; Project or Site Identification: The complete and individual identification of the sampling site must be made evident on the COC. Include the permit number if possible;

List a Project Manager or POC; For each sample, list the client’s sample or field ID. Samples must be uniquely identified; List the number of containers; Correct sampling date and time is on COC; Sample matrix (aqueous, sludge, etc.); Sample type (grab, composite, extract, etc.); Analysis requested – Include the parameter and method number. Assure the method corresponds to permit or project requirements; Indicate cooler or sample temperature;

Indicate preservation check or verification; Indicate total number of pages of COC; Signatures for receipt and relinquishing of samples; Field Personnel Lab Personnel Abnormalities or non-compliances noted on COC or indicated in another document.

Optional information……….. Type of sampling event, (single, daily, weekly, monthly, quarterly, etc.); Project number, PO or FID number; address of Project Manager or POC; Information about TAT, (RUSH, standard); Regulation information for intended use, (NPDES, RCRA Soil, UST); Sample Depth for Soils

Method of shipment, (FedEx, UPS, designated courier); Special remarks or safety warnings; Compositing information (ISCO #3, SN 12345). REMEMBER The more (relevant) information that can be documented, the legally stronger the COC becomes.

Avoid documenting…. Any calibration or analytical information on the COC; (Excluding temperature or field results such as pH or checks on residual chlorine). Document such in a separate document or log. Vital information related to calibration and analysis must be fully documented. The COC is not designed to document this type of information due to the complexity of test(s), calibration and analytical requirements.

Purpose of the Chain of Custody To legally record the progression of physical custody and control of a sample from the sampling event to induction into the laboratory.