A Private Laboratory Perspective on Environmental Regulation

Introduction to CCIL CCIL represents the independent testing laboratories sector. Part of a $2.3-billion-dollar-a-year industry that employs 20,000 skilled workers. Members operate more than 330 lab facilities, We work collaboratively with Government.

Canadian Council of Independent Laboratories Represents the interests of the private laboratory community. Two divisions Environmental Geotechnical

Environmental Division 100 Accredited Labs Across Canada $350 MM in annual revenue 4500 knowledge based jobs Our members do the vast majority of testing in support of Federal and Provincial Environmental Regulation

Concerns Guidelines at or below laboratory method detection limits (MDLs) Widely differing Guidelines between agencies Lack of notice when new Guidelines are introduced. Inconsistent or no Data Quality Objectives

Guidelines Below MDLs CCME Reactive Chlorine Species 0.5 ug/L MDL 3 ug/L CCME Toxaphene Soil mg/kg MDL mg/kg Frustration with the data user Makes the Lab look incompetent

Guidelines at MDLs ESRD Agricultural Guideline: Vinyl Chloride 0.34 ug/kg MDL ug/kg Measurement Uncertainty at the MDL ± 60% - 100% 19 of 20 measurements at 0.34 will fall between 0.13 and 0.43 ug/kg in the best case We measure 0.4 ug/kg. Is it really above the Guideline?

Widely Differing Guidelines Labs often don’t know source of sample Guideline may impact method choice Can there not be consensus? CCMEOMOEESRDBCCSR Xylenes mg/kg

Lack of Notice New Chemicals Revised Values Hydrazine: FEQG published Feb 2013 also adopted by ESRD 2014 surface water quality guidelines No lab analyzing currently Preservation problematic (degrades up to 100% in 4 days (FEQG factsheet)

Lack of Data Quality Objectives (DQOs) Lab Methods Performance based How do we ensure consistent data between labs ? What are DQOs? Lab QC samples run with every batch carried through the whole process + LRLs Blank, blank spike, matrix spike, duplicate Guidance on acceptable values E.g. Blank < LRL, blank spike 80% - 120%

Lack of Data Quality Objectives (DQOs) OMOE and USEPA have historically provided DQOs CCME Analytical Methods Compendium recently developed also contains DQOs Concerted effort to make CCME and OMOE consistent CCIL strongly supports adoption of consistent, reasonable DQOs across Canada Best practice to ensure consistent data between labs

Improved Communication BCELTAC CCIL / ESRD Liaison Committee ADLTAC OMOE TAG OMOE / CCIL DW Committee