Comment submitted by Wes Wygant

DMRQA is literally the only testing requirement imposed by EPA to track operational competency of a reporting laboratory. Having been both the lab personnel responsible for the actual testing and now the superintendent responsible for submitting the finished DMRQA report to EPA, I feel that DMRQA is a useful tool to both regulators and WWTP's equally. Because DMRQA involves testing against known pollutant quantities vs unknown quantities as normally seen in day to day lab operations, it can help identify quality control or procedural deficiencies that might go unnoticed when only testing for unknown pollutant levels. It's very possible to have unrecognized operational deficiencies in a lab and still get testing results that fall within allowable permit limits. In house QC standards are only subject to in house interpretation and response. DMRQA is the only tracked reporting requirement designed to set a minimum bar for operational accuracy. All EPA discharge limits are developed / determined in large part by the testing information provided by reporting labs. Without some formal way to establish a known minimum standard of the quality of the submitted information, the parameters used by EPA to establish protective limits for the environment become more difficult to develop in a fair and accurate way. Cost in dollars and labor are minimum, in the big picture. The testing required is the very same testing being done already by the reporting lab. No extra personnel, equipment or reagents are necessary. The only added cost is for the DMRQA test kit provider. This is minimal in the scope of operational costs of a lab. If that cost were truly a burden to a reporting lab, it would suggest that the lab in question is woefully underfunded and that would be a good example of a lab deficiency being identified by the requirement for DMRQA testing.