Anonymous public comment
AnonymousOpposeIndividual
Summary: The commenter opposes the renewal of the Performance Evaluation Studies on Wastewater Laboratories, arguing that the program is a burdensome and costly waste of resources for laboratories. They contend that existing accreditation requirements already ensure competency and that the specific tests required by the study are often niche or irrelevant to their primary operations.
1. The DMR QA program is a burden to laboratories that already are accredited in California to run tests. Laboratories are already required to report positive and negative controls to show competency in testing.
2. The WET testing offered doesn’t even cover the tests that are most used by most laboratories for testing. It only covers a fraction of the tests under a laboratory’s Fields of Accreditation. For clients who have to submit the results from their contract laboratory, most are submitting results from a species they don’t even use for their facility.
3. For smaller labs with limited testing, sometimes the DMR QA program is the only time they run that specific test.
4. The metrics used for acceptable and non-acceptable results can be broad in some tests and very narrow in others. The control charts the laboratories already use for accreditation give a much better idea of the laboratory’s proficiency in a specific test.
5. The cost and time consumption of running the DMR QA Study each year is burdensome for most laboratories. It is a waste of resources to conduct a test for what is considered an environmental testing niche.
6. The study for this year, if continued, is going to be delayed until the end of this year (due to this comment period), and extending into an extremely busy time for most laboratories.
Thank you for your time.