Anonymous public comment

We support pursuing a DMRQA exemption for Florida for the following reasons: •Duplicative requirements: NELAP accreditation already requires successful participation in proficiency testing (PT) for all accredited analytes. The DMRQA process relies on the same PT data that laboratories complete and that PT providers already submit to the Florida Department of Health for NELAP accreditation oversight. •Administrative burden: The primary concern is not the PT studies themselves, but the additional effort required to gather information, compile reports, complete forms and submit documentation that largely duplicates information already available to FLDOH. Laboratories and regulators are expending significant resources on a process that does not appear to provide additional quality assurance or benefit beyond existing NELAP requirements. •Existing regulatory oversight: Laboratories that fail PT requirements or do not participate as required are already subject to corrective actions through Florida’s accreditation program. As such, the DMRQA reporting process appears to duplicate an oversight function that is already in place. •Consistency with EPA-approved waiver states: EPA allows permittees to receive a DMRQA exemption when a state’s laboratory quality assurance program has been approved as an equivalent substitute. Several states have already received EPA-approved waivers, and that list continues to grow. Given Florida’s established NELAP accreditation program, is there a reason Florida would not be a strong candidate for a similar exemption? • California • Kansas • Kentucky • Nevada • New Jersey • North Carolina • Pennsylvania • South Carolina • Utah • Virginia • West Virginia • Wisconsin