Agency Information Collection Activities; Proposals, Submissions, and Approvals: Performance Evaluation Studies on Wastewater Laboratories (Renewal)

The commenter supports granting Florida a DMRQA exemption because the state's existing NELAP accreditation program already requires proficiency testing and provides sufficient regulatory oversight. They argue that the current DMRQA reporting process creates a duplicative administrative burden without providing additional quality assurance benefits.

The commenter opposes the proposed information collection, arguing that the DMR-QA program creates an undue burden on permit holders. They suggest that the agency should rely on existing TNI laboratory certifications from accrediting bodies instead of collecting additional DMR-QA information.

A commercial laboratory representative argues that wastewater laboratories should have more flexibility to choose and schedule performance testing (PT) studies to support their DMRQA reporting. They suggest this change would align WET laboratory requirements with analytical parameter requirements and help reduce laboratory certification costs.

The commenter suggests that the current proficiency testing requirements are not very useful for permittees. They argue that a more effective requirement would be for laboratories to provide permittees with their scope of accreditation and specific method detection and reporting limits.