Laboratory Approval Program Amendments (18 AAC 78) Frequently Asked Questions
1. What are NELAP and DoD-ELAP and where can I find more information about them?
NELAP stands for National Environmental Laboratory Accreditation Program (NELAP). The program is overseen by the National Environmental Laboratory Accreditation Council (NELAC). The program sets forth a set of standards and grants accreditation to labs following those standards. Information on NELAP can be found at http://www.nelac-institute.org/
DoD-ELAP is the Department of Defense Environmental Laboratory Accreditation Program. This program takes the NELAP standards and adds additional requirements described in their Quality Systems Manual. Information on DoD-ELAP can be found at http://www.denix.osd.mil/edqw/accreditation/home/
2. When do these changes take effect?
The changes, if adopted, will be effective July 1, 2017.
3. What happens to our lab’s existing certification? Is it no longer valid when the program changes?
Labs will be allowed to operate under their existing approvals until those approvals expire. For example, a lab approved through December 21, 2017 will not need a new certification from the LAP until December 22, 2017.
4. I have my 8260 and 8270 analyses approved under Minnesota NELAP, but my AK 101 and AK 102 analyses are approved under Oregon NELAP. Do I have to submit both approvals?
A laboratory will need to submit copies of their primary accreditations for all methods they seek to run for samples collected under 18 AAC 75 or 18 AAC 78.
5. I have several NELAP and DoD-ELAP accreditations, which do I submit with my application?
Labs should submit their primary accreditation. If a lab has primary accreditations from both NELAP and DoD-ELAP, the lab can choose which accreditation it wants to submit.
6. My approval expires this month, can I renew under the new system now?
Labs with approval expiring prior to June 30, 2017 will need to renew under the current program until the regulations are adopted. Once the regulations are adopted they will not become effective until July 1, 2017; however, between adoption and the effective date, labs will have the option of applying under the new system.
7. If I lose my NELAP or DoD-ELAP accreditation for method SW 8260 and fail to notify the Department within 3 business days, will I lose my method SW 8260 approval for 12 months, or do I lose my approval for all methods for 12 months?
Under the proposed changes, a laboratory that fails to notify the department within three business days of changes in their certification of a single method will be designated “disapproved” and lose DEC approval for all other methods as well, for a period of 12 months. It is therefore incumbent upon laboratory managers to provide timely notification of any change in status.
8. Can I obtain approval from any NELAP accrediting body?
Yes, however labs are advised to research accrediting bodies to verify that they will approve the methods for which certification is sought; For example, some NELAP programs will not approve out-of-state methods like the AK 101/102/103 methods or the State of Washington petroleum methods.
9. My lab isn’t NELAP or DoD-ELAP accredited, but I want to continue analyzing samples under 18 AAC 75 and 18 AAC 78. How do I choose which approval to get?
Ultimately this is a decision every lab will have to make for themselves. A number of factors can impact your choice of approval. Things such as the location of your lab, your current customer base, your potential future customer base, cost of approval, and the stability of each state’s NELAP program can all factor into a lab’s decision. Labs trying to choose a program are encouraged to contact both NELAP and DoD-ELAP and discuss advantages and disadvantages to each program.
10. My lab doesn’t have NELAP or DoD-ELAP accreditation but we are approved under the Alaska Drinking Water Program. Can we analyze samples for contaminated sites?
Under the proposed changes, only analytical methods for which NELAP or DoD-ELAP approval have been obtained by the laboratory will be approved for samples from contaminated sites or underground storage tank sites. Therefore, in order for a drinking water method to be used for a contaminated site, that method must have NELAP or DoD-ELAP approval.
11. What changes are being made to the UST Procedures Manual?
The only changes to the UST Procedures Manual are to include a source for a list of suppliers for obtaining Performance Evaluation (PE) samples for each of the Alaska Series petroleum methods (AK 101, AK 102, and AK 103). This information was previously listed in the regulation but is now shown in the manual. The other change is to delete “department’s chemistry laboratory” from the footnotes of Table 1 Part A and Table 1 Part B in Section 4.0. All changes are shown in red in the public noticed version of the Procedures Manual.