Qualified Environmental Professionals and Qualified Samplers

Overview

State regulations, 18 Alaska Administrative Code (AAC) 75 and 18 AAC 78, define the requirements for responding to oil and hazardous substance releases. These requirements include provisions that response activities, with the exception of some initial response actions conducted under 18 AAC 75.315, are conducted by individuals that meet minimum education, training and work experience standards. See 18 AAC 75.333 and 18 AAC 78.088.

Note: DEC does not maintain a list of qualified environmental professionals or qualified samplers, nor does it issue qualification certificates. If requested, DEC is available to review qualifications or assist with evaluating qualifying criteria. DEC may request resumes documenting workers’ qualifications be submitted with a work plan.

Qualified Environmental Professionals

Under 18 AAC 75.333(b), a qualified environmental professional is an impartial third party that is qualified to perform site characterization and cleanup activities, actively practices in the field of environmental science or another related scientific field, has not been found to have falsified environmental data or committed other acts of fraud directly related to environmental work, and meets one of the following sets of criteria for education and experience:

• Completion of a four-year undergraduate or a graduate degree from a nationally or internationally accredited postsecondary institution in environmental science or another related scientific field; and
• Have at least one year of professional experience in contaminated site characterization and cleanup activities under the supervision of a qualified environmental professional after the degree was obtained.

Alternatively, the following minimal qualifications are required:

• Completion of a four-year undergraduate or a graduate degree from a nationally or internationally accredited postsecondary institution in any field or a two-year degree from a nationally or internationally accredited postsecondary institution in environmental science or another related scientific field, or certification as an environmental technician under an apprenticeship program registered under 29 Code of Federal Regulations (CFR) Part 29; and
• Have at least three years of professional experience in contaminated site characterization and cleanup activities under the supervision of a qualified environmental professional after the degree or certificate was obtained.

A person responsible for investigating and cleaning up spills of oil and hazardous substances, or spills from a regulated underground storage tank (18 AAC 78), shall ensure that a “qualified environmental professional” does the following:

• Prepares site characterization work plans;
• Conducts or supervises the sampling, collection, interpretation and reporting of all data;
• Prepares site characterization, site assessment and release investigation reports;
• Prepares site cleanup and corrective action plans;
• Prepares post-treatment sampling plans and reports; and
• Prepares interim and final cleanup and corrective action reports.

Qualified Samplers

Under 18 AAC 75.333(c), a qualified sampler is an impartial third party that collects samples from soil, groundwater and surface water (does not include air or soil gas) for laboratory analysis, has not been found to have falsified environmental data or committed other acts of fraud directly related to environmental work, and meets one of the following sets of criteria for education and experience:

• Has successfully completed an environmental sampling training program recognized by DEC or, alternatively, completed applied field work involving environmental sample collection associated with a degree in environmental science or another related field from a nationally or internationally accredited postsecondary institution; and
• Has at least three months of experience in environmental sampling under the direct supervision of a qualified environmental professional completed after the training.

Qualified samplers may conduct sampling under the direct supervision of a qualified environmental professional or, when specifically approved by DEC, may collect samples of soil, groundwater, and surface water for laboratory analysis as part of the cleanup process.

Qualified Sampling Training Programs

The Division of Spill Prevention and Response will assess if a training program or applied field work course meets the minimum qualifications required to become a qualified sampler. Training programs should include the following elements:

1. Principles of Representative Sampling - This module should be designed to establish a foundation for environmental sampling. The module should emphasize the importance of data reproducibility and data quality objectives, identify sampling methods, explain the rationale for sampling, cover basic terminology, and responsibilities of a sampler.
2. Soil Sampling - This module should be designed to teach the particulars of soil sampling. The following subjects should be covered: differences in types of soils collected, discrete versus incremental/composite sampling, common sampling techniques or approaches, analytical methods, preservation, and holding times, field screening, using technology (GPS or other methods) to document sample locations, practical use of common tools to collect samples, and labeling of samples.
3. Surface Water and Sediment Sampling - This module should be designed to teach the particulars of surface water and sediment sampling. The following subjects should be covered: importance of co-locating surface water and sediment samples, importance of not filtering surface water samples, sample tools to collect surface water and sediment, common sampling techniques or approaches, analytical methods, preservation, and holding times, using GPS or locates to document sample locations, and labeling of samples.
4. Groundwater Sampling - This module should be designed to teach the particulars of groundwater sampling. The following subjects should be covered: groundwater monitoring well installation and development, documentation of groundwater elevations and fuel product on groundwater, purge versus no-purge sampling, sample tools to collect groundwater and purge a well, common sampling techniques or approaches, analytical methods, preservation, and holding times, containerizing and disposing of purge water, using GPS or locates to document sample locations, and labeling of samples.
5. Preservation, Documentation, Packaging, Transport, and Quality Assurance/Quality Control (QA/QC) - This module should be designed to teach the particulars of field documentation, sample packaging and transport, and field QA/QC. Trainees should be taught the following subjects: cooler packing, temperature blanks, and labeling for transport, sample equipment cleaning for re-use, QA/QC sample collection (field duplicates, trip blanks, and equipment blanks), techniques to minimize cross contamination of samples, chain of custody form completion, and documentation of measurements and activities in field notebooks.

The following training programs have been certified as meeting the educational requirement for becoming a qualified sampler:

• The Nielson Environmental Sampling E-Course
• Dr. Hagedorn’s Environmental Sampler Workshop

Requisite Experience for Qualified Samplers

To become a qualified sampler, DEC requires three months of experience in environmental sampling practices under direct supervision of a qualified environmental professional. This experience should include:

1. Identifying and Documenting Sample Locations - a qualified sampler trainee should gain experience identifying and documenting sample collection locations. Sample locations or GPS coordinates and all required field measurements should be obtained and recorded in a field notebook and on pertinent field forms so that all field activities are documented.
2. Collecting Samples - a qualified sampler trainee should gain experience conducting a variety of field screening tests, purging monitoring wells, and collecting primary, duplicate, and quality assurance samples from soil, groundwater, surface water or sediment; placing samples in appropriate jars or containers; ensuring samples are preserved, as required; labeling the samples; and completing all other field forms.
3. Packing a Sample Cooler and Delivering or Shipping Sample Cooler to the Appropriate Laboratory - a qualified sampler trainee should gain experience packing samples in a cooler for transport to a laboratory, labeling the cooler, and filling out chain of custody forms.

In most cases, fulfillment of the three months environmental sampling experience requirement can be completed during one field season provided the activities are supervised by a qualified environmental professional and cover the range of activities described above. DEC acknowledges that a single sampling event may not occur over a three-month time frame. Therefore, time devoted to report preparation, for example, or disposing of investigative derived waste can supplement the three months environmental sampling experience requirement as long as the required activities noted above have been completed.

Contact Our Staff

If you have any questions or concerns regarding requirements to become a qualified environmental professional or qualified sampler, please contact Todd Blessing at 907-269-7699 or email him at todd.blessing@alaska.gov.