Dear Ms. Marcus:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to comment on the California Environmental Laboratory Accreditation Program’s (ELAP) recommendation to adopt Volume 1 of The NELAC Institute’s (TNI) 2016 standard as the basis for laboratory accreditation as the California laboratory standard. CVCWA is a non-profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses. We approach these matters with the perspective of balancing environmental and economic interests consistent with state and federal law. Many of our members operate environmental laboratories to ensure proper operation of their wastewater treatment plants in a manner that is protective of public health and the environment. Additionally, others rely on small local laboratories to perform basic testing. In this letter, we provide comments on ELAP’s proposal to use the 2016 TNI as the California laboratory standard, including our concerns about the unintended consequences of adopting this standard and the lack of a real stakeholder process leading up to this proposal.