Comment Letter on ELAP Regulations Development/Laboratory Standard

Dear Chair Marcus:
The Central Valley Clean Water Association (CVCWA) appreciates the 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 the quality management system (QMS) for California laboratory accreditation.1 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 provide compliance monitoring and ensure proper operation of their wastewater treatment plants in a manner that is protective of public health and the environment. Others rely on small local laboratories to perform basic testing. In this letter, we provide further comments regarding ELAP’s proposal to base forthcoming regulations on the 2016 TNI Standard, and its potential impact on publically-owned treatment works (POTWs) in the Central Valley. This letter is not intended to provide an exhaustive list of provisions within the 2016 TNI Standards that we believe are problematic, but rather provide a few examples of some of the problems that specific provisions will create for municipal laboratories, especially small laboratories.