A Private Laboratory Perspective on Environmental

Regulation

Introduction to CCIL• CCIL represents the independent testing

laboratories sector.• Part of a $2.3-billion-dollar-a-year industry that

employs 20,000 skilled workers.• Members operate more than 330 lab facilities, • We work collaboratively with Government.

Canadian Council of Independent Laboratories

• Represents the interests of the private laboratory community.

• Two divisions• Environmental• Geotechnical

Environmental Division•100 Accredited Labs Across Canada

•$350 MM in annual revenue

•4500 knowledge based jobs

•Our members do the vast majority of testing in support of Federal and Provincial Environmental Regulation

Concerns

• Guidelines at or below laboratory method detection limits (MDLs)

• Widely differing Guidelines between agencies

• Lack of notice when new Guidelines are introduced.

• Inconsistent or no Data Quality Objectives

Guidelines Below MDLs

• CCME Reactive Chlorine Species 0.5 ug/L MDL 3 ug/L

• CCME Toxaphene Soil 0.0001 mg/kg MDL 0.005 mg/kg

• Frustration with the data user

• Makes the Lab look incompetent

Guidelines at MDLs

•ESRD Agricultural Guideline: • Vinyl Chloride 0.34 ug/kg MDL 0. 33 ug/kg

•Measurement Uncertainty at the MDL ± 60% - 100%• 19 of 20 measurements at 0.34 will fall between 0.13 and

0.43 ug/kg in the best case• We measure 0.4 ug/kg. Is it really above the Guideline?

Widely Differing Guidelines

• Labs often don’t know source of sample• Guideline may impact method choice• Can there not be consensus?

CCME OMOE ESRD BCCSR

Xylenes mg/kg

2.4 0.05 15 0.1 - 20

Lack of Notice New Chemicals Revised Values

• Hydrazine: FEQG published Feb 2013 also adopted by ESRD 2014 surface water quality guidelines

• No lab analyzing currently• Preservation problematic (degrades up to

100% in 4 days (FEQG factsheet)

Lack of Data Quality Objectives (DQOs)

• Lab Methods Performance based

• How do we ensure consistent data between labs ?

•What are DQOs?• Lab QC samples run with every batch carried

through the whole process + LRLs• Blank, blank spike, matrix spike, duplicate• Guidance on acceptable values

• E.g. Blank < LRL, blank spike 80% - 120%

Lack of Data Quality Objectives (DQOs)

• OMOE and USEPA have historically provided DQOs

• CCME Analytical Methods Compendium recently developed also contains DQOs

• Concerted effort to make CCME and OMOE consistent

CCIL strongly supports adoption of consistent, reasonable DQOs across Canada

• Best practice to ensure consistent data between labs

Improved Communication• BCELTAC

• CCIL / ESRD Liaison Committee

• ADLTAC

• OMOE TAG

• OMOE / CCIL DW Committee