quality assurance for tribal fifra enforcement grants david r. taylor epa region 9 quality assurance...
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Quality Assurance for Tribal FIFRA Enforcement Grants
David R. TaylorEPA Region 9
Quality Assurance Office
What are QA requirements under FIFRA?
Grant regulations and the CFR requires grantees collecting environmental data using Federal grant funds to have a quality system in place.
More importantly, it makes sense to have a system in place that ensures data of know quality will be used for decision making.
How do I establish a Quality System?
EPA expects grantees will prepare a Quality Management Plan (QMP) and/or a Quality Assurance Project Plan (QAPP) and then implement it.
Guidances for QMP and QAPP preparation describe the expected components of a Quality System.
What is a QMP?
A QMP is a document that describes a Quality System.
Policy document. Identifies QA Officer or how QA
function will be handled. Describes system, not day to day
data gathering operations.
Do I have to prepare a QMP?
EPA Regions differ in implementation of this requirement. Some require a QMP. Some accept QMP as part of QAPP. Some only expect a QAPP at this time. Check with Regional QA Officer and/or
EPA Project Officer.
What if we can’t afford a QA Officer?
Few small organizations have a QA Officer.
Must describe how QA function will be carried out independent of data generation
Some options Set aside time by supervisor or staff Another staff person (e.g., 2nd inspector) Person from another organization
What is a QAPP?
QAPP is a document that describes the data generation process, including sample collection, sample analysis, quality control, data review, and most importantly, decision making (i.e., how will the data be used?).
Environmental Measurements under FIFRA
Use/Misuse* Formulations* Worker Health and Safety** Groundwater Investigations** Special Projects*** Enforcement related, measurements involved
** Usually no measurements *** Usually one time event, no enforcement
QA Plan Options - QMP
EPA Requirements for Quality Management Plans (“R-2”)
Guidance for Quality Management Plan Development for EPA Funded Environmental Cooperative Agreements with State and Tribal Agencies
QA Plan Options –QA Project Plan
Guidance for the Preparation of Quality Assurance Project Plans (“G-5”)
Guidance for Quality Assurance Project Plan Development for EPA Funded Cooperative Agreements with State and Tribal Agencies for the Conduct of FIFRA Pesticide Programs
Critical Elements of an Enforcement QAPP
Description of how program is structured Project Organization Decision Makers
Critical Elements of an Enforcement QAPP
Overview of program components (e.g., use/misuse, formulations, worker health and safety, etc.
Description of how program is implemented (e.g., different activities, who carries them out, typical sequence of events, etc.)
Critical Elements of an Enforcement QAPP
Description of decisions to be made with the data
Criteria upon which decisions are to be made
Decision maker if not identified earlier
Critical Elements of an Enforcement QAPP Description of documentation
requirements with relevant examples (e.g., inspector incident report, lab submission form, chain of custody, field sampling plan template, etc.)
Description of how samples are collected or references to appropriate protocols (e.g., NEIC Manual, EPA Inspector Manual, field SOPs)
Critical Elements of an Enforcement QAPP
Description of how samples are packaged and shipped, chain of custody, holding times, etc.
Description of how and where samples are analyzed (expectation is use of state agricultural laboratory, but could be a commercial laboratory). Documentation not on file with EPA would need to be supplied.
Must we use our State Agricultural Laboratory (SAL)?
No, but it is recommended... Only a small number of pesticides are
covered by EPA methods. This may mean method development costs.
Lack of familiarity with some pesticides may impact analysis.
SAL will be more likely to have developed QC criteria for unusual pesticides – a data quality issue
Must we use our State Agricultural Laboratory (SAL)?
Few commercial labs have extensive experience with unusual matrices (e.g., different types of foliage, fruits and vegetables, wipe samples).
Commercial laboratory may not have necessary equipment/instruments.
Few commercial laboratories have experience with high concentration formulation samples.
References/Further Information
Region 9 QA website: www.epa.gov/region09/qa
[email protected] New Tribal FIFRA Enforcement
QAPP Guidance (in preparation by Region 9 QA Office) due in fall
Earlier cited FIFRA Documents
Training
Proposed training will be November 8-9, 2005 in Reno, Nevada, sponsored by EPA and the Pyramid Lake Paiute Tribe
Training will include use of a computer to develop QAPP on site
Each tribal staff person will need to know and understand how his or her program works and will need to bring relevant information