Questionable Practices in the Organic Laboratory: Part Ii

During recent environmental laboratory audits conducted by the USACE, certain ‘questionable practices’ have been observed, especially in the organic analysis areas. Most people have a relatively good idea of what constitutes a fraudulent activity today. The concepts of ‘dry-labing,’ ‘peak shaving,’ ‘peak enhancing,’ or ‘time-traveling’ are well understood. These practices clearly involve the deliberate manipulation and/or alteration of data, often to achieve or meet method QC criteria. Unfortunately, these practices are still being observed today. In addition, there are a new group of ‘questionable practices’ now being observed that often involve the selective exclusion of data to achieve or meet method QC criteria. Examples of some of these practices include the following: (1) Dropping points during initial calibration to meet method criteria. (2) Reporting very tight QC performance ranges when actual lab control charts show a significantly wider range. (3) Dropping points to achieve a lower Method Detection Limit (MDL). (4) Performing tunes by picking the scan or series of scans that will meet the desired criteria after the original tune had failed. (5) Performing initial calibration curves but never verifying that the peaks used for the calibration actually represented the target analyte. These practices are often described as ‘the common approach used by everyone,’ yet when described to people within EPA (e.g., the MICE Hotline), the clear response is that these approaches were never intended within the context of SW-846, although not explicitly addressed nor prohibited. INTRODUCTION The US Army Corps of Engineers (USACE) currently executes remedial and compliance activities under several environmental regulatory programs. The analytical testing of various environmental samples is often a significant part of these activities. The data must be produced by a process or system of known quality to withstand scientific and legal challenge relative to the use for which the data are obtained. To give the USACE programs the greatest flexibility in the execution of its projects, the SW-846 methods, as published by EPA, are generally the methods employed for the analytical testing of environmental samples. These methods are comprehensive and flexible and can be readily adapted to individual project-specific requirements. As stated in the Final Rule that incorporated the Third Edition of SW-846 (and its updates) into the RCRA regulations, this appendix is required to be used for certain activities in the RCRA program. In other situations, this EPA publication functions as a guidance document setting forth acceptable, although not required, methods to be implemented by the user, as appropriate, in satisfying RCRA-related sampling and analysis requirements. During recent laboratory audits conducted by the USACE, certain 'questionable practices' have been observed, especially in the organic analysis areas. Prior to project execution, the USACE may conduct a review of the laboratory that was proposed for use on that specific project. This review typically consists of three phases: (1) documentation review; (2) analysis of Performance Evaluation (PE) samples; and (3) on-site laboratory audit. Additional follow-up audits can also be conducted. These 'questionable practices' have been noted during all phases of these laboratory