SPOTSYLVANIA COUNTY LABORATORY SERVICES COMMENTS ON PROPOSED REGULATIONS FOR CERTIFICATION OF NONCOMMERCIAL ENVIRONMENTAL LABORATORIES

(1VAC30-45)

November 6, 2015

GENERAL COMMENTS

1. Spotsylvania County Laboratory Services ("Spotsylvania") supports DCLS’s mission to improve the regulations for Certification of Noncommercial Environmental Laboratories with amendments to improve efficiency and support the endurance of the program.

2. Spotsylvania appreciates amendments made to the program to ensure noncommercial laboratories are not held to more demanding requirements than commercial laboratories (1VAC30-46).

3. Spotsylvania appreciates the hard work and dedication of DCLS staff. This certification program is necessary to guarantee all noncommercial laboratories are held to the same standards across the board. Spotsylvania understands this program is self-funded and hopes the new fee structure brings enough additional revenue to bring on another assessor. The one-on-one time between laboratory and assessor is incredibly important and useful.

GENERAL PROVISIONS

1. Procedures to Suspend Laboratory Certification. Spotsylvania appreciates and supports the addition of a suspension process. This step before decertification will allow laboratories time to correct deficiencies, which in the past might have resulted in automatic decertification.

2. Reduction in Number of Proficiency Tests. Spotsylvania supports the reduction of PT studies to once every year. Laboratories have been requesting this change for quite some time and Spotsylvania is pleased to see it in the proposed regulations. This change has multiple benefits for DCLS and laboratories: reduced administrative burden, cost savings for laboratories, etc. The reduced proficiency test requirement partially offsets the increased certification fees proposed by DCLS and Spotsylvania appreciates this.

3. Maintain DCLS’s On-Site Inspection Frequency Spotsylvania supports the current schedule of inspections once every two years. Spotsylvania would also consider supporting a three year inspection cycle. Spotsylvania must withhold support for VAMWA’s suggestion of a Risk Based Inspection Strategy modeled after DEQ’s model. As we understand, an inspection plan similar to DEQ’s might have low-risk laboratories inspected once every five years. Spotsylvania feels this is much too long to go without a site visit. Inspections are valuable sources of information for laboratories and provide important time for training by DCLS assessors.

4. Confirmation Related to On-Site Assessment Checklists. Spotsylvania would like to confirm that checklists completed by assessors during on-site assessments will be available to the laboratory. As we understand it, the provision for DCLS providing checklists to laboratories was removed from this regulation because the checklists are now available online. Spotsylvania would like assurance that the practice of giving laboratories completed inspection checklists is continued. These marked-on checklists are an important tool to help laboratories understand findings and troubleshoot solutions with assessors during an on-site visit.