The Augusta County Service Authority appreciates the opportunity to comment on the proposed regulations for Certification of Noncommercial Environmental Laboratories.

Specifically, we support the reduction in the number of proficiency tests required for each field of certification from twice to once per year.    As noted, noncommercial environmental laboratories perform proficiency tests quite well and this will help reduce the costs of fees for smaller utilities.

The frequency of on-site inspections should be a Risk Based approach similar to the process used by DEQ with regards to Wastewater Treatment Plant inspections.  If a facility is not having issues, then DCLS's resources could be better utilized elsewhere.  An inspection schedule of every 3 years (like Drinking Water Labs) would benefit labs and possibly allow DCLS to combine the inspections.  If a lab had specific issues, the inspection frequency could remain on a 2 year schedule.

ACSA supports the addition of procedures for temporary suspension of laboratory certification in lieu of decertification.  This gives the lab an opportunity to remedy the problem prior to its certification being withdrawn.

ACSA also supports removing references to the initial certification period and streamling the process for laboratories applying for and renewing their certifications. 

ACSA supports modifications to ensure that noncommercial laboratories are required to meet standards no more stringent than commercial laboratories.