United States      Office of Research and    EPA/600/R-94/03Ba
         Environmental Protection   Development       April 1994
         Agency        Washington DC 20460
SEPA   Quality Assurance
         Handbook for
         Air Pollution
         Measurement
         Systems

         Volume I: A Field
         Guide to Environmental
         Quality Assurance

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                                    EPA-600/R-94/038a
     Quality Assurance Handbook

                   for

  Air Pollution Measurement Systems
      Volume I - A Field Guide to
   Environmental Quality Assurance
                  1993
                    by
                Monica Nees
        U.S. Environmental Protection Agency
        Office of Research and Development
Atmospheric Research and Exposure Assessment Laboratory
         Research Triangle Park, NC 27711
                                  Printed on Recycled Paper

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           OVERVIEW OF THE INTERIM EDITION OF VOLUME  I

     The Quality Assurance  (QA) Handbook is comprised of five
volumes.-  Volume I  (Principles), Volume II (Ambient Air Methods ,
Volume III  (Stationary Source Methods),  Volume IV (Meteorological
Measurements),and Volume V  (Precipitation Measurement Systems).
Much of the material in Volumes II,  III and V are out-of-date ar.d
some portions of these volumes have long been out-of-print.

     EPA is now preparing an updated version of. the QA Handbook
series which will be available in September 1995.  To meet the
needs of the user community until the updated version is
available, EPA has published Interim Editions of Volumes I, II,
III, IV and V.  Each volume of the Interim Editions,  is being
issued as a complete unit with out-of-date sections either
deleted or modified using addendum sheets and handwritten
notations in the text.

     This volume and the other four volumes of the Interim
Edition of the QA Handbook are available at no charge from:
               USEPA/ORD
               Center for Environmental Research Information
               26 West Martin Luther King Drive
               Cincinnati, Ohio  45268

     Since this volume was updated in 1993,  only minor changes
will be done to it in the updating process.  The updated versic-
will be available in September 1995.

     The user of the QA Handbook is cautioned to bear in mind
that the information provided in the handbook is for guidance
purposes only.  EPA regulations are published in the Code of
Federal Regulations (CFR).  When information in the CFR conflicts
with information in the QA Handbook, the CFR shall be considered
the authoritative and legally bonding document.

                                   William J.  Mitchell
                                         Chief
                              Quality Assurance Support Branch

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                          ACKNOWLEDGEMENTS
     This completely new version of Volume 1 of the Quality Assurance Handbook
for Air Pollution Measurement Systems was prepared by Dr. Monica Nees under
three affiliations.  First, as a chemist enrollee  of the Senior Environmental
Employment program of NCBA and the U.S. Environmental Protection Agency (EPA),
she developed the initial drafts under the direction of Dr. BiHMitchell, Chief, Quality
Assurance Support  Branch,  Atmospheric Research  and  Exposure Assessment
Laboratory, U.S.  EPA, Research Triangle Park, North Carolina. Then, as a senior
scientist at ManTech Environmental Technology, Inc., Research Triangle Park, North
Carolina, she completed work for  publication under the direction of  Kenneth J.
Caviston, Supervisor, Quality Assurance and Other Support, under EPA contract 68-
DO-0106 .
                               DISCLAIMER


     This document has been reviewed in accordance with the U.S. Environmental
Protection Agency's peer review policy and  has been approved for publication.
Mention  of trade names  or  commercial products does  not constitute  EPA
endorsement or recommendation for use.

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                                FOREWORD


     Throughout the world, air quality is a critical concern.  In the United States and
Canada, air monitoring is not the responsibility of just the  federal governments.
States  and provinces, local governments, private industries, and  environmental
Organizations are also participating. Elsewhere, especially  in those countries in
which  air quality is  beginning  to  be addressed,  national governments are the
principal monitors.
     The purpose of these monitoring efforts is not to collect data, because data are
only the beginning, not the end, of environmental investigations. Data should not
be stored and forgotten,  but should be  used to make informed decisions affecting
the health and well-being of planet Earth. Application of the principles of quality
assurance allows decision makers to know the quality of the data  on which their
actions are based.
     William Zinsser in his book On Writing Well calls the instructional manual "one
of the most forbidding swamps in the English language." I hope that this field guide
is not.  It focuses on  the  fundamentals that transcend national  borders, academic
disciplines,  and even  specific environmental media.  Like a field  guide used in
birdwatching, it does not tell everything, but only the most important things. It is
designed to be used in the field or laboratory, not stored on a shelf.  And, although
the examples are chosen from air monitoring, the principles can readily be applied to
any type of environmental monitoring.
     This field guide does not give detailed instructions  for preparing a quality
assurance plan.  Instead,  it emphasizes the thought processes and rationales for
designing any good data collection program with quality assurance as an integral
part. Once this occurs, preparing a quality assurance plan using the format specified
by any  sponsoring organization will be straightforward.
                                                                Monica Nees
                                                                       1993
                                     iv

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                        HOW TO USE THIS FIELD GUIDE


     This  field guide replaces Volume I, Principles,  of the Quality Assurance
Handbook for Air Pollution Measurement b'lthods, first published in the late 1970s
and  updated in 1984.  Using  a common-sense approach, it explains the unifying
concepts underlying all environmental quality assurance, in about one- tenth the
number of pages of its predecessors.
     Such a massive  reduction was possible by the elimination of duplication of
numerous definitions, examples, appendices, and details also  found in Volumes II
through V of the handbook.  Then  the basic principles could  be  revealed and
studied. Once the user understands the principles, he or she can consult the other
volumes for necessary details. Volume II, Ambient Air Specific Methods, for instance,
includes both a lengthy introductory chapter on quality assurance for  ambient air
methods and detailed guidance on nearly a dozen individual test methods.
     By design, the field guide covers only the "Big Picture."  Written  for a broad
audience, it is intended for use both by field and laboratory personnel and by their
managers in planning all aspects of environmental data collection. Its sections cover
all phases of the life cycle of any such project, from planning  through  final report
writing. Throughout, the  importance  of planning is stressed again and again. Each
section is self- contained, for ease in future reference. The best way to use the field
guide, however, is first to read it completely to  get an overview and then to consult
individual sections as needed.
     By applying  the principles described in  the field guide to his or her own
projects, the user will make certain that all data  collected will meet project needs.
Because that data will be of known and documented quality, others will be able to
use it with confidence too. And that is what quality assurance is all about.


     For additional information, contact:
                    Chief, Quality Assurance Support Branch
                Quality Assurance and Technical Support Division
           Atmospheric Research and Exposure Assessment Laboratory
                    U.S. Environmental Protection Agency
                 Research Triangle Park, North Carolina  27711
                                    USA

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                                  CONTENTS
SECTION                                                                   PAGE

   Acknowledgements	      Hi
   Disclaimer	      iii
   Foreword	      iv
   How to Use This Field Guide	      v

 1  PLANNING AND ORGANIZATION	     1-1

   1.1  PROJECT DESCRIPTION	     1-1
   1.2 ORGANIZATIONAL CHART	     1-1
   1.3 JOB DESCRIPTIONS  	     1-2
       1.3..1 Project Manager	     1-3
       1.3.2 Quality Assurance Manager 	     1-3

 2  PLANS AND REPORTS  	,.     2-1

   2.1  BEFORE DATA COLLECTION 	     2-1
   2.2 DURING DATA COLLECTION	     2-2
   2.3 AFTER DATA COLLECTION	     2-2

 3  STANDARD OPERATING PROCEDURES  	     3-1

   3.1  PURPOSE 	     3-1
   3.2 CONTENTS 	.•	     3-2
   3.3 HOUSEKEEPING DETAILS	     3-3

 4  PREVENTIVE MAINTENANCE 	     4-1

   4.1  EXAMPLES 	     4-1
   4.2 REQUIREMENTS  	     4-2

 5  SAMPLE COLLECTION, HANDLING, AND ANALYSIS 	     5-1

   5.1  SELECT SAMPLING SITES BASED ON DATA QUALITY NEEDS 	     5-1
   5.2 UNDERSTAND THE REASONS BEHIND THE PROCEDURES  	     5-1
   5.3 USE THE SAME CONDITIONS FOR STANDARDS AND SAMPLES  	     5-2
   5.4 USE QUALITY CONTROL CHECKS AND STANDARDS  	     5-2
   5.5 KNOW WHERE THE SAMPLES ARE AND BE ABLE TO PROVE IT  	     5-2

 6  DATA COLLECTION AND HANDLING	     6-1

   6.1  KNOW WHY THE DATA MUST BE COLLECTED f.	     6-1
   6.2 DOCUMENT EVERYTHING THOROUGHLY ,;	     6-1
   6.3 CALIBRATE INSTRUMENTS AND TEST SOFTWARE  	     6-2
   6.4 PRESERVE THE ORIGINAL DATA  	     6-2

                                                                     (continued)
                                     VII

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                                     CONTENTS
 SECTION                                                                        PAGE

 6  DATA COLLECTION AND HAN DUNG (Continued)	     6-1
    6.5  USE ONLY VALIDATED DATA	     6-2
    6.6  USE TABLES OR GRAPHS TO PRESENT SUMMARY STATISTICS 	     6-2
    6.7  LEAVE SOPHISTICATED DATA HANDLING TECHNIQUES TO THE STATISTICIANS ..     6-2
    6.8  BEWARE OF USING DATA COLLECTED FOR ANOTHER PURPOSE		..     6-3

 7  STATISTICAL TERMS AND DATA QUALITY INDICATORS	     7-1

    7.1  STATISTICAL TERMS  	     7-1
         7.1.1  Arithmetic Mean	     7-1
         7.1.2  Standard Deviation and Variance  	     7-1
         7.1.3  Geometric Mean	     7-2
         7.1.4  Geometric Standard Deviation  	     7-2
    7.2  DATA QUALITY INDICATORS 	     7-3
         7.2.1  Precision  	     7-3
         7.2.2  Accuracy  	;	     7-3
         7.2.3  Completeness 	     7-4
         7.2,4  Method Detection Limit	     7-4
         7.2.5  Representativeness	     7-5
         7.2.6  Comparability 	     7-5

 8  AUDITS  	     8-1

    8.1  DOCUMENTATION  	     8-1
    8.2  AUDIT TYPES	     8-2
         8.2.1  Technical Systems Audit  	     8-2
         8.2.2  Performance Evaluation Audit  	     8-2
         8.2.3  Audit of Data Quality  	     8-2
         8,2.4  Management Systems Audit  	     8-3
    8.3  AUDIT PROCEDURES 	     8-3
         8.3.1  PreauditActivities	     8-3
         8.3.2  Conducting the Audit	     8-4
         8.3.3  Preparation of the Audit Report	     8-5
         8.3.4  Postaudit Report Activities 	     8-5

 9  CORRECTIVE ACTION  	     9-1

    9.1  ROUTINE MEASUREMENTS  	     9-1
    9.2  MAJOR PROBLEMS	     9-1

10  BIBLIOGRAPHY 	.".	    10-1
                                        VIII

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                                         FIGURES
FIGURE                                                                              PAGE
 1-1   Example of Organizational Chart	     1-2
 9-1   Corrective Action Form 	     9-3
                                          TABLES
TABLE                                                                                PAGE
 3-1   Suggested Format for a Field or Laboratory
      Standard Operating Procedure	     3-2
 3-2   Tracking System for Standard Operating Procedures	     3-3
 3-3   Document Control Format 	     3-4
 5-1   Principles of Sample Collection, Handling, and Analysis	     5-1
 6-1   Principles of Data Collection and Handling	     6-1
                                            IX

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                                SECTION 1
                       PLANNING AND ORGANIZATION


     Projects brilliantly conceived  will not be brilliantly executed without good
planning and  organization.   Project success depends on  the leadership  and
organizational skills of the project manager. The manager not only must knowwhat
needs to be done, but also  must share that knowledge so that  all staff members
understand precisely how they fit into the "Big Picture."

1.1  PROJECT DESCRIPTION
     A detailed project description  forms the basis for all  other planning  and
organizational activities. The critical personnel and resource needs should arise from
the project description - and  not the other way around.
     The project manager and other key  personnel jointly  develop the project
description, which must contain  the following six components.
     •  What is going to be done
     •  Why it is necessary to do it
     •  Who will do it
     •  How it will be accomplished
     •  Where it will be done
     •  When it will be carried out

Unless all six are addressed  in  test and quality assurance (QA) plans, the project
description is incomplete and subject to misinterpretation. Section 2 describes these
components in more detail,  in the  context of reports required before, during, and
after data collection.

1.2  ORGANIZATIONAL CHART
     A clearly presented organizational chart is one of the most important products
of the planning process because it names all key individuals in charge of every major
activity of the project. Figure 1-1 shows a simple organizational chart.  If possible,
the names of all team members should be included; those of all supervisors must be.
                                    1-1

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All subcontractors must be listed too, with clear lines of reporting, to prevent the all-
too-common "floating subcontractor syndrome."
                                  Project
                                 Manager
                                  (Name)
       QA
     Manager
      (Name)
       Field
     Sampling
    Supervisor
      (Name)
Laboratory
 Analysis
Supervisor
  (Name)
  Data
 Analysis
Supervisor
  (Name)
                 Figure 1-1. Example of Organizational Chart


     Because the QA manager must be able to give completely unbiased advice on
data quality to  the  project manager, he  or  she should  be  organizationally
independent of the project manager  and  all other data collection and  handling
personnel. This special relationship is shown by a dotted line on the organizational
chart.

1.3  JOB DESCRIPTIONS
     Rather than list job responsibilities for each and every conceivable position, this
section examines the responsibilities of only two, the project manager and the QA
manager, in some detail.  Not every project will have a laboratory supervisor, for
                                   1-2

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instance, because it may entail only analysis of data already collected. But every
project will have a manager and a QA manager, even if they are one and the same
person on small projects.

1.3.1 Project Manager
     Like the captain of a ship, the project manager is ultimately responsible for
everything that happens in his or her project, including the QA necessary to achieve
the data  quality  required by the  project's sponsor.  The manager's  primary
responsibilities are liaison with the sponsor, planning, budgeting, staffing, and
overall coordination and review.  Just as no one would expect a ship's captain to
perform every operation  on  board,  no one expects  the project manager to do
everything single-handedly. That is why a staff is hired.  Frequently, the project
manager appoints a QA manager for assistance in developing and implementing the
QA/quality control (QC) needed to achieve the required data quality. The ultimate
responsibility for QA/QC, however, as for any other project function, still resides with
the project manager.

1.3.2 Quality Assurance Manager
     Two definitions will help in understanding the duties of the QA manager:
        QUALITY CONTROL is everything  YOU do to make certain  that
        your project is performing "up to specs."
        QUALITY ASSURANCE is everything you have SOMEONE ELSE do
        to assure you that your QC is being done "according to specs."

Thus, if the same individual who- performs the work also does the checking for
quality, that checking is quality control. Running duplicate samples in the laboratory
is a common QC procedure. If a different individual does the checking, that is an
example of quality assurance.  A project review by auditors from another company is
a typical QA activity.
     A review, however,  need not be  performed by a different company;  more
commonly,  it is done by the QA manager within the same organization  but
completely independent of the data- collecting staff. The QA manager protects the
project manager from poor quality data  that do not fulfill  project needs. Thus,
anything that affects data  quality comes under the purview of the QA manager.
     Most of the activities of a QA manager involve the review of project activities
and the preparation or review of reports. The mix depends on the wishes of the
                                    1-3

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project manager.  Frequently, the QA manager is assigned to prepare the QA plan,
review all other documents generated during the project, and carry out other tasks
specified by the project manager.
     The following sections  describe various project functions in detail:  reports;
standard operating procedures (SOPs);  preventive maintenance; sample collection,
handling, and analysis; data collection and handling; audits; and corrective action.
Because all impact on data quality, all must be addressed by the QA manager.
     Not addressed in these sections,  however, is one other important function
often assigned to the QA manager, that of training coordinator. Everyone must be
trained well enough to produce the highest quality of data needed by the project.
     A  common mistake is  to provide  training  only for field  and  laboratory
personnel, while neglecting the clerical staff and managers. Anything that affects
data quality is a suitable topic for training. Thus, the clerical staff must be trained
continuously to take full advantage of the ever-changing  enhancements in word
processing systems and managers need training on topics ranging from financial
information systems to handling personnel problems.
     Hiring staff with appropriate formal  education is only the first step in  building
a competent  team.   Next comes'on-the-job training under the  guidance of a
knowledgeable mentor who teaches the skills and nuances specific to the particular
task and organization.  Short courses, both on-site and off-site, develop well-defined
sets of skills in a specific area. Formal courses at a college or university  give a more
in-depth mastery of a subject.
     A combination of training activities  will be needed for most  projects.  Some
form of training will be needed for someone throughout the life of the project.
                                    1-4

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                                SECTION 2
                            PLANS AND REPORTS


     Anyone  "allergic" to  writing  anything  on  paper  will  not thrive  in
environmental data collection. Sponsors and supervisors require a steady stream of
reports, from  before a project begins until  after it is completed.  Writing a good
report  is not  that much different from writing a good newspaper article.  Both
processes concentrate on the six key principles of Who, What, Where. When, Why,
and How, but the relative emphasis given to each depends on where the report fits
into the life cycle of the project.
     Rare, indeed, is the project that spawns  only  one  report;  instead, many
different types are usually produced. The beginning of data collection in the field or
laboratory is the benchmark. Planning documents are written before data collection
begins, progress reports while it is under way, and final reports after it is completed.
Nobody wants to read a report that is top long and incoherent. Applying the six
principles can  prevent such a report from ever being written.  The best "mix of the
six" depends on whether the report comes before, during, or after data collection.

2.1 BEFORE DATA COLLECTION
     The most important project reports are those written before the first piece of
data is  collected. These planning documents include all six principles, but the most
important are Who, What, and How.  They specify, by name, Who is in charge of
What part of the project and How, in detail, the work will be accomplished.  Each
and every part must be included because success of the project depends on how well
all of the parts fit together.  A simple organizational chart is mandatory.  If the
relationships are difficult to draw, they will be even more difficult to execute.
     Examples of typical planning documents include the following.
     •   Data quality objectives reports
     •   Work or test plans
     •   Quality assurance plans
     •   Site selection, sampling, and analytical procedures (if not included in
        the work plan)
     •   Standard operating procedures
                                    2-1

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     •  Data handling protocols
     •  Corrective action plans
     •  Others, as necessary
     Although Who, What, and How predominate, Where, When, and Why cannot
be neglected.  Geographical location (the Where) can be a critical variable in field
work.  The When includes not only the specific hours,  days, months, or  years of
project duration but also such important topics as seasonal and diurnal variations.
     Although the Why is more subtle than the other principles, knowing Why the
data have to be collected is critical to the success of any project. The reason is quite
simple:  data must be collected for a purpose. Different  purposes require different
data collection plans.  Project planners can devise the best one only if they know the
end uses of the data. Planning documents must dearly state the purposes behind
data collection, so that both current and future users  understand the limitations on
using the data for decision making. They also establish  the competence of the
project team to do  the job right the first time, on  time,  and within budget.  They
describe what is anticipated and thus serve as yardsticks by which to  measure
progress.
     The QA manager reviews  and  approves the QA  plans, which include key
sections from many other planning documents, but the project manager must sign
off on all documents. Although each staff member is responsible for the quality of
his or her part of the project, the project manager is  responsible for the quality of
the entire undertaking.

2.2 DURING  DATA COLLECTION
     Progress re ports, the most commonly written reports during the data collection
phase of a project,  continuously answer  the question, "How are we doing?" The
standards used are the ones previously stipulated in the planning documents. Audit
reports and  corrective action reports are also prepared in this  phase.   Audits,
whether performed internally or by outside organizations, assess What is being done
and How well. Whenever corrective action is taken, the  report describes What the
problem was and How it was solved.

2.3 AFTER DATA COLLECTION
     If planning  and progress reports are well prepared, writing  the final report
should not be an overwhelming burden.  Its purpose  is to summarize and analyze -
                                    2-2

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to say What happened and Why, but not to meditate on every single data point.
Appendices and references to earlier reports can take care of that.
     The final report, which frequently mirrors the test or work plan in sequence
and approach, covers all six principles. It is also a self-audit, assessing How well the
standards spelled out in the planning documents were met, and clearly explaining
any limitations on data use for both present and future users. This careful analysis in
a final report for one project may also serve as a springboard to a new one in which
currently unresolved problems may be solved.
                                    2-3

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                                SECTION 3
                    STANDARD OPERATING PROCEDURES


     When should a manager decide that an SOP needs to be written? The answer is
deceptively simple:  as soon as the  procedure becomes standardized - and  not
before.  The argument that no procedure is ever standardized, however, is used all
too frequently only to avoid putting anything on paper.
     Although the time and effort spent in preparing an SOP can be significant,
there are important long-term benefits. No longer will the same procedure have to
be described  again and again  in test plans, QA  project plans, audits, and other
reports. Instead, it can  be incorporated by reference, with a copy attached to the
report. But saving data, not merely saving time, is the main reason for preparing an
SOP. Data collected using fully documented procedures have much higher credibility
and defensibility. Because well-written SOPs focus on routine operations, their users
can concentrate primarily on nonroutine problem solving.

3.1  PURPOSE
     An SOP  is written so  that the procedure will be performed consistently by
everyone, every time.  Deciding whether a particular procedure is a candidate for an
SOP is helped by answering two questions:
     •  Does the procedure significantly affect data quality?
     •  Is the procedure repetitive or routine?
Preparing an SOP is indicated if the answer to both  questions is YES.
     Targeting the proper audience can be the most difficult task.  Obviously, the
SOP should be written at  a level of detail  appropriate to  the  end users.  If
backgrounds of the usersare unknown, target the SOP for a "newhire," atechnician
with at least two years of college and one year of experience in the appropriate
field. This approach  usually ensures that the SOP has enough detail without
becoming overwhelming.
     Few routine laboratory or field projects can be described  completely in just one
SOP. Several will be needed, and deciding how best to divide the topics will take
careful planning.  In general, an SOP for each of several smaller segments is much
better and easier to write than one large SOP for an entire operation.
                                    3-1

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3.2 CONTENTS
     Table 3-1 shows a suggested format for an SOP, including numerous examples

of items that could be included in each section. The examples shown are only a few

of the many that  could  be covered,  depending on  the  particular procedure.

Occasionally, deciding whether an item belongs in one section or another can be a

problem. The important thing is to put it somewhere, rather than leave it out.


   TABLE 3-1.  SUGGESTED FORMAT FOR A FIELD OR LABORATORY STANDARD
              OPERATING PROCEDURE



                          A. TECHNICAL SECTIONS
             Section
               Typical Examples
   1.  Scope and Application


   2.  Summary of Method




   3.  Definitions

   4.  Interferences

   5.  Personnel Requirements


   6.  Facilities Requirements


   7.  Safety  Precautions



   8.  Apparatus


   9.  Reagents/Materials
Overview outjining purpose, range, sensitivity,
acceptance criteria

Overview describing sampling criteria and
analytical methods, method and instrumentation
detection limits, reasons for deviations from
Federal Register methods

All acronyms, abbreviations, specialized terms

Sources of contamination

Educational level and training of intended SOP
users, number of operators required

Mobile analytical laboratory, air conditioning,
types of electricity, fume hood

Types of respirators, carbon monoxide monitors,
special handling procedures; hazard warnings,
placed immediately BEFORE relevant part of text

Larger items such as a meteorological tower, audit
device, pH meter, gas chromatograph

All chemicals used, including distilled or deionized
water; grades of reagents; materials include
smaller items such as filter paper, boiling chips,
tubing, electrical wiring
                                                              (continued)
                                   3-2

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 TABLE 3-1.   SUGGESTED FORMAT FOR A FIELD OR LABORATORY STANDARD
             OPERATING PROCEDURE (Continued)
                        A. TECHNICAL SECTIONS
           Section
               Typical Examples
10.  Samples/Sampling
    Procedures

11.  Calibration/
    Standardization

12.  Analysis Procedures
13.  Calculations



14.  Data Reporting

15.  Corrective Action

16.  Method Precision and
    Accuracy
Sample preparation, collection, storage, transport,
and data sheets

Preparation of standards and standard curves,
frequency and schedule of calibrations

Standard and custom-tailored methods for all
analytes in all matrices

Data reduction, validation, and statistical
treatment, including confidence levels and
outliers

Selection criteria, format, equations, units

Criteria for initiation;  individuals responsible

Tabular or narrative summary
                    B. QUALITY CONTROL SECTIONS
           Section
               Typical Examples
 1.  QC Checks



 2.  QC Controls
Precision, accuracy, repeatability, reproducibility,
blanks, spikes, replicates, selection criteria, and
frequency summarized in tables

Audits, notebook checks, blind samples; control
charts and graphs; actions to be taken when QC
data approaches or exceeds QC limits
                        C. REFERENCE SECTION
                          Standard reference methods, reports, SOPs,
                          journal articles; avoid citing unpublished
                          documents
                                  3-3

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3.3 HOUSEKEEPING DETAILS
     Once an organization commits to SOPs, many new SOPS will be prepared in the
same length of time  it took to do  the first one.  And, as refinements become
available, older SOPs will need to be updated, preferably without having to rekey
the entire text.  A tracking system  is a  must in  handling  this ever-increasing
workload.
     Initially, a simple system shown in Table 3-2 will be sufficient. The title should
be as specific as possible; generic titles such as "Atmospheric Monitoring" usually are
too broad to be truly descriptive of the SOP.

     TABLE 3-2. TRACKING SYSTEM FOR STANDARD OPERATING PROCEDURES

     General Information           Specific Example

     SOP Number                  SOP-25
     Title                         Site Selection Criteria for Meteorological
                                 Monitoring at Heavily Forested Areas
      Date                        July 1,1992


     To accommodate later revisions, however, a more detailed "document control
format" is frequently used for tracking documents from the very beginning of the
SOP program. The information shown in Table 3-3 is placed on the upper right-hand
corner of each page.
                  TABLE 3-3. DOCUMENT CONTROL FORM AT

     General Information           Specific Example

     SOP Number                  SOP-25
     Section Number               Section 3
     Revision Number              Revision No. 1
     Date of Issue                  July 29,1992
     Page	of	      Page 5 of 12
                                   3-4

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The original version is always labeled  as Revision 0.  If, for example, page 5 of
Sections needs to be updated, the  changes are made and issued  as Revision 1,
together with instructions to replace page 5 of Revision 0 with the new page 5 of
Revision 1. Thus, the value of a ring-binder format becomes obvious.
     A complete set of SOPs is stored for reference in one place, usually the office of
the QA manager.  The most important copies, however, are the dog-eared, coffee-
stained ones in the field and laboratory; SOPsare meant to be used, not just filed.
                                    3-5

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                                SECTION 4
                        PREVENTIVE MAINTENANCE


     Because  breakdowns and repairs use up the time needed for preventive
maintenance,  buying reliable equipment is the best way to guarantee enough time
for planned maintenance. Reliable equipment, which does the job right (almost)
every time, has fewer breakdowns and requires less time for troubleshooting.
     Several steps are involved in getting reliable equipment.
     •  Procurement:  Ordering the "right stuff"
     •  Inspection:    Checking that everything came in
     •  Control:       Knowing its whereabouts at all times
     •  Testing:       Proving it does what it should do
     •  Training:      Teaching the operators how to use it
Once these steps are  carried  out, the equipment and the project should run
smoothly, with little downtime for repairs.
     Merely setting up a detailed schedule  of  preventive maintenance is not
enough; actually following it is the critical step. Auditors pay particular attention to
whether planned  maintenance activities were  indeed  performed.    Because
individual air  pollution and meteorological monitoring methods include detailed
descriptions of required preventive  maintenance, this section focuses only on
features common to all methods.

4.1 EXAMPLES
     Many  types of preventive maintenance  are  needed to achieve good data
quality.  The following are only a few examples.
     •  Clean the sample manifold
     •  Replace vacuum pump filters
     •  Lubricate pump box blower motors
     •  Change data tape
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Each activity by itself may seem insignificant, but, when coupled with dozens of
others, the net result is a program with more reliable data, less downtime, and much
less cost in dollars, time, and grief.
4.2 REQUIREMENTS
     A good preventive maintenance program must include the following items.
     • Short description of each procedure
     • Schedule and frequency for performing each procedure
     • Supply of critical spare parts on hand, not merely on a list
     • List  of maintenance  contracts  for  instruments  used  in critical
       measurements
     • Documentation showing that maintenance has been performed as
       required by the maintenance contract, QA project plan, or test plan
     For convenience, summarize as much of this information as possible in tables.
                                   4-2

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                                SECTION 5
               SAMPLE COLLECTION, HANDLING, AND ANALYSIS


     At first glance, covering sample collection, handling, and analysis in one section
sounds like a tall  order.  But  because sampling and  analysis share so  many
characteristics - calibration, contamination, and sample custody, to mention only a
few - considering them as a unit is logical.   Because other sections of  the  QA
Handbook describe individual methods in greater detail, this one can examine  the
underlying  principles common to all.  These  principles  are first  summarized in
Table 5-1, then discussed briefly in the following sections.

              TABLE 5-1.  PRINCIPLES OF SAMPLE COLLECTION,
                         HANDLING. AND ANALYSIS

            1. Select Sampling Sites Based on Data Quality Needs

            2. Understand the Reasons Behind the Procedures

            3. Use the Same Conditions for Standards and Samples

            4. Use Quality Control Checks and Standards

            5. Know Where the Samples Are and Be Able to Prove It

5.1 SELECT SAMPLING SITES BASED ON DATA QUALITY NEEDS
     Although convenience and previous use are attractive features of any sampling
site, the driving force behind site selection must be the data quality needs of  the
project. If a site cannot provide suitable samples, it is useless for the project. Once
project needs  are specified, a  statistician should  be consulted for  help in  site
selection; sampling  strategy; and the type, frequency,  and  number of  samples
required to attain the desired level of confidence in the results.

5.2 UNDERSTAND THE REASONS BEHIND THE PROCEDURES
     All procedures should explain  why certain steps are used, not just how to
perform them.  For example, here are only a few of many precautions taken to
prevent contamination during the  cleaning  and handling  of  air  monitoring
equipment and samples:   glass fiber, quartz,  or Teflon  filters are handled with
                                   5-1

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tweezers,  not bare  hands;  clean cotton gloves, not surgical rubber gloves with
potentially contaminating powder, are also used to handle the filters; dedicated or
disposable glassware is used for standards; and glassware for anion analysis is  not
cleaned with soap, which could leave a residue containing anionic contaminants, but
with multiple rinsings of deionized water.  Similar explanations should be a part of
all procedures, especially SOPs. The more reasons that are given, the more likely the
procedure will be understood, appreciated, and followed.

5.3 USE THE SAME CONDITIONS FOR STANDARDS AMD SAMPLES
     Simple as this admonition  sounds, it goes unheeded all too frequently in both
field and  laboratory. For  example,  suppose  the  expected  concentration of an
analyte is around 200 ppm.  Even a careful calibration in the 0 to 20 ppm range is
meaningless at the 10-fold higher concentration. Calibrations must be made over
the full span  of expected concentrations.  Gas cylinders  and regulators need to
equilibrate for at least 24 hours to adjust for changes in temperature and altitude
before being  calibrated  and used.  Leak  checks must be made  under the same
pressure to be used during data collection. Only when standards are subjected to
the same treatment as the samples can meaningful data be obtained.

5.4 USE QUALITY CONTROL CHECKS AND STANDARDS
     Quality control checks  and standards show when the system is out-of-control
and corrective action is needed.   High-quality  precision and accuracy data  are
derived from blanks, replicates,  spikes, standards, and other QC checks.  Calibration
standards, which should  be  verified regularly,  are also used throughout sampling
and analysis.  To avoid the possibility of being precise but not accurate, QC check
samples should not be the same  ones used for calibration standards.

5.5 KNOW WHERE THE SAMPLES ARE AND BE ABLE TO PROVE IT
     Proof is  especially important  for high visibility projects where litigation  is a
distinct possibility. Strict sample custody procedures protect against losses, mixups,
accidental  contamination, and tampering. Although good sample labels, custody
seals, and tracking sheets are essential for maintaining sample integrity, dedicated
sample custodians are the most important factors. Chain-of-custody forms must be
used for all sample transfers, not only between field and laboratory, but also from
one field (or laboratory) group to another. Projects of lesser visibility also benefit
from similar, though less stringent, procedures.
                                    5-2

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                                SECTION 6
                     DATA COLLECTION AND HANDLING


     Entire books have  been written  on data collection, validation, reduction,
analysis, storage, and retrieval, yet this chapter covers the same topics in only a few
pages. How? By focusing on the fundamental principles common to many of these
steps in the data-gathering process. These principles are first summarized in Table 6-
1, then discussed briefly in the following  sections.

             TABLE 6-1. PRINCIPLES OF DATA COLLECTION. AND HANDLING
      T.   Know Why the Data Must Be Collected
      2.   Document Everything Thoroughly
      3.   Calibrate Instruments and Test Software
      4.   Preserve the Original Data
      5.   Use Only Validated Data
      6.   Use Tables or Graphs to Present Summary Statistics
      7.   Leave Sophisticated Data Handling Techniques to the Statisticians
      8.   Beware of Using Data Collected for Another Purpose
6.1  KNOW WHY THE DATA MUST BE COLLECTED
     How data will  be used dictates how they  must be collected.  Consider, for
example, just a few of the many questions to be answered before beginning air
monitoring studies:  How many sites?  Are all sites equally important, or are some
more important than others?  Will sampling be continuous or episodic? Over what
time period?  How many samples are needed?  Statistical expertise is required to
answer questions like these and to design a cost-effective data collection program
that will yield data good enough for confident decision making.
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6.2 DOCUMENT EVERYTHING THOROUGHLY
     From data collection through data use, the motto is "Write it down!" Nothing
enhances the credibility of a data collection program more than thoroughly detailed
documentation.  Data usability, for future as well as present applications, depends
on how well all of the details are recorded.

6.3 CALIBRATE INSTRUMENTS AND TEST SOFTWARE
     Improperly  calibrated  instruments frequently  cause  poor  results.   All
calibrations must be directly traceable to a standard of recognized accuracy, such as
those from the National Institute of Standards and Technology. All calibrations must
also include a .zero-span check covering the full  range of concentrations expected
during data collection. Linearity of instrumental response must be demonstrated,
not  assumed.  Software, too,  must  be tested  thoroughly, to verify that it is
performing as  planned.  If not, data collection, validation, reduction, and analysis
can be jeopardized.

6.4 PRESERVE THE ORIGINAL DATA
     Whatever is done in data processing, especially in data reduction, the original
data must be preserved and all  derivative data must be directly traceable to them.
All data transformations must also be preserved. Back-up files, whether computer or
manual, are mandatory. Only protected data allow a second chance for analysis if
critical problems arise on the first attempt.

6.5 USE ONLY VALIDATED DATA
     To catch data errors and biases at the earliest possible stage, data validation is
used to compare each data point against prespedfied criteria.  Whether performed
by humans or computers, during or after data collection, it asks the question "Is this
specific piece of data  reasonable?" Only validated  data  can proceed to the next
step. Abnormally high or low values  cannot be  discarded automatically.  Instead,
they must be  examined  statistically to determine  if they truly fall outside the
expected range. They may be real values on the tails of  a distribution curve or they
may be invalid as  shown by standard tests.  Or,  as  sometimes happens, their
occurrence is simply  unexplainable. Decisions to use or discard suspect data can be
made only after these validity checks.
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6.6 USE TABLES OR GRAPHS TO PRESENT SUMMARY STATISTICS
     Air monitoring studies, particularly those with multiple stations and automatic
recording devices, produce vast quantities of data impossible to comprehend in the
raw state. Trends become apparent only after data are reduced and tables or graphs
are used to present summary statistics. Graphs are frequently more informative than
tables for presenting numerical data because  patterns and magnitudes are easier to
comprehend. Statistics used most often are the number of observations, means, and
Standard deviations, with others included  as needed. Presenting numerical data in
narrative  form  throughout  a  report  is  a   poor  alternative  because  the
interrelationships among scattered data are easily lost.

6.7 LEAVE SOPHISTICATED DATA HANDLING TECHNIQUES TO THE STATISTICIANS
     Amateur statistics can be nearly as dangerous as amateur surgery.  Powerful
software packages are widely available for data validation  and analysis, but using
them without a  thorough understanding  of  their limitations  and underlying
statistical assumptions almost guarantees severe over- or under-interpretation of the
data.  Key topics such  as graphical display of data,  identification  of  outliers,
regression analysis, analysis of variance, and how to handle zero or nondetected
data require advanced statistical techniques.  To extract the maximum information
from a data  set, statisticians must participate in  the design  phase  too, rather than
just the data analysis.

6.8 BEWARE OF USING DATA COLLECTED FOR ANOTHER PURPOSE
     The temptation to use existing data  rather than collect new data is especially
strong when budgets are tight. Succumbing to that temptation can be disastrous,
unless  all  of the restrictions  applicable to the  previous  data  are known  and
documented.
                                    6-3

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                                SECTION 7
             STATISTICAL TERMS AND DATA QUALITY INDICATORS


     Previous sections have discussed data qualitatively.  This section summarizes
how data  are  described  quantitatively  by statistical  terms  and  data  quality
indicators.  Definitions and equations are accompanied by brief descriptions of the
conditions when the specific terms  should or should not be  used.  For  ease  in
reference, the equations are numbered at the right of the page.

7.1  STATISTICAL TERMS
     In Volume 1, Principles, of the first edition of the Quality Assurance Handbook
for Air Pollution Measurement Systems, there were almost 200 pages dealing with
statistics. Here they have been condensed to less than 6, which no doubt will cause
consternation to some.  But this is a  field guide,  and a field guide covers only the
most important things.

7.1.1 Arithmetic Mean
     Whenever data plots  show a roughly symmetrical  (bell-shaped or  normal)
distribution, the average value 'is called the arithmetic mean. It is simply the sum of
the individual values divided by the number of values in the data set:

                              *=-£*                                   ™
                                  n   *
where
     X  =  arithmetic mean
     n  =  number of values
     Xi  =  individual data values
     Calculating the arithmetic  mean without first plotting the data to  verify a
symmetrical distribution can lead to faulty data interpretation. See Section 7.1.3 for
a discussion of when the arithmetic mean is particularly inappropriate.
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7.1.2 Standard Deviation and Variance
     The standard deviation, used to measure the dispersion or spread of data, is
defined as follows:
                         8 =
                                   n-l
where
     s  = standard deviation
     Xi = individual data values
     n  = number of values
The square of the standard deviation, called the variance, is another frequently used
measure of data dispersion.
     Programmable calculators require only that the  raw data be entered in  a
specified  manner.  All computations are then performed automatically. Thus, in
actual practice, it is no longer necessary to manually compute the tedious squarings
required by Equation 2.

7.1.3  Geometric Mean
     Plots of air  monitoring data frequently show a skewed,  nonsymmetrical
distribution.  For these cases, the geometric mean rather than the arithmetic mean is
a better measure of the average value. The geometric mean is defined astheantilog
of the average of the logarithms of the data values:

                        Xg  = antilogb (- S to*^)                            (3)
where
     Xg   = geometric mean
     n    s number of values
     logbXi ~ logarithms of individual data values
Either common  logarithms (log 10) or natural logarithms (loge) can be .used  to
calculate the geometric mean. The necessary tables of logs and antilogs are found in
mathematics and statistics textbooks and  in standard reference books such as the
Handbook of Chemistry and Physics. Software programs are also available.
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7.1.4 Geometric Standard Deviation
     The geometric standard deviation, used when data a re distributed lognormally
rather than normally, is defined as follows:
                                          (2 log Xf
                          .,  1 /      '       n                           W
                   s = antihg  / -"--•'       	-•
                             /        n-l
where
     sg    -  geometric standard deviation
     logXi =  logarithm of individual data values
     n     =  number of values

7.2 DATA QUALITY INDICATORS
     "How good are the data?"  Because project success depends on the answer,
data quality is used as an  indicator of project performance. Six terms frequently
used  to  describe  data  quality  are precision, accuracy,  completeness,  method
detection limit, representativeness,  and comparability.  Each  is defined in the
following sections, but, as shown there, the definitions are not always quantitative
or universally accepted. Nevertheless, the definitions do provide a common ground
for discussions on data quality. '

7.2.1 Precision
     Precision is a measure  of agreement among two or more determinations of the
same parameter under similar conditions. Two terms used to describe precision are
relative percent difference  (RPD) and relative standard deviation (RSD) (also called
the coefficient of variation), depending  on whether two or more than two replicates
are used.                           .
     If precision is calculated from duplicate measurements, use
                                                                         (5)
where
     RPD  = relative percent difference
     Xi    = larger of the two values
     X2    = smaller of the two values
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     If precision is calculated from three or more replicates, use RSD rather than
RPD:
                            RSD = 100 (s/X)                               W)
where
     RSD s  relative standard deviation
     s    =  standard deviation (see Equation 2)
     X    =  mean of replicate analyses
For two replicates, RSD = RPD/^/2

7.2.2 Accuracy
     Accuracy is the degree of agreement between a measured value and the true,
expected, or accepted value. It is frequently expressed in terms of percent recovery
(%R)  whether Standard  Reference Materials (SRMs) or spiked samples (known
concentrations of test materials added to samples) are used.
     If SRMs are used, accuracy is expressed as follows:
where
     %R    = percent recovery
     CM    = measured concentration of SRM
     CSRM  = actual concentration of SRM

     When spikes are added to samples, %R is calculated as follows:
                                    -eye                              (8)
                                   t    u  ia
where
     %R = percent recovery,
     Cs  = measured concentration in spiked aliquot
     Cu  = measured concentration in unspiked aliquot
     Csa = actual concentration of spike
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     When measurement systems for ambient air monitoring are audited, accuracy
is expressed as follows:
                         fipz? = ioo(C -cvc                             (9)
                                    m   a  a
where
     RPD = relative percent difference
     Cm  = measured value of audit standard
     Ca   = actual value of audit standard

7.2.3 Completeness
     Completeness is a measure of the amount of valid data obtained compared
with that expected to be  obtained under normal operating conditions.  It is defined
as follows for all measurements:
                            %C=100(n/n)                               (10)
                                     ,11
where
     %C =  percent completeness
     nv  -  number of valid measurements
     n   =  total number of planned measurements
The above equation is a  simplified definition. In actuality, %C must be tied to the
specific statistical level of confidence needed for decision making.  Obviously, a
decision needing, say, a 99%  confidence level needs more valid  data than one
requiring only an 80% level. A statistician should be consulted for guidance on this
topic.

7.2.4 Method Detection Limit
     The method detection limit (MDL), the lowest concentration of an analyte that
can be  measured by a given  procedure, is as much  a statistical  as an analytical
concept, and there are numerous definitions.  One definition favored by statisticians
is as follows:
where
     MDL          =  method detection limit
     5             =  standard  deviation  of  the  replicates  at the  lowest
                      concentration
     t(n-i,i- a = 0.99) =  Student's t-value appropriate to a 99% confidence level
                      and a  standard deviation  estimate with rc-1 degrees of
                      freedom
                                    7-5

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     Field and laboratory personnel frequently use a much simpler version:
                              MDL = W)(s)                                 (12)
where
     MDL =   method detection limit
     N   =   a multiplier between Band 10
     s    =   standard deviation

7.2.5 Representativeness
     Representativeness expresses how closely a sample reflects the characteristics
of the  substance for which it is a surrogate.  Ideally, the representativeness of the
sample would be 100%; practically, however, the quantitative value is rarely known.
Every effort is made to ensure that the sample is truly representative, by using such
techniques as thorough mixing to obtain homogeneity, duplicate analyses, and such.
Problems with uniformity are not so great with air samples as with liquids or solids
because of the nature of the air media.

7.2.6 Comparability
     Comparability refers to how confidently one data set can be compared with
another. Ideally, all data would be completely comparable, so comparability would
be 100%.  Practically, because the data were collected under different conditions
and for different purposes, comparing data sets must be done very cautiously.  See
Section 6.8 for more details.
                                    7-6

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                                SECTION 8
                                  AUDITS


     Managers need to  know how well things are going on their projects.  Is a
particular project performing according to specifications? An audit, a management
tool used to answer that question, is a formal, detailed study of one or more aspects
of a project by independent auditors.  The project is not audited at random, but
against specific criteria previously determined  by  the  manager to be  critical to
project success.   Many  audits are  held shortly  after the  project has become
operational, to detect and correct problems  before  they  affect  data quality
adversely.
     A cooperative  effort  of auditors and  auditees  (to  gather the needed
information efficiently and completely) gives the best results.  There is no room for
"Gotcha!" in any audit.
     The audit report describes any problems found and may suggest appropriate
corrective actions.  Equally important,  it  also covers those aspects  that  were
operating as specified. Thus, the manager learns what is going well, not just what
needs attention.
     An audit focuses on one or more of the following components of a project.
     •  People
     •  Procedures
     •  Equipment
     •  Data
     •  Documentation
The success of any project depends  on how well the people follow procedures,
operate  equipment,  collect and interpret data, and  carefully  document their
activities.

8.1 DOCUMENTATION
     A poor paper trail can  lead to even poorer audit results.  During their on-site
visit, auditors can observe only the current operations first hand; for previous ones,
they must depend on written documentation. Verbal assurances from the auditees
                                    8-1

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are not enough to convince the auditors that proper procedures had, indeed, been
followed. Only clear, complete, written documentation can do that.

8.2 AUDIT TYPES
     The  QA project plan  is the basis for all four audit types described  in the
following sections.   Although the  audit  is used to  determine whether criteria
stipulated in the plan are being met, any. additional findings are also included in the1
report.              .                                  .

8.2.1 Technical Systems Audit
     The  technical  systems audit, a qualitative  on-site evaluation  of an entire
measurement-system, is used frequently in an air monitoring program. It looks at
everything - all facilities, equipment,  systems, record  keeping,  data validation,
operations, maintenance, calibration procedures, reporting requirements, and QC
procedures.  Findings from this global review can then be used to focus efforts on
specific parts of the  measurement system that need attention to obtain the desired
data quality. Systems audits are normally done immediately before, or shortly after,
measurement systems are operational, and should also be performed on a regularly
scheduled basis throughout the lifetime of the project.

8.2.2 Performance Evaluation Audit
     The  performance evaluation audit, also  used frequently in air monitoring
studies, is a  quantitative evaluation of a part or parts of a measurement system,
including  all associated data acquisition and reduction procedures.  It involves the
analysis of a reference material of known value or composition and  critical to the
success of the project. The reference material is usually disguised as a typical project
sample so that the operator or analyst will not give it  any undue special attention.
Long-term projects  require regularly scheduled performance audits.  Although a
performance audit may show that a system is out-of-control, a systems audit may be
needed to pinpoint the cause and target the corrective action.

8.2.3 Audit of Data Quality
     An audit of  data quality exhaustively evaluates the methods used to collect,
interpret,  and report data quality. The following criteria are evaluated against the
QA project plan and other pertinent guidelines:
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     •  Recording and transfer of raw data
     •  Calculations, including equations used for presentation of data
     •  Documentation of data-handling procedures
     •  Selection and discussion of data-quality indicators, including precision,
        accuracy, representativeness, comparability, and completeness

8.2.4 Management Systems Audit
     A management systems audit (or review) examines the structures and processes
used by management to achieve the desired  data  quality.   Broad in scope, it
frequently covers multiple projects within a  larger program.  Laboratory and field
personnel rarely participate directly in this type of audit.

8.3 AUDIT PROCEDURES
     Detailed planning is the essence of any good audit.  Without it, the resulting
chaos causes short tempers and sloppy work; with it, the ensuing cooperation fosters
harmony and success. In addition to auditor and auditee, a third party, the sponsor,
plays a key role.  As commonly occurs in government and industry, a sponsor funds
the project and  requests the  audit.  The following  sections describe  critical
interactions among these three,parties. If only auditor and auditee are involved, the
audit procedure is simpler because the auditor assumes the functions of the sponsor.

8.3.1 Preaudit Activities
     Decisions made by the sponsor in the preaudit planning phase determine the
course  of  the audit.   As shown in  the following summary, all  three  parties
communicate  extensively to ensure that there will be no hidden agendas and no
surprises.
     A. RESPONSIBILITIES OF THE SPONSOR
        The sponsor's project manager and  QA manager decide on  the following
     audit details.
       (1) Intent, scope, cost, and frequency of auditing activities
       (2) Parts of project to be  audited
       (3) Audit schedule
       (4) Qualifications needed for auditors
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   (5) Action to  be taken by auditors  if they discover out-of-control
      situations
   (6) Potential for organizational conflict of interest between auditors
      and auditees
   (7) Selection of proposed auditors

Of these items, (5) is the most critical. Out-of-control situations can arise.
in the field, the laboratory, or in data handling operations: What shoufd
the auditors do?  Correct the problem  immediately and cite it in the
report? Take no corrective action and cite the problem in the report?
Use some other approach? Whatever the answer, it must be spelled out
and agreed upon by all parties before the audit can begin. The sponsor's
project manager then notifies the auditee of the purpose and scope of
the audit and requests comments on the following items.
   (8) Acceptability of preceding points (1) through (7)
   (9) Actual or perceived, current or potential, conflicts of interest
  (10) Necessity for a preaudit, face-to-face meeting of auditor, auditee,
      and sponsor
  (11) Location, date, and time of meeting, if requested in item (10)

B. RESPONSIBILITIES OFTHE AUDITEE
   The auditee or the sponsor's project manager then sends the following
information to the auditor.
   (1) Details of project operation (SOPs, site locations, QA project plan,
      operator proficiency and training, sampling schedule, etc.)
   (2) Name of person to contact for additional information

C. RESPONSIBILITIES OF THE AUDITOR
   The auditor responds by sending the following information to the auditee.
   (1) Standard operating procedures to be used in the audit
   (2) Parts of the project to be audited, and by whom
   (3) Qualifications of the auditors
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       (4) Name of person to contact for additional information

       (5) Authority and responsibility of the auditors to take action if a
          problem is found
         Note:  All parties must address all of the above points and come
                to an agreement on them before the audit begins.
8.3.2 Conducting the Audit
     The audit should proceed smoothly because of the preaudit agreements. Steps

in the actual audit are as follows.

     A.  The audit is conducted according to the preaudit agreements. If any
        party feels that changes are needed, it must then notify all other
        parties and gain approval before deviating from the agreements.

     B.  Auditor  informs  auditee  (on  site  or by  phone/fax/E-Mail,  as
        appropriate) of preliminary audit findings and recommendations for
        corrective action.

     C.  Auditor tries to resolve any disagreements before leaving the site.

     D.  If disagreements between auditee and auditor  cannot be resolved,
        auditor contacts sponsor's project  manager, QA manager, or the
        auditee's project manager, depending on the preaudit agreements.

     E.  In  the  audit  report, the auditor  includes  the  outcome  of  this
        postaudit discussion and identifies still unresolved disagreements.


8.3.3 Preparation of the Audit Report
     An audit report is the  last step in the auditing process.  As shown in the

sequence below, the auditee has significant input

     A.  Auditor briefs sponsor's project manager and QA manager on the
        audit findings.

     B.  Auditor prepares draft audit report and submits it, and all supporting
        data, to the QA manager.

     C.  The QA manager determines if the report meets the sponsor's
        guidelines for clarity, accuracy, completeness,  etc.  (If not, the report
        is returned for revision.)

     D.  Once the draft report is accepted by the QA manager, it is sent to
        both the sponsor's project manager and to the auditee.
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     E.  The sponsor's project manager and the auditee send their written
        comments to the QA manager, not to the auditor.
     F.  After reviewing the comments, the QA manager discusses them with
        the auditor, and, if necessary, arranges a meeting of all appropriate
        parties.  If disagreements remain, the QA manager will recommend
        to the sponsor a course of action such as
       (1)  Repeat the part of the audit in question;
       (2)  Issue the audit  report, but include a statement that the auditee
           has questioned a particular audit finding; or
       (3)  Delete the item(s) under question from the report.

     If disagreements still remain, the sponsor's project manager receives the final
     report only after the sponsor has approved the proposed course of action. If
     there  are no disagreements, the QA manager releases the final report to the
     sponsor's project manager, with a copy to the sponsor and the auditee.

8.3.4 Postaudit Report Activities
     The audit report is not the end of the audit.   If major  problems  were
discovered, the auditee  must institute corrective action (see Section 9).  If the
problems were  critically  compromising to data quality,  a special follow-up  audit
might be necessary to verify that the corrective action was adequate to allow data
collection to resume. Corrective actions for minor problems are checked at the next
regularly scheduled audit.
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                                SECTION 9
                            CORRECTIVE ACTION
     Few projects run perfectly; fewer still automatically correct the many problems,
large and small, that inevitably arise.  For that, competent, responsible people are
required. Both assigning and accepting responsibility  are critical to the success of
any corrective action plan.

9.1  ROUTINE MEASUREMENTS
     Many corrective action plans are already embedded in the QC checks used for
all routine measurements.  Acceptance criteria or tolerance limits are contingency
plans that state that "If this happens, then WE will do  the following:". The "WE"
cannot be  left unspecified in the corrective  action  plan; a person  or  persons
(chemical analyst, stack sampling  operator, etc.) must be designated by title or
function, and, if possible,  by name.  A statement such as "If  this measurement
activity is out of control, all sampling will be stopped" is unacceptable because it
does not indicate who is responsible for making that decision.
     Field and laboratory personnel will be able to make most of the corrective
actions needed.   They must then document these  actions in the  appropriate
notebooks or logbooks so that a record exists of the problems encountered and the
solutions discovered.

9.2  MAJOR PROBLEMS
     Sometimes, however,  problems occur that field and laboratory staff members
are  unabJe  to solve,  despite their best efforts. These problems can arise during
routine operations or as a  result of performance evaluation and technical systems
audits.  Staff members must immediately  bring these  major problems to the
attention of their supervisor or  other individuals designated in their test or QA
project plans to handle the problem.  Because many individuals could  become
involved  in the  corrective  action, the  notification is best done by  a  standard
corrective action form, a copy of which is shown in Figure 9-1.
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                      CORRECTIVE ACTION FORM
Project Title
                                       Project No.
I.    REQUEST FOR ASSISTANCE
              A
To:
From:
              B
    Date-
Signature:
     Problem: (1) Nature
             (2) Suspected Cause
II.
PROPOSED CORRECTIVE ACTION
To:       B
From:     A
                                         Date:
                                     Signature:
     Suggestion:
III.  RESULTS OF PROPOSED CORRECTIVE ACTION
    To:       A                          Date:
    From:     B                      Signature:

    Results:
                  Figure 9-1. Corrective Action Form.
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     The form has three parts:
     •  Request for Assistance
     •  Proposed Corrective Action
     •  Results of Proposed Corrective Action
A three-part, no-carbon-required, corrective action form is highly  recommended,
especially for field use, where photocopiers are rarely available. Space is provided
for signatures and a brief outline of the problem, the proposed solution, and the
results.  Each person signing the form should feel free to attach any other needed
material, but must also keep a copy of the complete packet in his or her own files for
ready access should a similar problem arise.
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                                 SECTION 10

                               BIBLIOGRAPHY
1.   American  National Standard:  Generic Guidelines for Auditing  of Quality
     Systems. ANSI/ASQC Standard Q1-1986. American Society for Quality Control,
     Milwaukee, Wisconsin. 1986. 13pp.

        Detailed description and flow charts of the entire auditing process.

2.   Dixon, W.J. and FJ. Massey, Jr. 1969 Introduction to Statistical Analysis, Third
     Edition. New York, NY: McGraw-Hill, Inc.

        A clearly written basic textbook, still a standard for statistical analysis.

3.   Interim Guidelines and Specifications for Preparing Quality Assurance Project
     Plans. QAMS-005/80. U.S. Environmental Protection Agency, Washington, DC.
     1980.

        The ancestor of all U.S. EPA guidance documents for preparing QA
        project plans.  Still the standard, but will be replaced in  1993  by a
        completely new document consistent with recommendations of the
        American Society  for  Quality  Control  and the American National
        Standards Institute.

4.   Porter, L.F.   Guideline ,for  Design,  Installation,  Operation,  and  Quality
     Assurance for Dry Deposition Monitoring  Networks. EPA/600/3-88/047.  U.S.
     Environmental Protection  Agency, Research Triangle Park, NC. 1988. 500 + pp.

        Practical  guidance on  the  design of  monitoring  projects  and
        associated QA/QC. Lengthy and detailed, but a readable format.
        Covers all phases from design to installation to implementation of
        monitoring networks.

5.   Simes, G.F.   Preparing  Perfect  Project  Plans:  A Pocket  Guide for the
     Preparation  of  Quality Assurance Project Plans.   EPA/600/9-89/087.   U.  S.
     Environmental Protection  Agency, Cincinnati, OH. 1989. 62 pp.

        A companion document to those listed  in item (6) below.  Uses four-
        category  approach to  project classification and associated QA.  For
        each category, provides hints and checklists for preparing QA project
        plans.

6.   Simes, G.F.  Preparation  Aids for  the  Development of Category  I (II, III, IV)
     Quality  Assurance   Project  Plans.    EPA/600/8-91/003,  EPA/600/8-91/004,
     EPA/600/8-91/005, EPA/600/8-91/006. U. S. Environmental Protection Agency,
     Cincinnati, OH.  1991. 65, 63, 57,35 pp., respectively.

        Companion documents to that  listed in item (5) above. Uses a four-
        category  approach to  project classification and associated QA.  For
                                    10-1

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        each category, gives more detail than the Pocket Guide.  Includes
        many examples of summary tables for presenting QA requirements.

7.    Quality Assurance Handbook for Air Pollution Measurement Systems.   U.S.
     Environmental Protection Agency, Research Triangle Park, NC. Dates variable.

        Volume I    Now: A Field Guide to Environmental Quality Assurance.
                   1993. Replacement for:  Principles.
                   EPA-600/9-76-005,1976.

        Volume II   Ambient Air Specific Methods.
                   EPA-600/4-77-027a,l977.

        Volume III   Stationery Source Specific Methods.
                   EPA/600/4-77-027b, 1977.

        Volume IV   Meteorological Methods.
                   EPA/600/4-90/003,1989.

        Volume V   Manual for Precipitation Measurement Systems.
                   EPA-600/4-82-042a & b, 1983.

        A large 5-volume compendium of all things related to ambient air
        measurements, including,  but not  restricted to, test  methods,
        sampling, analysis, and QA. Individual methods revised occasionally
        since 1976, but many are both out of date and out of print. Use the
        EPA document numbers shown above to  obtain  the  most  recent
        updates  if available.  Major  revisions are planned for the  entire
        Handbook.  Those for Volume I are completed with publication of
        this field guide. Work on Volumes II and III has begun. Volumes IV
        and V, published more  recently,  will be addressed later.  Pending
        funding, the target for completing all revisions is the mid-1990s.

8.    Quality Assurance Project Plan for the  Atmospheric Research and Exposure
     Assessment  Laboratory.  U.S. Environmental Protection  Agency, Research
     Triangle Park, NC. 1990.

        Example of  a broad guidance document for an  entire laboratory
        rather than  a  single project.   Emphasizes  job  descriptions, QA
        oversight requirements,  and protocols  for the  preparation  and
        review of a wide variety of documents. Other U.S. EPA laboratories
        have similar plans tailored to their special needs.
  -f(U.S. GOVERNMENT PRINTING OFFICE: IW4 - 550-001/80372


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