UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, B.C. 20460
OFFICE OF
SOLID WASTE AND
EMERGENCY
RESPONSE
November 14, 2002
Directive # 9420.0-38
MEMORANDUM
SUBJECT: FORMS II Lite™ Role in Tracking Superfund Sampling Data
FROM:
TO:
Michael B. Cook, //ss// Michael B. Cook
Director, Office of Emergency and Remedial Response
Superfund National Program Policy Managers
Regional Science and Technology Division Directors
Purpose
The purpose of this directive is to establish the Field Operations and Records
Management System (FORMS II Lite™), the Office of Emergency and Remedial Response's
(OERR) sample tracking software, as a mandatory system to use on Contract Laboratory
Program (CLP) samples by January 1, 2003. FORMS II Lite™ will be phased into the
Superfund program for non-CLP samples by October 1, 2003 as appropriate. Regional
Science and Technology Division laboratories have the option of using FORMS II Lite™ for
sampling conducted by the Region for any customer, although I am strongly encouraging its
use. This Directive and Directive 9240.0-2C (Tracking Superfund Non-CLP Analytical Data) are
companion documents. FORMS II Lite™ can also be used to fulfill the requirements for
Directive 9240.0-2C.
The background and benefits of FORMS II Lite™, suggested contract language,
exemptions from the requirement, and training opportunities are provided below. All ten
Regions have received training at least once and are using FORMS II Lite™. FORMS II Lite™
has been used for over 50,000 Superfund samples, at the Hart Senate Building anthrax
cleanup, and for the indoor air and dust sampling and analyses of Lower Manhattan associated
with the World Trade Center collapse.
Background
FORMS II Lite™ was developed to expedite sample documentation, to track samples
from the field to the laboratory, and to reduce the most common documentation problems
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associated with sampling. Specifically, FORMS II Lite
TM.
• Generates and prints sample documentation (e.g., Traffic Reports/Chain-of-Custody,
bottle labels, and sample tags) in the field;
• Provides a legible document for each of the recipients of the Traffic Report/Chain-of-
Custody record;
• Eliminates manual transcription errors associated with the completion of sample
documentation through the "enter once, use many" philosophy; and
• Facilitates the electronic capture of sample information into Laboratory Information
Management Systems (LIMS) to automate the sample login process.
Since the implementation of FORMS II Lite™ the following benefits have been documented:
• FORMS II Lite™ saves up to 15 minutes of work per sample and it has the potential to
save up to $2 million per year if used on all Superfund samples (about 240,000 analyses
per year).
+ As of September 30, 2002, FORMS II Lite™ was used at 62% of all the CLP samples
(this is a 20% increase from the prior fiscal year). During October 2002, FORMS II
Lite™ was used at 86% of all the CLP samples. During Fiscal Year 2001, the increased
use of FORMS II Lite™ resulted in an average 48 percent reduction in paperwork
discrepancies for all the Regions.
• The reduction in paperwork discrepancies saves resources in tracking down samplers to
discern the analytical work required, reduces the frequency of samples exceeding
holding times, and allows samplers more time for sample collection rather than
correcting or manually filling out paperwork.
+ Two of the top five sampling issues (from FY2000 to FY2001) have dropped off the top
five list since the implementation of FORMS II Lite™. The issues reaching resolution
are: samples listed on the Traffic Report/Chain of Custody but not received at the
laboratory and samples not listed on the Traffic Report/Chain of Custody but received at
the laboratory.
* FORMS II Lite™ fulfills the Non-CLP Analytical Services Tracking System requirement.
(See Directive 9240.0-2C)
• FORMS II Lite™ establishes progress towards meeting the goals of the Government
Paper Elimination Act.
* FORMS II Lite™ helps meet the objective of OMB's Directive which requires EPA to
focus on "reproducible and documented" data for decision-making.
Attachment 1 provides a summary of FORMS II Lite™ along with software and hardware
requirements.
Suggested Language and Requirements for EPA Contracts. Intergencv Agreements, and
Cooperative Agreements
Attachment 2 provides additional details and suggested language to modify EPA
contracts and Interagency Agreements. Amendments to cooperative agreements with the
States and Tribes may be required to address the FORMS II Lite™ requirement or to purchase
equipment. Amendments to Interagency Agreements with federal facilities for EPA-lead sites
may also be needed. The language is provided to establish national consistency in overseeing
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sampling activities. Each Region needs to amend its major assessment and response
contracts (e.g., Remedial Action Contracts (RACs), Superfund Technical Assessment and
Response Team (START)) that provide sampling services. In addition, regional modifications
may be necessary to accommodate Region-specific needs. Contractors shall provide the
equipment and software necessary to operate FORMS II Lite™.
Effective January 1, 2003, the contractors performing sample work for the CLP shall be
required to use FORMS II Lite™ to manage sample collection, documentation, and submission
of all relevant reports. The samplers shall also submit electronic Traffic Reports/Chain-of-
Custody to the Sample Management Office (SMO) to automate the sample tracking process.
Exceptions to the January 1, 2003 requirement should be rare (our goal is 95% Forms II Lite™
usage for the CLP) but can be waived by the Regional Sample Control Center Coordinator
(RSCC) or another Regional designee who is most familiar with the sampling activities. The
Region may also institute special procedures to handle situations when the use of FORMS II
Lite™ is not practical. Headquarters does not need to approve individual waivers or the waiver
process. Examples of acceptable waivers include small businesses conducting very limited
sampling for one site such as at Brownfield sites, and substantial breakdown of equipment such
as laptops, printers, or other related equipment. The RSCC should coordinate with the Project
Officer and/or Contracting Officer if there is a trend in equipment problems or to address
penalties for non-compliance, as appropriate. The Region will be responsible for determining
alternative tracking procedures for sites that are waived from using FORMS II Lite™.
For non-CLP samples, the requirement is being phased-in by October 1, 2003. OERR
is shifting many of its E-Commerce initiatives beyond the CLP and is developing web-based
services that can also meet the needs of Emergency Response and Homeland Security.
However, OERR also recognizes the Regional need for flexibility and recommends the Regions
determine procedures for when the use of FORMS II Lite™ is not practical (e.g., emergency
response). It is expected that the RACS and START contracts can be amended to require the
use of FORMS II Lite™. Applicability of this requirement to other contracts (e.g., ERRS) may
vary with the Region. In many cases, the same samplers are collecting samples for CLP and
non-CLP analyses, and thus the contracts can be modified once for the two implementation
dates.
States and Tribes accessing the CLP or using EPA services for non-CLP analyses
should try to comply with the implementation dates as well. However, each Region should use
their judgement on whether certain States and/or Tribes need special accommodations or an
extension of the deadline. Potentially Responsible Parties have the option of using FORMS II
Lite™, unless the samples (e.g., split samples) are being analyzed by EPA contractors.
Status of Software and Training
FORMS II Lite™ software and training are offered at no cost to EPA personnel, EPA
contractors conducting Superfund work, the States and Tribes. The software will continue to be
upgraded to meet customer needs, for example, modifications are underway to accommodate
Regional LIMS and web-based services. Samplers in all the Regions and some States have
been trained by OERR and training requests will continue to be honored. Training has been
conducted during actual sampling events to minimize work disturbance. Training is also
provided via computer-based and web-based systems, a self-help web site, and the FORMS II
Lite™ help desk. Training can be requested via the RSCCs or by directly contacting Willie
Wong at 703-603-8846.
Next Steps
Regional Contracting Officers and Project Officers will need to amend their assessment
and response contracts to address the FORMS II Lite™ requirements. Site project managers
need to ensure that sampling contractors use FORMS II Lite™. RSCCs or other appropriate
staff overseeing sampling activities need to work closely with site managers to ensure sampling
contractors are complying with the requirement. OERR will provide quarterly updates to the
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Regions on which samplers have been trained and are using FORMS II Lite™ for CLP samples.
Willie Wong should be contacted to request software modifications.
Thank you for your cooperation in deploying FORMS II Lite™. Please contact Dana
Tulis at 703-603-8993 for general policy issues including any concerns with the time frames and
Willie Wong at 703-603-8846 for technical questions.
Attachments
CC:
Field and Analytical Services Teaming Advisory Committee
Superfund Senior Regional Management and Acquisition Council
Regional Lab Directors
Regional Quality Assurance Managers
CLP Project Officers
Regional Sample Control Center Coordinators
RACs, START, ERRS Contract Officers/Project Officers
OERR Senior Management Team
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ATTACHMENT 1
FORMS II Lite™ Overview
The Problem: Collecting environmental samples at hazardous waste sites requires an enormous amount
of supporting documentation. In the Superfund Program, for example, 10 water volatile samples may
require up to 75 separate pieces of sample documentation, including: sample labels, bottle tags, custody
seals and chain-of-custody records. This documentation is vital to the cleanup and litigation of sites, but
the paperwork process is tedious and time consuming. EPA OERR's Analytical Operations/Data Quality
Center (AOC) developed FORMS II Lite™ to assist samplers with generating sample documentation and
to track samples.
Background: EPA Headquarters worked closely with Regions 4 and 10 to develop a customer-driven
software based on initial systems developed by these Regions. The first Beta version of FORMS II Lite™
was released for testing in November 1998. After several rounds of testing and incorporating regional
comments, FORMS II Lite™ was released in production form in February 2000. FORMS II Lite™ is
continuously updated to meet customer needs. Version 5.1, released in August 2002, includes the ability
to transfer old data between previous versions and contains a computer-based training module.
What is FORMS II Lite™: A flexible and easy-to-use, stand-alone, Windows-based application software
that accelerates sample documentation and reduces the generation of hand written documents by almost
70 percent. Specifically, FORMS II Lite™ :
• Generates sample labels, bottle tags, and Traffic Reports/Chain of Custody (COC) forms;
• Tracks samples from the field to the laboratory;
Facilitates electronic capture of sample information into databases; and
Exports data electronically as .xml, .dbfor .txt files.
Why does FORMS II Lite™ carry the trademark symbol? The FORMS II Lite name carries the symbol
"TM" to show the public that the phrase "FORMS II Lite" is being used as a trademark (i.e., to indicate the
source of the product). By using "FORMS II Lite" as a trademark, EPA provides consumers a means for
finding the original EPA developed product, as opposed to an imitation, thereby protecting the integrity of
the product. The use of the trademark symbol by EPA does not affect distribution of the product to
regulators, government contractors or the general public.
Training Support: On-site, computer-based training (Version 5.1) and distant learning (using National
Guard nationwide distant training facilities) is available.
System Requirements:
/ IBM-compatible
/ Windows 98, NT, 2000, or XP
/ Internet Explorer 4.0 or above
/ 200 MHz Pentium processor
/ Minimum 32MB RAM (recommend 64MB)
/ 35MB available hard disk space
/ 2X or hijgher CD-ROM drive
/ 800x600 resolution using small fonts
/ Mouse interface, printer, and remote power source for field use
Contact Point:
Willie Wong
USEPA OERR AOC (5204G)
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
Telephone: 703-603-8846
Fax: 703-603-9112
Email: wong.willie@epa.gov
FORMS II Lite Help Desk: 703-715-4474
FORMS II Lite web site: http://dyncsdao1 .dyncorp.com/f2lite
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ATTACHMENT 2
Suggested Language for EPA Contracts, Interagency Agreements, and
Cooperative Agreements
The contractor shall be required to use EPA's field sample tracking software, Field
Operations and Records Management System, FORMS II Lite™, to manage the sample
collection, documentation and submission of all relevant reports for Contract Laboratory
Program (CLP) activities by January 1, 2003 and for non-CLP activities by October 1, 2003.
The contractor shall provide the equipment (e.g., laptops, portable printers) and software (e.g.,
Internet Explorer) necessary to operate FORMS II Lite™. EPA will provide FORMS II Lite™
software and training at no charge to the contractor. Exceptions to this requirement will be
waived by the Regional Sample Control Center Coordinator (RSCC) or another Regional
designee who is most familiar with the sampling activities.1 The Region may also institute
special procedures to handle situations when the use of FORMS II Lite™ is not practical.
Examples of acceptable waivers include small businesses conducting very limited sampling for
one site such as at Brownfield sites, emergency response situations, and substantial
breakdown of equipment such as laptops, printers, or other related equipment.
The contractor shall use the FORMS II Lite™ software to generate and submit Traffic
Reports (also known as a Chain-of-Custody Form) in accordance with established regional
guidance. For CLP services, the samplers shall also submit electronic traffic reports to the
Sample Management Office to automate the sample tracking process. The extensible mark-up
language (XML) electronic traffic reports can be submitted via the Internet. Exact procedures
and instructions on how to submit electronic traffic reports are available on the Office of
Emergency and Remedial Response's CLP web page
(http://vyww.eDa.gov/superfund/proQrams/cip/f2SSte.htm).
1 Please include an EPA point of contact and telephone number if possible in the
modified contract language. Regional penalties, if instituted, would need to be stated
as well.
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