Air Pollution Training Institute
MD20
Environmental Research Center
Research Triangle Park, NC 27711
EPA 450/2-82-018
February, 1983
Air
&EPA
APTI
Slide/Tape Course 443
Chain of Custody
Guidebook
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United States
Environmental Protection
Agency
Air Pollution Training Institute
MD20
Environmental Research Center
Research Triangle Park, NC 27711
EPA 450/2-82-018
February, 1983
Air
APTI
Slide/Tape Course 443
Chain of Custody
Guidebook
Prepared by:
B. Michael Ray
Cynthia France
Northrop Services, Inc.
P.O. Box 12313
Research Triangle Park, NC 27709
Under Contract No.
68-02-3573
EPA Project Officer
R. E. Townsend
United States Environmental Protection Agency
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
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Notice
This is not an official policy and standards document. The opinions and selections
are those of the authors and not necessarily those of the Environmental Protection
Agency. Every attempt has been made to represent the present state of the art as
well as subject areas still under evaluation. Any mention of products or organizations
does not constitute endorsement by the United States Environmental Protection
Agency.
n
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Table of Contents
Page
Course Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Supplementary Reading. . . .. .....,...................................... 1
Using the Slide/Tape Presentations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
Part A-Chain-of-Custody Procedures for Samples and Data. . . . . .. .. " 3
Goal and Objectives. . " ..... . . . . . . . . . . . .. ............ .......... 3
Scri pt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
Part B - Model Chain-of-Custody Procedure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Goal and Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
Script. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Hi
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Chain of Custody
Course Description
This two pan slide/tape presentation covers proper procedures for documenting the
possession or custody of samples and data. Pan A defines chain of custody, presents
a rationale for maintaining proper chain-of-custody documentation, and delineates
correct chain-of-custody procedures for both samples and data. Pan B presents a
model chain-of-custody procedure for a hypothetical measurement project in which
manual sampling takes place at one location and the samples are analyzed at
another . You will see the entire procedure, from preliminary operations through
preparation and storage of the final data.
Supplementary Reading
Reference documents are not required; however, the Quality Assurance Handbook
for Air Pollution Measurement Systems Volume II (EPA 600/4-77-027a) and Volume
III (EPA 600/4-77-027b) are recommended to you as on-the-job references.
Using the Slide/Tape Presentations
You do not need to follow the script provided as you view each slide/tape presenta-
tion. The script is provided for you to review the content. To use the slides, load
them into a carousel tray upside down. Be sure they are in numerical order. The
audio cassette can be used in two ways. If your cassette player has a mechanism for
synchronizing an audio cassette and 35-mm slides, you can use the side of the
cassette marked "automatic advance." This will cause the slides to advance
automatically while you listen to the tape.
. To use the slides and audiotape together, advance the slide tray to the first slide
and focus the image.
. Leave the tray positioned at slide # 1.
. Place the cassette in the tape player so that the side marked "Automatic
Advance" will play. The tape recorder will advance the slides for you.
If you do not have equipment that automatically advances the slides, you can use
a 35-mm slide projector and any cassette player.
. Use the side of the tape marked "Manual Advance."
. Set the slide tray to slide #1, and advance the slides manually as you hear a
"beep" (tone) on the tape.
1
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If you have any problems using these slides and tapes, please contact the Training
Institute.
Air Pollution Training Institute
Environmental Research Center
MD 20
Research Triangle Park, NC 27711
Telephone Numbers:
Commercial: (919) 541-2401
ITS: 629-2401
2
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Part A
Chain-of-Custody Procedures
for Samples and Data
Goal and Objectives
Goal
To familiarize you with proper procedures for documenting the possession or custody
of samples and data.
Objectives
After viewing this slide/tape presentation, you should be able to
1. recognize the definition of chain of custody.
2. describe a rationale for following chain-of-custody procedures.
3. recognize situations in which chain-of-custody procedures are most appropriate.
4. identify proper chain-of-custody procedures for samples:
a. during sample identification.
b. during reagent and material preparation.
c. during sample handling at the site, during transpon, and at the lab.
d. during fmal disposition.
5. recognize proper chain-of-custody procedures for:
a. data identification.
b. data custody in manual and automated data-acquisition systems.
c. data custody during data processing and storage.
6. identify correct procedures for using, correcting, and storing standardized logs
and data forms.
3
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Chain~£-Custody Script-Part A
Slide
no.
Narration
1. Judge: "Would the prosecuter and attorney for the
defense please approach the bench."
Attorneys: "Yes, your Honor."
2. Judge: "Mr. Prosecuter, have you any additional evidence
to present concerning the integrity of the samples you
have attempted to introduce into evidence in this case?"
Prosecuter: "No, your Honor. The State did not maintain
records or security of the samples."
Judge: "Mr. Prosecuter, I have no choice but to dismiss
this case because of lack of security of the samples. How
could this happen? Don't you realize that this is a busy
coun and trials cost money."
Prosecuter: "Yes, your Honor."
Judge: "Case dismissed."
3. Narrator: This counroom scene is not unusual. Every
regulatory agency must cope with mountains of data, any
of which could become pan of a legal or quasi -legal
proceeding.
4. If we knew which data, which samples, or which repons
would be required in coun, we could be sure to document
them carefully.
4
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Slide
no.
Narration
5. Unfortunately, we never know which tests or data will be
ones we may actually need, so we must be prepared to
produce any of them when asked.
6. In legal proceedings. we must prove the legal integrity of
both the samples and the data. That means what. . .
There must be positive written identity.
7. where they've been at all times. and. . .
8. who has had access to them.
9. Verification of what. where, and who will be easier if you
use.. .
10. chain-of-custody procedures.
5
Illustration
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no.
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11. Chain-of-custody procedures document all possessions
and exchanges-
12. all "custodies" of both samples and data.
13. Chain-of-custody fonns should always accompany both the
samples and the data.
14. The fewer people handling samples and data, the better.
Everyone who does handle samples and data should be
associated with the project. If no established set of chain-
of-custody procedures is available, they should be
developed.
15. Let's consider a typical set of procedures for samples.
Sample identification is the first step.
16. Imagine a legal proceeding in which a lab analyst admits
that he is uncertain whether he analyzed sample #6 or
sample #9.
6
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no.
Narration
17. Such an admission could destroy the validity of an entire
test report. Therefore,
18. every sample must carry positive identification at all
times.
19. Each sample container must have its own unique and
penn anent identification. This helps prevent container
mix-up.
20. Next, let's consider chain-of-custody procedures for
reagent and materials preparation.
21. Materials and reagents may be used to calibrate sampling
equipment, or they may become part of the sample itself.
22. In a legal proceeding, both the methods of preparation
and the competence of the preparer may be questioned.
. . . So, it's important to. . .
7
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Slide
no.
Narration
23. keep records! These records must include the date of
preparation,
24. the name of the person who prepared the reagents and
materials,
25. and the location of reagents and materials from
preparation through use.
26. Chain-of-custody must be maintained during sampling.
27. During short-term manual stack sampling, for example,
one person has the responsibility for security. The
collected sample. . .
28. is placed in a nonreactive container and sealed, usually
with tape, to prevent accidental opening.
8
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no.
Narration
29. If there is any possibility that unauthorized persons may
have even temporary access to the samples, the container
should be. . .
30. sealed with a self-adhesive sticker, signed and numbered,
and.. .
31. attached so that it cannot be removed without tearing it.
32. In long-term sampling situations, sampling devices are left
unattended for long periods. As a result, maintaining
proper chain-of-custody may present some problems.
33. When the sampling probe must be exposed to the
environment, for example, tampering is a possibility.
9
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Slide
no.
Narration
34. Placing the sampling device in a locked shelter may help.
35. Installing security lights and checking the sampling device
at random intervals may also help.
36. Handling the sample is the fourth area of concern in these
chain-of-custody procedures.
37. Samples should usually be either in the physical possession
of a properly designated person, or. . .
38. in limited-access locked storage.
10
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Slide
no.
Narration
39. Physical possession or locked storage is appropriate for
sample handling at the sampling site,
40. as well as during transpon.
41. It's best to use project personnel to transpon samples. but
from time to time common carriers must be used.
42. Samples transponed by the V.S. Postal Service must be
sent by registered mail. return receipt requested. and
marked "deliver to addressee only."
43. Samples sent by V.P.S. require a description of the items
on the bill of lading. and must be marked "deliver to
addressee only."
44. A shipping/receiving record should always accompany the
transponed samples.
11
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-------
Slide
no.
Narration
45. At the lab, samples should be in the possession of the
sample custodian, or in limited-access locked storage.
46. During analysis, samples and intermediate solutions must
be in continuous view of the analyst, or in limited-access
locked storage.
47. The final disposition of samples is the last concern in this
set of chain-of-custody procedures.
48. After analysis. some samples will be discarded and others
will need to be securely stored - depending on the
objectives of the project involved. If samples are toxic or
hazardous, they must be disposed of safely.
49. Chain-of-custody procedures for data are every bit as
imponant as those for samples. First, let's look at data
identification.
50. Data should be clearly identified with permanent. non-
erasable markings that do not interfere with the data.
12
Illustration
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-------
Slide
no.
Narration
51. J.D. information usually includes what, where, when,
how, and who. That means a listing of. . .
52. the parameter measured, the location, the date and time
of the sampling,
53. the measurement methodology used-including units for
reporting and the instrument's full scale setting-and the
signature of the sampler.
54. Chain-of-custody procedures in manual and semi-
automated data-acquisition systems are the same as those
for sample handling:
55. physical possession by a designated person or in limited-
access locked storage.
56. Magnetic tape records require additional care. They
should be copied, verified, sealed, and transponed
separately in shielded containers.
13
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-------
Slide
no.
Narration
57. Unique chain-of-custody problems may occur when data-
acquisition systems are fully automated,
58. as with telemetry systems. No one "possesses" the data
as it travels from the sampling site to the data-processing
facility.
59. Comparing data recorded at the site to data received at
the processing facility is one way of assuring the integrity
of the data.
60. Chain-of-custody procedures must also be maintained
throughout the processing of th~ data.
61. Only authorized persons should be allowed access to the
areas where data are processed.
62. Finally, the full test repon and all notes, calculations, and
chain-of-custody records leading up to it should be placed
in limited-access locked storage. where they remain as
long as required by regulations, or until they are no
longer useful.
14
Illustration
Chain of Custod\' for Data
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Slide
no.
Narration
63. Briefly, let's review what we now know about chain-of-
custody procedures. Think for a moment about what
chain-of-custody procedures are and why we use them.
64. Remember chain-of-custody procedures document all
possessions and exchanges of samples and data.
65. Chain-of-custody procedures verify what samples and data
are-their identity, where they've been, and who has had
access to them.
66. This is imponant when data from a project may be used
in a legal proceeding.
15
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no.
Narration
67. If the samples and data you work with are always ~n the
physical possession of a designated person or in limited-
access locked storage, you may generally assume. . .
68. that you are following chain-of-custody procedures.
16
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Part B
Model Chain-of-Custody Procedure
Goal and Objectives
Goal
To present you with a model of the proper use of chain-of-custody procedures, as
demonstrated in a hypothetical measurement project employing manual sampling at
one location and subsequent sample analysis at another.
Objectives
After viewing this slide/tape presentation, you should be able to
1. identify the person(s) responsible for custody of samples for each of the opera-
tions listed in the model.
2. distinguish between proper and improper chain-of-custody procedures in
hypothetical examples sim~ar to those in the slide/tape.
17
-------
Chain-of-Custody Script-Part B
Slide
no.
Narration
1.
2.
3.
4. Suppose you are working on a measurement project
involving manual sampling at one location and sample
analysis at another.
5. You know that following chain-of-custody procedures is
imponant in this case, since the data from your project
will be used in a legal proceeding.
18
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no.
Narration
6. Chain-of-custody procedures should be followed in each of
these steps: preliminary operations; sampling operations;
sample transpon; sample receipt, storage, and transfer;
sample analysis; and sample-data record keeping.
7. Let's consider who is responsible for the custody of
samples in each step and which procedures they should
follow.
8. The lab-sample custodian begins the chain-of-custody
procedures during the preliminary operations. She gives
reagents and supplies needed for sampling to a laboratory
technician for preparation.
9. The chain-of-custody form for reagents and supplies,
filled out by the lab-sample custodian, documents this
exchange.
10. The lab technician then prepares the reagents and
supplies that will be used in the sampling operation.
11. He documents his methods of preparation by recording on
the same chain-of-custody form the appropriate reference
number for standard methods listed in lab manuals.
19
III ustration
Chain of Custody in:
. Prelimin.irV Operations
. Sampling Operations
. Transport
. Receipt. Storage, Transfer
. Sample Analysis
. Sample-Data Record Keeping
Preliminary
Operations
n of Custody
gents and Supplies
I ~,...'ion
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-------
Slide
no.
Narration
12. ~repared reagents and supplies are returned to the lab-
sample custodian, who places them in limited-access
locked storage,
13. and completes the chain-of-custody fonn for reagents and
supplies, placing it in the locked project files.
14. When the reagents and supplies' are needed in the field,
the field-sample custodian takes possession of them. At
that time, he also receives a copy of the chain-of-custody
fonn. '
15. The field-sample custodian keeps the reagents and
supplies until they are released to the field sampler. In some
cases the field-sample custodian and the field sampler are the
same person.
16. In preliminary sampling operations, custody of reagents
and supplies rests first with the lab-sample custodian, next
with the lab technician, and then back to the lab-sample
custodian. The chain-of-custody fonn for reagents and
supplies provides documentation. Finally, the field-sample
custodian takes possession until the reagents and supplies
are delivered to the field sampler.
20
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Slide
no.
Narration
17. During sampling operations. the field sampler is
responsible for the custody of samples.
18. He starts chain-of-custody procedures for samples at the
sampling site by filling out standardized forms that list all
necessary sampling information. including sample
custody.
19. Once the sample is obtained. the field sampler keeps the
sample in continuous view at all times or in limited-access
locked storage.
20. The field sampler also places adhesive-backed
identification labels on all samples. . .
21. before delivering them to the field-sample custodian along
with the sampling-data forms.
21
Illustration
Samp6ng Oper~lions ~
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Slide
no.
Narration
22. So, in sampling operations, custody is the responsibility
of the field sampler. The necessary chain-of-custody forms
are the field-samPling data sheets and the sample
identification labels.
23. The next step is getting the sample from the sampling site
to the lab. The field-sample custodian is responsible for
recovering. preserving. and storing the samples until they
are delivered to the lab.
24. He attaches tamper-proof seals to all the samples
before. . .
25. arranging to have them transponed by project personnel,
or, if necessary, by common carrier.
26. The field-sample custodian fills out the shipping/receiving
form. keeping one copy and sending the other with the
samples.
22
Illustration
Sampling Operations
Custod~n
Forms
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Slide
no.
Narration
27. Briefly, then, proper custody of samples during transport
is arranged by the field-sample custodian and documented
on the shipping/receiving form.
28. The next step of the process involves the receipt ana.
handling of samples at the lab. The lab-sample custodian
maintains the chain-of-custody at this stage.
29. When samples are received, the'lab-sample custodian
verifies the number of samples and their identification.
30. She also checks to see that they have not been tampered
with.
31. Only then does she sign the field-sampling data forms or
complete the shipping/receiving forms.
23
Illustration
Sample Transport
Custodian
Form
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Slide
no.
Narration
32. Next, the lab-sample custodian assigns each sample its
own alpha-numeric identification number, and. . .
33. records that number on the Sample Receipt and Record
Log.
34. Finally, the lab-sample custodian places the samples in
limited-access locked storage until they can be analyzed.
35. She records, on the Sample Control Record, all transfers
of sample custody within the lab and all procedures
performed on the samples.
36. The proper receipt, storage, and transfer of samples at
the lab is managed by the lab-sample custodian and
documented by the Shipping/Receiving forms, the Sample
Receipt and Record Log, and the Sample Control
Record.
24
Illustration
~..:.
~~
v' :n ':: \
y:q.. '\J-----=::: .-
,~,~
- . ICJ
. ~ ~-=-
i__,J 'lir
~'.'''~Tm
Simple
\ Identification
~ Number
c .,
Q' , ,
E:1 r:.' "'/'? '\ \
:- Q , (, I
---4~lfj". ~;'. I~~~,~-
~. "."'" .~.'::::Il=. ~
~: ""/
~. :,..,
// ~,':;;h.
:; , ',j \ 1 '1--'"
~ ~ '. 'e.-- - r "I 'i.Y
~ '~ ", . Ii 1\
Receipt, Storage, Transfer
Custodi.ln Fonns
..... -.-..... bco
-------
Slide
no.
Narration
37. During sample analysis, the analyst has responsibility for
the integrity of samples.
38. After obtaining the sampleL.from the lab-sample
custodian, the analyst verifies the information given on
the Sample Control Record and makes appropriate notes.
39. During analysis the analyst keeps the samples as well as
any intermediate solutions in continuous view or in
limited-access locked storage.
40. He records all analytical data on a data sheet. including
associated calibrations, references to standard solutions or
instrument numbers, and sample calculations.
41. In some cases, the analyst must reseal remaining ponions
of samples and return them to the lab-sample custodian.
25
Illustration
Sample Analysis c~ .:...~-:'
------'I~~~
~ \....,; ...J'
- n - ~ ~(, .
" A . "
'v::. ,,~o------ '-
~c=--~
--
/
-------
Slide
no.
Narration
42. So, during analysis, the analyst is the responsible
custodian who documents his work with samples on the
Sample Control Record and the Analytical Data Sheet.
43. The final step in this project involves sample-data record
keeping. When the final repon is issued, the lab-sample
custodian receives a copy of it, along with all associated
documents.
44. She places them in limited-access locked storage.
45. So, the proper custodian of the final repon copy and all
the forms is the lab-sample custodian.
46. For each step of the process-preliminary operations;
sampling; transpon; receipt, storage, and transfer; sample
analysis; and final record keeping,
26
Illustration
Analysis
Custodian
Forms
~~~}
t1~,~ .~
~
, - "
\~,'
. '
-'-
"Mi",1
........ ~-",.....-
---
........... 0.'" "'".'
F
Sample-Data Record Keeping
Custodian Forms
""-"'.uIOoI.lUl...,
~ ~lWcfo.loI""'WII~r
- ----
~Cllfllral""o.d
i'~ ...,..-..:..........0r4lOl
II.. I'
~ ~.......~~
LaD SampIo CuoIooio. ,......c......"""'.
...- -
-
C1Yin of Custody in:
. PrelimiNry Oper~tions
. 5ampling Operations
. Transport
. Receipt, Storage. Transfer
. Sample Ana1y8
. Sample-Data Record Keeping
-------
Slide
no.
Narration
47. the person responsible for the custody of samples follows
prescribed procedures and documents every possession and
exchange. . .
48. to-preserve the chain-of-custody.
49. Credit
50. Credit
51. Credit
27
Illustration
I~
~
ub ,«hntCWn
M
\i1
~
l.b s..mpl. Cu\lodw.n
:---:;:,
f:..I~
:\..':
J
F,,'ld ~mplt'
(U,todlol"
~
,,~~
~
field S..mplt'r
"n.lh\1
Model Chiin-of-Custodv Procedure
TKhnK.i1 ronl."1 Mlltt'R,...
ImlrvctioMI DftiBn
C.,nlh.. fr.nct'
Gr.phtn lnl.. Wt!il"
PholDp.phv Aucio
o.".d Churchill
N.",hOn 1bcL.. p.lm.,
c...O'Iopood.ndpnM!utf'CIb.
NOl1hrop SeMCn Inc.
undo.
ErA Contract No. 68-0].);73
Northrop
Environmental
Training
-------
1. REPORT NO.
EPA 450/2-82-018
TECHNICAL REPORT DATA
{Please read IRUTuctions on (he re~'erse before completing)
12. 3. RECIPIENT'S ACCESSIO~NO.
4. TITLE AND SUBTITLE
APTI Slide/Tape Course 443
Chain of Custody: Guidebook
5. REPORT DATE
Februarv. 1983
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
B. H. Ray
Cynthia France
9. PERFORMING OR"'ANIZATION NAME AND ADDRESS
Northrop Services, Inc.
P.O. Box 12313
Research Trian~le Park, NC 27711
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
B18A2C
11. CONTRACT/GRANT NO.
68-02-3573
.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Manpower and Technical Information Branch
Air Pollution Training Institute
Research Triangle Park, NC 27711
15. SUPPLEMENTARY NOTES
Project officer for this publication is R. E. Townsend, EPA-ERC, RTP, NC 27711
13. TYPE OF REPORT AND PERIOD COVEREO
Student Guidebook
14. SPONSORING AGENCY COOE
EPA-OANR-OAQPS
16. ABSTRACT
This Guidebook was developed for use in the Air Pollution Trainin~ Institute's
Slide/Tape Course 443, "Chain of Custody". It contains viewin~ information
and scripts for two slide/tape presentations concerning chain-af-custody
procedures.
17.
. a.
DESCRIPTORS
KEY WOROS ANO DOCUMENT ANAL YSIS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Training
Air Pollution
Measurement
Air Monitoring
Training Course
DB
51
68A
18. DISTRIBUTION STATEMENT unl~m~ted
Available from National Audio Visual
Center, National Archives and Records
Service, GSA, Order Service HR,
EPA Form 2220.1 19.73) Wash~ngton DC LD409
28
19. SECURlrTY CL~S~ (This Repol't)
unc ass~t~ed
21. NO. OF PAGES
31
22. PRICE
20. SECURITY CLASS (This page)
unclassified
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