EPA-460/3-74-019
OCTOBER 1974
LABORATORY CERTIFICATION
PROGRAM IMPLEMENTATION
ANALYSIS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
Ana Arbor, Michigan 48105
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EPA-460/3 -74-019
LABORATORY CERTIFICATION
PROGRAM IMPLEMENTATION
ANALYSIS
by
Warner B. Lee and Merrill G. Hinton
The Aerospace Corporation
El Segundo, California
Contract No. 68-01-0417
EPA Project Officers:
William H. Houtman and P.P. Hutchins
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
Ann Arbor, Michigan 48105
October 1974
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This report -was furnished to the Environmental Protection Agency by The
Aerospace Corporation, El Segundo, California, in fulfillment of Contract No.
68-01-0417. The contents of this report are reproduced herein as received
from The Aerospace Corporation. The opinions, findings, and conclusions
expressed are those of the author and not necessarily those of the Environ-
mental Protection Agency. Mention of company or product names is not to
be considered as an endorsement by the Environmental Protection Agency.
Copies are available free of charge to Federal employees, current contrac-
tors and grantees, and nonprofit organizations - as supplies permit - from
the Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711, or, for a fee, from
the National Technical Information Service, 5285 Port Royal Road,
Springfield, Virginia 22161.
NOTE: The purpose of this study was to establish the requirements of a
certified laboratory program along with suggestions for implementation. As
such, several of the ideas contained herein are not sanctioned by current
government policy; for example, application fees. One final caution should
be made concerning the economic analyses; some of the cost estimates are
made on a slightly different basis than EPA's own economic projections.
Any discrepancies are of little importance since these cost estimates are
only preliminary and are intended to indicate the types and general range
of expense that can be expected. Final, more detailed estimates will be
made prior to the implementation of any program.
This notice is in no way intended to imply any criticism of the report; it is
only to remind the reader that it does not necessarily reflect the EPA's
position.
Publication No. EPA-460/3-74-019
11
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FOREWORD
This report, prepared by The Aerospace Corporation for the
Environmental Protection Agency, Division of Emission Control Technology,
presents the results of an analysis of possible emission testing laboratory
and operator certification processes under consideration by EPA.
A concise review of important findings and conclusions is
presented in the Highlights and Summary sections. The remaining sections
provide detailed discussions of each study topic and are of interest primarily
to the technical specialist. Section 2 presents a review of the contemporary
on-going certification activities of a number of federal and state regulatory
agencies. It identifies what their regulatory duties are, how they go about
implementing their functions, their organizational structure, work flow
sequences, and the number and types of personnel involved. Section 3 des-
cribes a brief review of the emission test procedures and equipment require-
ments as promulgated by EPA in the Federal Register. A requirements
matrix is developed which compares the facility, equipment, and procedural
requirements for certification testing in any currently promulgated subpart,
for 1975-1977 model years of LDVs and LDTs, and 1974 HDV engine testing.
The functional tasks selected as appropriate for EPA use in implementing a
laboratory certification program are delineated in Section 4 for both labora-
tories and operators. They encompass initial certification, renewal of certi-
fication, and on-going quality control functions. Section 5 describes and
discusses detailed expansions of the selected basic functional tasks in terms
of work flow sequences. The number and types of work flow elements are
defined, and the interrelation of work flow elements between the laboratory
(or operator) and the EPA laboratory certification control group are exten-
sively illustrated by means of flow sheet diagrams. Section 6 identifies a
reasonable EPA management organizational structure for performing the
necessary work tasks identified in Section 5. Staffing requirements, person-
nel requirements, and management plan options are identified, together with
111
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cost estimates for implementing an independent laboratory certification
program involving 17 such laboratories. Cost and staffing estimates are
also developed for the case of establishing EPA-owned-and-operated emis-
sion testing laboratories in Europe and Japan.
IV
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ACKNOWLEDGMENTS
Appreciation is acknowledged for the guidance and assistance
provided by Mr. William H. Houtman and Mr. F. Peter Hutchins of the
Environmental Protection Agency, Division of Emission Control Technology,
who served as EPA Technical and Contract Project Officers, respectively,
for this study.
Mr. Warner B. Lee of The Aerospace Corporation was prin-
cipally responsible for the acquisition and analysis of the data presented
herein.
Merrill G. Hinton, Director
Office of Mobile Source Pollution
Approved by:
Toru lura, Associate Group
Director
Environmental Programs Group
Directorate
;p Meltzer, Grojip'yDirector
ironmental Programs Group
rectorate
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CONTENTS
FOREWORD iii
ACKNOWLEDGMENTS v
HIGHLIGHTS H-l
H. 1 Laboratory Certification Program Elements H-2
H. 2 Operator Certification Program Elements H-4
H. 3 Staffing Requirements H-5
H. 4 Scheduling Implications H-6
H. 5 Costs H-6
H. 6 Management Organization Options H-7
H. 7 Program Start-Up Considerations H-8
H. 8 Longer-Term Implications H-9
SUMMARY S-l
S. 1 Introduction S-l
S. 2 Contemporary Certification Activities S-2
S. 3 Principal Elements of Laboratory
Certification Program S-6
S. 4 Program Implementation Requirements S-17
S. 4. 1 Generalized Personnel Requirements S-17
S. 4. 2 Staffing Requirements S-17
S. 4. 3 Costs S-24
S. 4. 4 Organizational Structure S-26
S. 4. 5 Special Problems S-28
S. 4. 6 Extension of Analysis Results to Longer-Term
Implementation S-30
S. 5 Cost of EPA-Operated Certification Test Facilities
in Europe and Japan S-30
VI1
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CONTENTS (Continued)
1. INTRODUCTION 1-1
1. 1 Background, Objectives, and Scope 1-1
1. 2 Acquisition of Relevant Data 1-3
1. 3 Organization of This Report 1-3
2. REVIEW OF CONTEMPORARY ON-GOING
CERTIFICATION ACTIVITIES 2-1
2. 1 The Federal Aviation Administration 2-2
2. 2 The Atomic Energy Commission (AEC) - Licensing
of Nuclear Power Plant Operators 2-18
2.3 The California Bureau of Automotive Repair (BAR) .... 2-31
2.4 The California Department of Public Health (DPH) 2-37
2. 5 The Pennsylvania Bureau of Traffic Safety (BTS) 2-41
2. 6 The New Jersey Department of Environmental
Protection (DEP) 2-42
2.7 Overview of Contemporary Certification
Requirements and Procedures 2-45
3. REVIEW OF TEST PROCEDURES AND EQUIPMENT
REQUIREMENTS 3-1
4. FUNCTIONAL TASK SELECTION 4-1
4. 1 Laboratory Certification 4-1
4. 2 Operator Certification 4-5
4.3 Use of the Functional Tasks 4-8
5. WORK FLOW SEQUENCE ANALYSIS 5_1
5. 1 Introduction 5_1
5. 2 Laboratory Certification 5_1
5. 3 Laboratory Quality Control 5-25
5.4 Operator Certification 5-34
Vlll
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CONTENTS (Continued)
6. MANAGEMENT ORGANIZATIONAL STRUCTURE 6-1
6. 1 Introduction 6-1
6. 2 Generalized Personnel Requirements 6-1
6. 3 Staffing Requirements 6-2
6. 4 Management Plan Options 6-26
6. 5 Special Problems 6-35
6. 6 Comparison With Cost of EPA-Operated Certification
Test Facilities in Europe and Japan 6-41
APPENDICES
A. SIGNIFICANT MEETINGS AND COMMUNICATIONS A-l
B. APPLICATION FOR INITIAL LABORATORY
CERTIFICATION B-l
C. INDEPENDENT TEST LABORATORIES DATA C-l
IX
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FIGURES
S-l.
S-2.
S-3.
S-4.
2-1.
2-2.
2-3.
2-4.
2-5.
2-6.
2-7.
2-8.
2-9.
2-10.
2-11.
2-12.
2-13.
2-14.
2-15.
2-16.
Initial and Renewal Laboratory Certification
Laboratory Certification- On-Going Quality Control Process .
Initial and Renewal EPA Operator Certification
Organization of Laboratory Certification Group —
A Long-Term Option
Management Structure - Flight Standards Division
Sequence of Initial Certification Procedures -
Aviation Mechanic Training School
Sequence of On-Going Quality Control Procedures -
Aviation Mechanic Training School
Steps in Certification Process for Aviation Mechanics ....
Sequence of AEC Licensing Procedures
Initial Application Content
Sequence of AEC Renewal Licensing Procedures
Renewal Application Content
Requalification Program - Overview
Requalification Program - Breakdown "A"
Requalification Program - Breakdown "B"
Requalification Program - Breakdown "C"
Management Structure and Staffing - California BAR
Scope of MVPC Activities - California BAR
Scope of Safety Check Activities - California BAR
Licensing Procedures for MVPC Device Installation
and Inspection Stations - California BAR
S-9
S-12
S-15
S-27
2-4
2-9
2-10
2-13
2-22
2-24
2-25
2-26
2-27
2-28
2-29
2-30
2-32
2-33
2-34
2-35
XI
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FIGURES (Continued)
2-17. Licensing Procedures for MVPC Device Installers -
California BAR
2-18.
2-19.
2-20.
5-1.
5-2.
5-3.
5-4.
5-5.
5-6.
5-7.
5-8.
5-9.
5-10.
5-11.
5-12.
5-13.
5-14.
5-15.
Licensing Procedures for Clinical Laboratories -
Laboratory Field Service, California DPH
Procedures for Licensing as Official Inspection
Station - Pennsylvania BTS Program
Procedures for Certifying Mechanics - Pennsylvania
BTS Vehicle Safety Inspection Program
Initial and Renewal Laboratory Certification
Application for Subparts "A" and "C" Certification
Laboratory Information Requirements
Exhaust Emission Measurement Details
Overview of Application Processing
Processing of Application
Preliminary Processing of Application
Application Correction Loop
Checklist for Exhaust Gas Sampling and
Analysis System ,
Checklist for CVS System Calibration
Checklist for CVS System Verification
Checklist for Gas Analysis Instruments
Organize and Schedule Inspection Visit
Block IX Work Element Details - Observe Complete
Test of Subpart Rating Applied For
Block X Work Element Details - Inspection Visit
2-40
2-43
2-44
5-4
5-5
5-7
5-8
5-9
5-11
5-12
5-13
5-14
5-15
5-16
5-17
5-21
5-22
5-23
XI1
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FIGURES (Continued)
5-16.
5-17.
5-18.
5-19.
5-20.
5-21.
5-22.
5-23.
5-24.
6-1.
6-2.
6-3.
6-4.
6-5.
6-6.
Final EPA Review . . . . .
Periodic Inspection - Scheduled Inspection at
6 -Month Intervals
Scheduled Inspection - Inspect Calibration and
Test Procedures
Scheduled Inspection - Examine Data and Records
Unannounced Inspection - Random, Average
Two per Year
Laboratory Certification - On -Going Quality
Control Process
Summary of Certification Control Mechanisms
EPA Operator Certification - Initial and Renewal
EPA Task Assignment for Operator Certification
Organization of Laboratory Certification Group -
A Long -Term Option
Current Organizational Structure
Option A Organizational Structure
Option B Organizational Structure
Option C Organizational Structure
Option D Organizational Structure
5-26
5-28
5-29
5-30
5-32
5-33
5-35
5-37
5-38
6-25
6-27
6-28
6-30
6-32
6-33
XI11
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TABLES
S-l. Data Sources S-3
S-2. Initial and Renewal Laboratory Certification S-7
S-3. On-Going Laboratory Quality Control S-10
S-4. Initial Operator Certification S-13
S-5. On-Going Quality Control S-l6
S-6. Laboratory Facility Classification S-18
S-7. Total Inspector Office Burden S-20
S-8. Inspection Team Numerical Structure S-20
S-9. Inspection Visit Man-Day Requirements S-22
S-10. Overall Inspector Travel Schedule S-23
S-ll. Travel Expenses for Inspection Visits S-25
S-l2. EPA Laboratory in Europe and Japan - Workload
and Staffing Estimates S-32
S-13. Cost Estimates for EPA Laboratories in
Europe and Japan S-33
1-1. Principal Data Sources 1-4
2-1. Staffing - National Office 2-5
2-2. Staffing - Regional Offices 2-5
2-3. General Aviation Staffing - District Offices 2-6
2-4. Scope of Activities - General Aviation 2-7
2-5. Summary of Initial Facility Certification
Requirements 2-47
2-6. Summary of Critical Elements of a Facility
Application 2-48
xiv
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TABLES (Continued)
2-7. Summary of Renewal and/or On-Going Facility
2-8.
2-9.
2-10.
2-11.
3-1.
4-1.
4-2.
4-3.
4-4.
5-1.
5-2.
5-3.
6-1.
6-2.
6-3.
6-4.
6-5.
Summary of Initial Personnel Certification
Requirements
Summary of Critical Elements of Personnel
Application
Summary of Renewal and/or On-Going Personnel
Quality Control Requirements
Summary of Term of Certification
Emission Test Requirements
Initial and Renewal Laboratory Certification
On -Going Laboratory Quality Control
Initial Operator Certification
On -Going Operator Quality Control
Flow Sheet Breakdown - Laboratory Certification
Flow Sheet Breakdown - Laboratory Quality Control . . .
Operator Certification - Work Flow Sequence
Analysis
Laboratory Facility Classification
Ideal Man-Hour Estimates for Laboratory
Certification Activities
Inspector Office Burden, Initial Application
Processing
Total Inspector Office Burden
Inspection Team Numerical Structure
. . £.--±7
2-51
2-52
2-54
2-55
3-2
4-2
4-4
4-6
4-7
5-3
5-27
5-36
6-5
6-7
6-9
6-10
6-11
XV
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TABLES (Continued)
6-6.
6-7.
6-8.
6-9.
6-10.
6-11.
6-12.
6-13.
6-14.
6-15.
Inspection Visit Man-Day Requirements
Supervisory Workload
Inspector Travel Schedule - Domestic
Laboratories
Inspector Travel Schedule - European
Laboratories
Inspector Travel Schedule - Japanese
Laboratory
Inspector Travel Schedule - Overall
Travel Expenses for Inspection Visits
Technical Work Areas
EPA Laboratory in Europe and Japan; Workload
and Staffing Estimates
Cost Estimates for EPA Laboratories in
Europe and Japan
6-12
6-13
6-15
6-16
6-17
6-18
6-20
6-22
6-42
6-43
XVI
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HIGHLIGHTS
An analysis was made of the work task activities that would be
required of an EPA group in the process of implementing a program whereby
independent testing laboratories (and their test operators) would be certified
as to their capability to perform vehicle exhaust emission tests in accordance
with the requirements of 40 CFR 85. This analysis effort included the selec-
tion and definition of the basic certification procedures to be used in the pro-
gram, and resulted in estimates of staffing and scheduling requirements as
well as costs likely to be incurred if such a certification program were in
fact implemented by EPA.
To provide the basis for the selection of the certification pro-
cedures and methods used in the analysis, an extensive review was conducted
of the procedures and practices of six federal and state regulatory agencies
who have responsibility for laboratory or operator certification or licensing.
This review indicated a concensus as to basic principles of certification
requirements and implementation techniques; this concensus was drawn upon
in formulating the basic structure of the laboratory certification program
analyzed in this study.
To establish specific numerical estimates for personnel,
schedules, and costs, it was necessary to establish a baseline scenario of
emission test laboratories to which the program would be assumed to apply.
A review led to the conclusion that about 17 independent laboratories could
reasonably be expected to be early applicants (within a year) to the proposed
certification program. This total was composed of 12 in the continental U.S. ,
4 in Europe, and 1 in Japan. A longer-term look indicated that about 26
laboratories might be involved within a few years (18 domestic, 6 in Europe,
and 2 in Japan).
of Federal Regulations, Title 40, Part 85
H-l
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All of the detailed analyses of this study were based on the
near-term group of 17 laboratories. However, for comparative purposes,
cost estimates were made for EPA-owned-and-operated emission test labo-
ratories in Europe and Japan (one in each location).
The following are brief highlights summarizing the major
aspects of the study results.
H.I
H.I.I
LABORATORY CERTIFICATION PROGRAM
ELEMENTS
Initial and Renewal Certifications
The basic elements of the laboratory initial (and renewal) certi-
fication process are the use of (a) a detailed application form and (b) a compre-
hensive inspection of the applicant laboratory to verify the information con-
tained in the application. A 24-month certification period was selected as
appropriate, in conjunction with the on-going quality control procedures delin-
eated below. The major work activities of the EPA laboratory certification
group are:
a. Application Processing -- The applicant is required to
submit a detailed application which states compliance with
the requirements of 40 CFR 85. The EPA laboratory
certification group must make a paragraph-by-paragraph
determination of compliance, based on the facts stated in
the application, prior to approving for and scheduling an
inspection visit to the laboratory.
b. Laboratory Inspection -- The applicant laboratory is visited
by a team of EPA certification inspectors who perform a
detailed examination of the general facility, equipment,
instruments, and operational procedures, as well as veri-
fying the presence of the requisite certified operator(s) on
the laboratory staff. The results of this inspection are key
inputs to a final EPA staff review which results in issuance
or denial of certification.
H-2
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H.I.2 On-Going Quality Control
Control of the quality of work performed by the certified labo-
ratory prior to the certification renewal time is accomplished by a number of
on-going quality control techniques, including:
a. Scheduled Inspections -- An EPA inspection team visits the
laboratory at scheduled 6-month intervals. This inspection
of the laboratory is similar to that made for initial certifi-
cation purposes, but less extensive in nature. Major
emphasis is placed on (a) determining if the key calibration
and test procedures are being followed, and (b) ensuring
that the calibration schedules for key equipment are in
compliance with requirements.
b. Unannounced Inspections -- Less extensive random inspec-
tions of the laboratory are made between scheduled inspec-
tion periods. These inspections are principally concerned
with (a) checking for certified personnel and (b) examina-
tion of records to verify calibration frequency and major
instrument and equipment maintenance activity. However,
the EPA inspectors may request the demonstration of
equipment, operation, calibrations, etc., which in their
judgment may be necessary.
c. Transmittal of Data and Information -- The laboratory is
required to transmit to EPA (a) a complete set of data
(raw and reduced) for each certified test performed by the
laboratory, and (b) any change of status of personnel,
equipment, procedures, etc. This permits on-going sur-
veillance of the quantity and quality of the data being taken,
and enables the opportunity to make timely re-inspections
of the laboratory if any changes in the facility so indicate.
d. Gas Analysis Cross-Checks -- On a quarterly basis, EPA
sends gas cylinder standards "unknowns" to the labora-
tory for measurement and identification on the laboratory
instruments to verify their accuracy. In addition, the labo-
ratory sends some of its span and calibration gas cylinders
to EPA, for "naming" on EPA's equipment. Although this
will normally be done at the option of the laboratory, it
may be requested by EPA in the case of analysis discrep-
ancies.
Any discrepancies discovered by EPA in any element of the
above quality control processes can be the basis for:
a. Suspension of certification
b. The requirement for changes in laboratory equipment,
operations, procedures, etc.
H-3
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c. An additional inspection for further surveillance of
the laboratory
H.2 OPERATOR CERTIFICATION PROGRAM
ELEMENTS
H.2.1 Initial and Renewal Certification
The basic elements of the operator initial (and renewal)
certification process are the use of (a) a detailed application form and (b) both
written and practical tests to verify the capability of the operator to perform
certified tests in accordance with requirements. A 24-month certification
period was selected as appropriate, in conjunction with the on-going quality
control procedures delineated below. The major work activities of the EPA
laboratory certification group are:
a. Application Processing -- The applicant is required to sub-
mit a detailed application which on its face indicates that
the operator has the requisite minimum job experience and
talents to perform certified vehicle tests. The preferred
approach is to have the laboratory employing the operator
to both verify the job experience requirement and recom-
mend that the applicant be certified. However; an alterna-
tive path would be for the operator to apply directly to
EPA for certification. In either case, the EPA laboratory
certification group must make a determination of com-
pliance with requirements, based on the facts stated in the
application, prior to approving for and scheduling both
written and practical tests.
b. Written Examinations -- Each applicant is required to
take and pass a written examination which is designed to
assure a specified minimum level of knowledge and
expertise with regard to EPA exhaust emission regulations
and the theory with regard to emission measurements made
in compliance with EPA regulations. A preferred approach
is to administer this examination in conjunction with an
inspection visit made to the laboratory employing the appli-
cant. If the applicant has applied directly to EPA, then
such examinations would probably have to be given at the
EPA Ann Arbor test laboratory.
c. Practical Tests -- Each applicant is required to take and
pass a practical or "hands-on" test during which the appli-
cant is required to demonstrate his proficiency with regard
to instrument and equipment operation, calibration, and
H-4
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maintenance. As in the case of written examinations, it is
preferred that such practical tests be given at the employer's
facility. If direct application to EPA is permitted, these
practical tests would have to be given at the EPA Ann Arbor
test laboratory.
H. 2.2 On-Going Quality Control
The on-going quality control of the operator is accomplished in
conjunction with laboratory quality control. First, the operator is required
to verify (by signature) that the certified test data submitted to EPA by the
laboratory has been performed under his surveillance and control. This per-
mits EPA to screen the submitted test data for compliance with procedures.
Second, the operator can be required to participate in or perform any tests,
calibrations, or other checks requested by EPA inspectors at times of labo-
ratory inspections (scheduled or unannounced). This permits direct obser-
vation of the operator's performance and techniques.
H.3 STAFFING REQUIREMENTS
It is estimated that a laboratory certification group consisting
of seven inspectors and one supervisor is adequate to perform the certification
activities listed above (H. 1 and H. 2) for the near-term scenario of 17 labora-
tories and 34 operators (two operators at each laboratory). In addition,
clerical support would be required for paperwork processing and filing.
On the above basis, each inspector would be required to make
an average of 16 trips per year, spending an average of 72 days per year on
the road (counting travel time). This also includes an average of three week-
end days per year travel time, in conjunction with a European inspection trip.
The above time spent out of the office represents approximately
32 percent of an inspector's total work time. A comparable figure is 27 per-
cent for examiners of the Atomic Energy Commission office which licenses
nuclear power plant operators. Increasing the EPA staff from seven inspec-
tors to eight could reduce the field-plus-travel time to about 60 days per year
per inspector or approximately 27 percent of the total work time.
H-5
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H.4 SCHEDULING IMPLICATIONS
Under the worst-case condition of simultaneous application for
certification by 17 laboratories (and their test operators), the initial
certification process can be completed in from 7 months to 1 year with the
above eight-man laboratory certification group staff, the exact time value
depending upon the technical complications encountered in application process-
ing. This time allotment also includes all scheduled and unannounced facility
inspections which would come due during the period for those laboratories
being certified first.
If an additional three inspectors were made available during
this worst-case initial certification period, the required time could probably
be reduced to less than 6 months.
The likely result of such a worst-case situation would be to
produce an undesirable, asymetrical certification cycle. That is, there would
be a preponderance of renewal applications and inspections coming due within
a period of from a few months to a year. This can be avoided if EPA uses the
discretionary option of extending (or shortening) the certification period of
selected facilities. This technique can be used to smooth out the certification
cycle and produce a more uniform workload for the laboratory certification
group.
H.5 COSTS
If a staff of seven inspectors and one supervisor is assumed at a
burden rate of $50, 000 per position per year, the cost of the initial 17 labora-
tory certification program would be approximately $400, 000 staff burden plus
$60, 000 travel expenses, for a total annual cost of approximately $460, 000.
The cost of certifying just the four European and one Japanese
laboratory (plus operators) is estimated to be one-third of the total program
cost, or approximately $156,000 per year ($120,000 staff burden plus $36,000
travel cost).
A cost estimate was also performed for the special case of
EPA-owned-and-operated emission testing laboratories in Europe and Japan
(one at each location). The estimate was based on facilities and personnel
H-6
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to perform near-term vehicle certification tests of 360 and 210 per year,
respectively. The total cost to perform 570 certification tests per year in
these two foreign laboratories is approximately $900, 000 per year, or
$1600 per certification test. The equivalent figure for EPA Ann Arbor
testing is estimated to be approximately $1000 per test when performing about
3100 certification tests annually.
The higher cost per test of the foreign laboratories is a result
of the inherently lower personnel and equipment utilization efficiency of a
small facility as compared to that of a much larger one. Not until the volume
of testing could justify at least three or four test cells per laboratory could
the costs per test become significantly closer to the Ann Arbor level.
H.6 MANAGEMENT ORGANIZATION OPTIONS
Since the initial laboratory certification program manpower
requirements consist principally of seven or eight inspectors plus one super-
visor, it would appear more utilitarian and effective to initially organize the
group as a section or branch within an existing branch or division of the Office
of Mobile Source Air Pollution Control (OMSAPC). This would enable the
new laboratory certification group to utilize existing lines of management
control and clerical services. Also, it would not divert their time to nonpro-
ductive activities which are often associated with the formation of a totally
new organizational structure.
In the longer term, it is expected that there will be an
increase in the number of personnel assigned to the group because of (a) an
increase in the number of certified laboratories covered by the program,
(b) the need to expand and develop additional written and practical examina-
tions for the operators, and (c) an increased clerical work load, particularly
with respect to retention of records. Because of these factors, it may be
advisable in the long run to provide a more formal organizational structure
for the laboratory certification group.
One such option would have the "laboratory certification group"
organized as a branch of an existing OMSAPC division in Ann Arbor. Three
H-7
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sections would be included in accordance with the three principal functional
task areas:
a. A "Certification Processing Section" would be charged
with responsibility for ensuring that all in-office certifi-
cation activities are accomplished in a timely and effec-
tive manner. Corollary functions would include (a) the
development of examinations for operators, and (b) changes
and updating of certification regulations and forms. When
the inspectors are not on laboratory field inspections, their
efforts would be available to this section.
b. An "Operations Section" would be charged with the
responsibility of conducting all field activities, including
the scheduling of the inspectors for each trip and the
coordination required between the laboratory and the labo-
ratory certification group.
c. A "Clerical Section" would be charged with all paperwork
processing, filing, and information storage functions. In
the long term such a separate clerical office section may
be essential for efficient operation of the laboratory certi-
fication group. This is particularly true since the inspec-
tors are engaged in field work for a high percentage of the
time.
H.7 PROGRAM START-UP CONSIDERATIONS
H.7.1 jnspector Training
It is unlikely that a sufficient number of personnel will be
available initially who satisfy the requirements for appointment as an
"inspector", including essential recent "hands-on" experience with emission
test equipment. Therefore, a training program would have to be instituted
prior to full-scale implementation of the certification program. This program
should consist of working in the EPA Testing Laboratory at Ann Arbor in the
areas of basic instrument and equipment operation, calibration, maintenance,
and trouble-shooting. It is estimated that approximately 3 months full time
work in these areas would be required to establish the necessary knowledge
and skills.
H.7.2 Additional Start-Up Manpower
Because of potential scheduling problems at program initiation
(item H.4), it would be advantageous to have three additional men of the
H-8
-------
"inspector" level available during the first 6 months or so of the program.
These additional inspectors could be borrowed temporarily from other Ann
Arbor activities (e.g. , Emission Testing Laboratory, Certification and Sur-
veillance Division, or the Emission Control Technology Division).
H.8 LONGER-TERM IMPLICATIONS
It is considered likely that some 26 independent laboratories
could be involved in the program after a few years. A review of the analysis
details used to obtain the results for the near-term scenario of 17 laboratories
leads to the conclusion that, to a first approximation, both personnel staffing
requirements and travel expenses would be increased in direct proportion
with the increase in the number of certified laboratories. For 26 laboratories,
there would be a staff requirement of 11 to 13 inspectors and 2 or 3 super-
visory or administrative positions.
H-9
-------
-------
SUMMARY
S. 1 INTRODUCTION
Except for a few heavy duty vehicle (HDV) emission
certification tests performed for EPA by the Southwest Research Institute
and those emission tests permitted by EPA to be performed abroad, all
other emission certification tests [including light duty vehicles (LDVs) and
light duty trucks (LDTs)J are performed at the emission testing laboratory
of the EPA located in Ann Arbor, Michigan. For example, foreign auto-
makers have only the 4000- and 50,000-mile LDV emission certification
tests performed at EPA and are allowed to send in their own test results for
the intermediate mileages.
A significant increase in certification test work load, such
as could be caused by new certification regulations (e.g. , motorcycles,
truck CVS tests, etc. ), increased frequency of foreign vehicle emission
certification tests, and retrofit device tests, might require either an increase
in the Ann Arbor testing laboratory facilities and personnel, or a means
whereby independent laboratories could be certified to perform emission
tests.
This potential problem is further accentuated by the fact that
there are a number of inventors or other entrepreneurs who wish to evaluate
new devices or ideas applicable to emission control for new cars, after-
market parts, or used-car retrofit. Currently, the Ann Arbor laboratory
cannot accommodate these people and must refer them to a list of about ten
independent laboratories who do perform exhaust emission testing. At the
present time there is no mechanism for certifying that such laboratories have
the facilities, equipment, and personnel necessary to meet the emission
testing requirements published by EPA in the Federal Register.
Therefore, the present study was initiated to explore and
characterize alternative means whereby laboratories such as these could
S-l
-------
be certified. This characterization could aid in the implementation of a
laboratory certification process and/or enable a tradeoff between such
laboratory certification and the continuation of all emission certification
testing by EPA.
With regard to manpower and cost estimations, major
emphasis was focused on an initial scenario in which it was assumed that
17 such independent emissions testing laboratories would apply to EPA for
certification. These laboratories were geographically distributed as follows:
12 laboratories in the continental United States, 4 laboratories in Europe
(e.g., England, France, Italy, Germany), and 1 laboratory in Japan. A
limited amount of effort was devoted also to estimating the manpower and
cost requirements to EPA for staffing and operating EPA-owned emission
test facilities in Europe and Japan (one laboratory, at each location).
S.2 CONTEMPORARY CERTIFICATION ACTIVITIES
A review of contemporary on-going certification activities
was made by contacting a number of federal and state regulatory agencies
who have responsibility for laboratory or operator certification or licensing.
The purpose of this review was to determine (a) what their regulatory duties
were, and (b) how they go about implementing their functions, particularly
with regard to organizational structure, work flow sequence, number and
types of personnel involved, and work load. The agencies contacted and the
type of information obtained from each is shown in Table S- 1.
This review has resulted in a comprehensive picture of
established regulatory procedures as used in the certification process in
general. There is a consensus as to basic principles of certification
requirements and implementation techniques; this consensus was drawn upon
in selecting the basic elements of the laboratory certification program
analyzed in this study (delineated in Section S.3). The consensus as to
general functional requirements is delineated below.
S-2
-------
Table S-l. Data Sources
Agency /Company
Type of Information
Federal Aviation Administration
(FAA)
Atomic Energy Commission (AEC)
California Bureau of Automotive
Repair (BAR)
California Department of Public
Health, Laboratory Field
Service (DPH)
Pennsylvania Department of
Transportation, Bureau of
Traffic Safety (BTS)
New Jersey Department of
Environmental Protection (DEP)
Certification activities related to:
a. Aircraft repair stations
b. Aviation mechanic training
schools
c. Flight and ground schools
d. Aviation mechanics
e. Designated mechanic
examiners
f. Designated pilot examiners
g. Flight ratings
Certification activities related to
operators of nuclear power plants
Certification activities related to:
a. Motor vehicle pollution con-
trol (MVPC) device installers
b. MVPC stations
Certification activities related to:
a. Clinical laboratories
b. Clinical laboratory
technologists
Certification activities related to:
a. Safety inspection mechanics
b. Safety inspection stations
Voluntary program for training
mechanics
S-3
-------
S.2.1 Facility Certification
S.2.1.1 Initial Certification Requirements
An application for certification plus inspection visits to
verify the information contained in the application are the principal tools
used in the facility certification process. Testing, per se, is not involved,
except in the case of an FAA-approved flight school where the chief flight
inspector is required to undergo a standardization flight check. Application
fees are required in some instances.
All agencies require that the application explicitly list
(a) certified personnel on the staff and (b) adequate definition and description
of the facility's physical plant and equipment. Aside from training schools,
the other information required, in some instances, relates to personal
information on the owner, operator, or directors of the facility. The infor-
mation required in the application is considered necessary to make both
initial and final assessments of compliance with regulatory requirements.
S.2.1. 2 Renewal and/or On-Going Quality Control
Requirements
In most cases, extensive inspection visits/checks are used
for the quality control of facilities. In every case, regular inspection visits
are used; however, the frequency of the scheduled inspections varies from a
few months to 2 years, depending upon the nature of the particular facility
involved. In four of the six cases examined, additional special checks are
included in the quality control process.
S.2.2 Personnel Certification
S.2.2.1 Initial Certification Requirements
As in the case of facility certification, all agencies use the
application as a principal tool for personnel certification. However, testing
(both written and practical) instead of inspection visits or contacts (as in
the case of facility certification) is the other principal tool used in personnel
certification. Except for the Designated Mechanic Examiner (DME) and
S-4
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Designated Pilot Examiner (DPE) ratings of the FAA, all other personnel
ratings are required to pass a written examination. Even in the DME and
DPE cases, however, these same personnel have previously passed a
written examination when obtaining the prerequisite aviation mechanic or
flight rating. Practical tests are required (or optional) in six of the eight
cases examined. Medical examinations are required only in those cases
(FAA flight ratings and AEC nuclear power plant operators) where inadver-
tent medical problems could lead to substantial property damage or personal
injury as a result of operator incapacitation.
In all cases there are minimum requirements for prior
experience and/or qualifications that must be included. For the FAA DME
and DPE ratings, prior certification in the appropriate aviation mechanic
or flight rating must be shown. In three of the eight cases examined, the
facility employing the operator is required to request and recommend that
the operator be certified.
S.2.2.2 Renewal and/or On-Going Quality Control
Requirements
Except for AEC operators and the FAA DME and DPE ratings,
very little actual quality control is exercised over personnel. In these cases,
where operator proficiency may be considered to be more closely related to
potential property damage or personnel injury, periodic inspection contacts
and checks are made. The AEC operator is required to participate in a
requalification program which is essentially a continuous updating and
retraining program.
S.2.3 Term of Certification
There is considerable variability in the term of certification
for both facilities and personnel; in both cases the term of certification
varies from 1 year to valid indefinitely. For those facilities having definite
certification period durations (i.e., other than indefinite validation), the
S-5
-------
renewal period is 2 years or less. Similarly, for personnel having definite
certification periods, in four of the six cases examined the period was also
2 years or less.
However, there does not appear to be any real consensus as
to term of certification, either for facilities or personnel. Rather, it
appears the term of certification is somewhat arbitrarily selected in each
case to fit the needs of the particular organization involved in the certification
process.
S.3 PRINCIPAL, ELEMENTS OF LABORATORY
CERTIFICATION PROGRAM
A set of discrete basic requirements and procedures was
selected to form the basis of a sound certification program for both labora-
tories and operators. These functional task selections were made after
reviewing the status of established regulatory procedures used by other
federal and state certification agencies (Section S. 2) and noting the consensus
as to functional task requirements in the comparable certification processes.
Also considered in the selection process were the specific requirements of
40 CFR 85 regarding facilities, procedures, and test operations.
S.3.1 Laboratory Certification
S.3.1.1 Initial Certification
Table S-2 lists the specific functional tasks required of EPA
and the laboratory requesting certification, both for initial certification and
renewals.
The EPA tasks are directed to:
a. Application form preparation
b. Application processing and review after receipt
Code of Federal Regulations, Title 40, Part 85.
S-6
-------
Table S-2. Initial and Renewal Laboratory Certification
en
LABORATORY TASKS
• PREPARE AND SUBMIT APPLICATION (FOR
SUB-PART RATING DESIRED)
• LISTING CERTIFIED OPERATORS ON
STAFF
• IDENTIFY FACILITY, EQUIPMENT, AND
TEST PROCEDURES USED IN ACCORDANCE
WITH 40 CFR 85 REQUIREMENTS
• PROVIDE OTHER INFORMATION
• DIRECTORS
• RELATIONSHIPS WITH OTHER
ORGANIZATIONS
• FINANCIAL AND BUSINESS DATA
EPA TASKS
• PREPARE APPLICATION FORMS
• PROCESS AND REVIEW APPLICATION DETAILS
• SCHEDULE INSPECTION VISIT
• PERFORM INSPECTION OF LABORATORY
• TESTING
• CALIBRATION
• PROCEDURES
• EQUIPMENT
• REVIEW INSPECTION RESULTS
• ISSUE OR DENY CERTIFICATION
-------
c. Laboratory inspection
d. Final review of inspection results and determination
as to issuance or denial of certification
The laboratory tasks are solely concerned with preparing
and submitting the application for certification to EPA. The basic informa-
tion required, as noted in Table S-2, would be concerned with (a) certified
operators on the staff of the laboratory, (b) a complete description of the
facility, equipment, and test procedures used by the laboratory (to permit
an initial determination as to compliance with 40 CFR 85 requirements),
and (c) other organizational and financial data which might be relevant to
the desirability or suitability of certifying the laboratory for emission test-
ing purposes. For example, if the laboratory were a part of another
organization which manufactured or sold retrofit or emission-control-related
parts, it might be considered a conflict of interest to permit certification of
the laboratory.
Figure S-1 summarizes the principal elements of initial (and
renewal) certification and their interrelationship in flow-sheet format.
S.3.1.2 On-Going Quality Control
The specific functional tasks selected for quality control are
listed in Table S-3. The basic EPA tasks consist of:
a. Periodic scheduled (semiannual) laboratory inspections
b. Unannounced (random) laboratory inspections
c. Naming the laboratory's calibration gases on EPA
equipment
The scheduled inspections would be extensive and consist of test observations;
inspection of calibration procedures; checking for certified personnel; exami-
nation of facility data and records; and observation of the general facility,
equipment, and operations. The unannounced inspections would be less
extensive in nature, and would be principally directed to verifying that proper
calibration schedules were being followed.
S-8
-------
FLOW SHEET 201
C/2
riPELc--.
TCHANGES' _
I BY LAB .w
'DROP .
(APPLJCAJ
JION /
A
APPLICATION SATISFACTORY
II
EPA s
PROCESSING "*\
SFACTORY
CATION FUNDAMENTALLY UNSAT
0.
a.
tr
%
\
1
XIV
K
-*
/
in
CHANGES
1-
NOTIFY
APPLICANT
*~
/DENY \
— REASONS -HCERTIFI-1
\CATION /
VII
,, . REVIEW ./
v I vi
RESPONSE TRANSMIT
^^ DV ^^ RESULTS
TO FPA
APPLICANT lUtHA
CHANGES UNSATISFACTORY
CORRECTION LOOP
E
U
T
S
E
t
OE
TE
1 VIII
:EPA
SCHEDULE _k
INSPECTION
VISIT
\ ,x
SERVE COMPLETE
ST OF SUB-PART
TING APPLIED FOR
l
PA INSPECTION TEAM SPLIT
P FOR DETAILED OBSERVAT
ESTING, OR CALIBRATION 0
PECIFIC PROCEDURES AND
QUIPMENT
MINOR C
INSPEC"
NSPECTION _^/
VISIT ^^^*x
1ST VISIT
ION,
F
:HANGE
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A. SUB
^v vis
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IT
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TS
XIII
AT EPA
DISCRETION,
INSPECT ONLY
THOSE AREAS
FOUND TO BE
DEFICIENT
X , • i
AT B \ c \
\
FUELS VEHICLE GAS ANALYSIS
HANDLING PREP INSTRUMENTS
1 1
CHANGES
REQUIRED
D T
GAS
HANDLING
SYSTEM (CVS)
' XI
EPA
REVIEW
A
V
1 F
\ o*
1 DYNOS 1 AUXILIARY
| DYNU5 | EQUIPMENT
1
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/(SSUE >
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1 1
nrrc.f\L. uti^iML. ~
1 OF CERFICIATIONJ
Figure S-l. Initial and Renewal Laboratory Certification
-------
Table S-3. On-Going Laboratory Quality Control
en
h-^
o
LABORATORY TASKS
• TRANSMIT TO EPA COMPLETE DATA SET FOR
EACH CERTIFIED TEST MADE
• TRANSMIT TO EPA ANY STATUS CHANGES
• EQUIPMENT LOSS OR CHANGE
• CERTIFIED OPERATORS
• ETC.
• MAKE QUARTERLY MEASUREMENTS OF
EPA GAS CYLINDER "UNKNOWNS"
• TRANSMIT TO EPA
• PERFORM ANY TESTS, CALIBRATIONS, OR
OTHER CHECKS REQUIRED BY EPA
DURING INSPECTION VISITS
EPA TASKS
• PERIODIC SCHEDULED INSPECTIONS OF LABORATORY
• SEMI-ANNUAL
• OBSERVE TESTS
• CHECK FOR CERTIFIED PERSONNEL
• INSPECT CALIBRATION PROCEDURES
• EXAMINE DATA AND RECORDS
• OBSERVE STATUS OF
• FUEL HANDLING OPERATIONS
• AUXILIARY EQUIPMENT
• GENERAL FACILITY
• UN-ANNOUNCED LABORATORY INSPECTIONS
• RANDOM, AVERAGE 2 PER YEAR
• VERIFY PROPER CALIBRATION SCHEDULES
• NAMING OF LABORATORY'S CALIBRATION
GASES ON EPA EQUIPMENT
-------
The laboratory would be required to transmit a complete set
of emission test data to EPA for each certified test made; this would permit
the opportunity for a direct observation of the quality of the test data.
Quarterly measurements of EPA gas cylinder "unknowns" would be required
to verify the laboratory's gas sampling instrumentation accuracy. During
EPA inspection visits, the laboratory would be required to perform any
tests, calibrations, or other checks required by EPA inspectors. In
addition, any changes in certified operators, equipment loss or change, etc.
would have to be provided to EPA to permit temporary suspension of certi-
fication or reinspection, if necessary.
Figure S-2 summarizes the principal elements of the on-going
quality control process in flow-sheet format.
S.3.2 Operator Certification
S.3.2.1 Initial Certification and Renewals
Table S-4 lists the specific functional tasks required of EPA
and the operator requesting certification, both for initial certification and
renewals. The principal EPA tasks are directed to:
a. Preparing application form
b. Processing and reviewing application after receipt
c. Preparing, administering, and grading written
examinations
d. Preparing, administering, and grading practical
examinations
e. Granting or denying certification
The operator's tasks are concerned with:
a. Preparing and submitting the application
b. Taking and passing the written examination
c. Taking and passing the practical examination
With regard to the application, a preferred approach is to have the employer
request that the operator be certified and verify the minimum .job experience
S-ll
-------
FLOW SHEET 204-
HNPUTSN
TO EPA '
LAB
CERT.
VBRANCH>
UN-ANNOUNCED
INSPECTION
(random)
QUARTERLY
MEASUREMENT
OF EPA GAS
CYLINDERS
("unknowns")
NAMING OF LAB'S
CALIBRATION GASES
ON EPA EQUIPMENT
STATUS CHANGE TRANSMITTAL
FROM LAB: EQUIPMENT,
PERSONNEL, PROCEDURES.
REQUEST FOR AND/OR
NOTICE OF CHANGE
J
1
/*
^\
<
-
-
REVIEW BY EPA
LAB CERTIFICA-
TION BRANCH
1
C/l
I
EFFECTIVE
IMMEDIATELY
I 1
I APPEAL L.
I SUSPENSION p
I I
I REASONS
Jv
Y
[CORRECTIVE '
ACTION BY I
I LAB I
REQUIRED CHANGES,
OR CLARIFICATION
OF DISCREPANCY
AT EPA OPTION, MAY
MAKE UN-ANNOUNCED
INSPECTION, OR SPECIAL
VISIT, OR AWAIT NEXT
SCHEDULED VISIT AS
APPROPRIATE
'LET \
' CERT. '.
*\ BE I
'.REVOKED/
Xx ^
CORRECTIVE
ACTION NOT
COMPLETE
APPRAISAL
BY EPA I
NOTE:
1) ONE RE-INSTATEMENT
REQUEST PERMITTED FOR
EACH SUSPENSION NOTICE
2) A SUSPENSION WHICH IS NOT
REMOVED WITHIN 6 MONTHS
RESULTS IN REVOKING
CERTIFICATION
3) IN THIS CASE, CERTIFICATION
CAN BE ATTAINED AGAIN ONLY
BY MAKING A NEW INITIAL
APPLICATION (flow sheet 201)
AFTER A SPECIFIED DELAY
Figure S-2. Laboratory Certification - On-Going Quality Control Process
-------
Table S-4. Initial Operator Certification
*
en
OPERATOR TASKS
• PREPARE AND SUBMIT APPLICATION (FOR
SUB-PART RATING DESIRED)
• HAVE EMPLOYER REQUEST THAT HE
BE CERTIFIED**
• HAVE EMPLOYER VERIFY APPLICANT
HAS MINIMUM JOB EXPERIENCE
REQUIREMENTS**
• TAKE AND PASS WRITTEN EXAMINATION
• AT EMPLOYERS FACILITY
• TAKE AND PASS PRACTICAL TEST
• AT EMPLOYERS FACILITY
* SAME TASKS INVOLVED IN CERTIFICATION RENEWAL,
EXCEPT FOR VERIFICATION OF EXPERIENCE
**AN ALTERNATIVE PATH IS FOR THE APPLICANT
TO APPLY DIRECTLY TO EPA FOR EXAMINATION
AT EPA ANN ARBOR FACILITIES
EPA TASKS
• PREPARE APPLICATION FORMS
• PROCESS AND REVIEW APPLICATION DETAILS
• SCHEDULE EXAMINATIONS
• PREPARE WRITTEN EXAMINATION
• ADMINISTER AND GRADE WRITTEN EXAM
• PREPARE PRACTICAL TEST
• ADMINISTER AND GRADE PRACTICAL TEST
• GRANTOR DENY CERTIFICATION
-------
requirements of the applicant. It would appear, however, that an alternative
path should be available whereby the applicant can apply directly to EPA.
Similarly, it would be preferred to have the written and practical tests given
at the employer's facility, but it may be necessary to permit such testing at
the EPA test facility.
Figure S-3 summarizes the principal elements of the initial
(and renewal) certification process in flow-sheet format.
S.3.2.2 On-Going Quality Control
As noted in Section S. 2, ordinarily there is very little on-
going quality control exercised over operators (except in the specific case
of AEC-licensed nuclear power station operators). However, as listed in
Table S-5, the nature of the task functions selected for the laboratory
certification process makes it possible to exercise a reasonable degree of
control over the quality of the work performed by the operator.
First, the operator is required to verify (by signature) that
the certified test data submitted to the EPA by the laboratory has been per-
formed under his surveillance and control. This permits EPA to screen
the submitted test data for compliance with procedures. Second, the
operator can be required to participate in or perform any tests, calibrations,
or other checks requested by EPA inspectors at times of laboratory inspec-
tions (scheduled or unannounced). This permits direct observation of the
operator's performance and techniques.
S.3.3 Use of the Functional Tasks
The selected functional tasks, as described above, are the
basic building blocks of the laboratory and operator certification processes.
They provide the basis for further breaking down the certification process
into more definitive work elements (or steps) which can be developed to
ensure meeting the specific requirements of 40 CFR 85 as well as permitting
a simple and logical sequencing of required work elements. The so-developed
work flow sequences are described in Section 5.
S-14
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FLOW SHEET 101
CO
i
i—*•
en
NOTIFY
APPLICANT:
a| FAILURE OF
ANY PART
b| CATEGORIZE
INCORRECT
ANSWERS AND
DEFICIENT
PROCEDURES
NOTE 1- AN ALTERNATIVE PATH IS FOR THE APPLICANT
TO APPLY DIRECTLY TO EPA, FOR EXAMINATION
AT EPA ANN ARBOR FACILITIES-
IN THIS CASE, ALL BLOCKS OF THIS FLOW SHEET
WHICH REFER TO "EMPLOYER" ACTIONS, MUST
BE PERFORMED BY APPLICANT. ALL OTHER
PARTS OF FLOW SHEET ARE UNCHANGED.
APPLICANT IS RESPONSIBLE FOR PERSONAL COSTS.
Figure S-3. Initial and Renewal EPA Operator Certification
-------
Table S-5. On-Going Quality Control
to
i
OPERATOR TASKS
VERIFY CERTIFIED TEST DATA
TRANSMITTED TO EPA
PARTICIPATE IN OR PERFORM ANY
TESTS, CALIBRATIONS, OR OTHER
CHECKS REQUESTED BY EPA AT
TIMES OF SCHEDULED OR UN-ANNOUNCED
INSPECTIONS OF LABORATORY BY
EPA PERSONNEL
EPA TASKS
SCREEN CERTIFIED TEST DATA
SUBMITTED FOR COMPLIANCE WITH
PROCEDURES
OBSERVE OPERATOR'S PERFORMANCE
DURING SCHEDULED AND UN-ANNOUNCED
INSPECTIONS OF LABORATORY
-------
S.4 PROGRAM IMPLEMENTATION REQUIREMENTS
S.4.1 Generalized Personnel Requirements
The basic EPA staff position which is required for the
proposed laboratory certification program is termed "Inspector" in this
report. This position involves participation in all aspects of certification
activity -- application processing, office work, panel review sessions,
operator examination, and facility inspections. The job requirements of an
inspector fall into three main categories. The first requirement is com-
plete familiarity with both theory and practice of instrument and equipment
operation -- including details of operation, calibration, and maintenance.
There is no alternative to prior "hands-on" experience in this case. If a
person does not have a recent background in this area, a job training pro-
gram, probably conducted at the EPA Ann Arbor testing laboratory, would
be required.
The second requirement is that the inspector be intimately
familiar with all applicable provisions of 40 CFR 85, including all recent
EPA promulgations in the Federal Register- and their implementation.
The third requirement, which is nontechnical, is that the
inspector be capable of working well with people of widely different back-
grounds and at all organizational levels of the certified laboratories. The
inspector position is an important one, and the inspector serves as an EPA
representative both in this country and abroad.
S.4. 2 Staffing Requirements
S.4. 2.1 Estimate of Laboratories to be Certified
To establish specific numerical estimates for personnel,
schedules, and costs, it was necessary to establish a baseline scenario of
emission test laboratories to which the program would be assumed to apply.
A review of this subject led to the conclusion that about 17 independent
laboratories could be reasonably expected to be early applicants (within a
year) to the proposed laboratory certification program. This total was
S-17
-------
composed of 12 in the continental U.S. , 4 in Europe, and 1 in Japan. The
foreign laboratories were assumed to be located as follows: one each in
the vicinity of London, Paris, Rome, and Tokyo, plus one in an unspecified
location in northern Europe. A longer-term look indicated that about 26
laboratories might be involved within a few years (consisting of 18 domestic
laboratories, 6 in Europe, and 2 in Japan). All of the detailed program
implementation analyses of this report were applied to the near-term group
of 17 laboratories.
Available information indicated that the candidate laboratories
could be divided into four classifications based on equipment capabilities.
This facility classification system is defined in Table S-6.
Table S-6. Laboratory Facility Classification
Equipment and Locations
Emissions Test Capability
(For 1975 LDV Testing, Subpart A)
Number of Dynamometers
Number of CVS Systems
Number of Complete Sets of
Gas Analysis Instruments
Number of Laboratories
Domestic
Europe
Japan
Total
Facility Classification
A
1
1
1
6
2
-
8
B
2
2
1
2
-
-
2
C
2
2
2
3
2
1
6
D
3
3
2
1
-
-
1
S-18
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S.4.2.2 Man-Hour Estimates
Estimates were made of the man-hours required to perform
every operation specified in the work elements presented in Section S.3.
Each class of laboratory was followed through every step of the certification
process, starting with the receipt in the mail at EPA of the completed
application form and proceeding through the various analysis and panel
review phases, the inspection visit, and the final review process prior to
granting certification. This same facility was then subjected to a periodic
and unannounced inspection, in which all steps in the pre- and post-inspection
office work were analyzed, as well as the inspection visit proper. In every
phase of this process, a degree of technical complication was structured
into the analysis which was considered to be representative of a real situa-
tion. In addition, allowances were made to cover work interruption or
competing work assignments.
Personnel requirements were developed based on these man-
hour estimates. The development process consisted of cataloging this infor-
mation in terms of man-day requirements to perform each of the required
functional tasks over the 24-month certification cycle. A distinction was
made between office and field (inspection) work. Each of these two categories
was cataloged for each of the four basic task functions of the laboratory
certification group; namely, initial/renewal application and inspection,
periodic inspection, unannounced inspection, and operator testing. This
resulted in the total inspector office burden shown in Table S-7; a require-
ment for approximately four inspectors.
Similar analyses were performed for the on-site inspection
visit work load for each type of inspection for each class of facility. From
this information, the inspection team numerical structures of Table S-8 were
established. Next, the total man-day requirements for these inspection
visits, including travel time, were computed. This man-day figure must
include the time required for certified operator testing. The latter item is
not included in Table S-8. The results of these calculations on inspection
S-19
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Table S-7- Total Inspector Office Burden
Activity
Initial Inspection
Periodic Inspection
Unannounced Inspection
Operator Testing
A! Man- days
3,
Number of Inspectors
Inspector Office Burden,
Man-days (2-year cycle)
943
456
388
73
1860
4.2
o
Based on 225 work days per year per inspector
Table S-8. Inspection Team Numerical Structure
Facility
Classifi-
cation
A
B
C
D
Initial/Renewal
Inspection
No. of
Inspectors
3
3
3
3
Days of
Visit
2
2
3
3
Periodic Inspection
No. of
Inspectors
2
2
2
2
Days of
Visit
2
2
3
3
Unannounced
Inspection
No. of
Inspectors
1
2
2
2
Days of
Visit
1
1
1
2
S-20
-------
visit man-day requirements are shown in Table S-9, from which it is seen
that the inspection work load is equivalent to approximately a 2-1/2-man-
level staffing. Combining this with the results of Table S-7 for the office
burden gives a requirement for a seven-man staff to handle both the office
and field work associated with the laboratory certification program for 17
independent testing laboratories.
A similar analysis procedure was applied to estimate the
work load associated with the supervision of the activities of the inspection
staff. The results indicated that one supervisory position was required.
S.4.2.3 Scheduling of Inspection Visits
The goal was to establish an efficient scheduling of inspection
trips, consistent with two restrictions. The first restriction is that there
be minimum weekend travel or stay time. This is considered to be an
essential requirement for long-term job acceptability, as the inspector
positions require relatively extensive travel time. The second restriction
is that there be no compromise with the surprise element of the unannounced
inspections, such as would occur by combining them with other visits to the
area in a more time-efficient but predictable manner. Table S-10 presents
the summarized results for all inspection visits, based on a seven-man
inspection staff.
The key results of this analysis are that each inspector must
make an average of 16 trips per year, spending an average of 72 days per
year on the road (counting travel time) which includes an average of three
weekend days per year travel time (in conjunction with a European inspection
trip).
This is a rather high travel load and is probably near the
upper range of a practicable schedule. A travel time reduction down to
about 68 or 69 days per inspector should be readily achievable in practice
by utilizing specific features of the distribution of the applicant laboratories.
If a larger reduction in travel load is considered necessary, this can only
S-21
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Table S-9. Inspection Visit Man-Day Requirements
(2-Year Certification Cycle)
Type of Inspection
Initial / Renewal
(Including Operator
Certification)
Periodic
Unannounced
z
Time, Man-days
Inspection
157
246
112
515
Travel
136
204
208
548
Inspectors Required
Inspectors Required
For Office Burden (Se
Total Inspectors Requ
Total
293
450
320
1063
No. of
Trips
17
51
68
136
1063 _ ,
Man- Trips
68
102
104
274
2 X 225 "'
e Table S-7) 4. 2
Lred
6.6
= 7
Based on 225 work days per year per inspector.
S-22
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Table S-10. Overall Inspector Travel Schedule
(24-Month Certification Cycle)
Type of Trip
Domestic
Europe
Initial /Renewal/
Operator
Unannounced
Japan
z
Man-days
712
146
72
73
1003
Number of Trips
76
4
16
8
104
Man-trips
164
16
24
18
222
Average Inspector Load per Year
Travel Time (work days)
Individual Trip Duration
Trips per Year
Time Between Start of
Successive Trips
Weekend Travel Time
71.7 days
4.5 days
15.9
16.4 work days
2. 9 days (plus that which
may result solely from
time change on foreign
trips)
S-23
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be accomplished (without voiding the basic features of the proposed
certification process) by increasing the size of the inspection staff. Thus,
an eight-man staff would reduce the travel time to about 60 days per year
per inspector.
S.4. 3 Costs
Based on the inspection visit schedule derived in the
preceding section, travel expenses for each inspection trip were computed
in accordance with the following basic procedure. Each trip was assumed
to be a round trip from Ann Arbor, with some trips including one or more
intermediate sites. Airline fare was taken as the coach rate in effect on
the date the calculations were performed. Per diem (lodging plus meals)
was assumed to be $34 per 24-hour day per inspector for domestic trips,
and $50 for foreign trips. Ground transportation estimates were included
for all applicable stages. The summarized results are given in Table S-ll,
which shows a total inspection visit travel expense of approximately $61,000
per year.
If the staff is assumed to consist of seven inspectors and one
supervisor at a burden rate of $50,000 per position per year, the cost of the
laboratory certification program would be approximately $400,000 staff
burden plus $61,000 travel expenses, for a total annual cost of approximately
$461,000.
It should be noted that the travel allowances and costs per
position as used above are made on a different basis than used by EPA for
its own economic projections. The EPA uses a different accounting struc-
ture for personnel costing, full details of which were neither available nor
directly pertinent to the present analysis. The purpose of the present esti-
mate is to indicate the approximate total magnitude of the charges which
should be attributed to the proposed laboratory certification program,
regardless of the details as to how these costs would be distributed internally
by the EPA.
S-24
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Table S-ll. Travel Expenses for Inspection Visits
(2-Year Certification Cycle)
Geographical
Category and
Number of
Laboratories
Domestic (12)
European (4)
Japan (1)
Type of
Inspection
Initial /Renewal0
Periodic
Unannounc e d
z
Initial /Renewal
and Periodic
Unannounc ed
E
f>
Initial /Renewal
Periodic
Unannounced
z
Overall Subtotals
Domestic
Europe
Japan
£
Cost, in dollars
Travela
7,870
11,790
9,700
29,360
14,430
18,700
33, 130
5, 140
7,720
10,290
23, 150
29,360
33, 130
23, 150
85,640
On- site
5,690
9,510
5,460
20,660
9,750
2,980
12,730
860
1,430
990
3,280
20,660
12,730
3,280
36,670
Total
13,560
21,300
15, 160
50,020
24, 180
21,680
45,860
6,000
9, 150
11,280
26,430
50,020
45,860
26,430
122,310
Percent
of Total
27. 1
42.6
30.3
100.0
52.7
47.3
100.0
22.7
34.6
42. 7
100.0
40.9
37.5
21. 6
100.0
aRound trip cost from Ann Arbor to airport of destination
Per diem and ground transportation from airport of destination to return
Includes operator certification
Initial /renewal, operator certification, and periodic inspections combined
in inspection tour
S-25
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S.4.4 Organizational Structure
Since the initial laboratory certification program manpower
requirements consist principally of seven or eight inspectors plus one
supervisor, it would appear more utilitarian and effective to initially orga-
nize the group as a section or branch within an existing branch or division
of the Office of Mobile Source Air Pollution Control (OMSAPC). This would
enable the neophyte laboratory certification group to utilize existing lines of
management control and clerical services.
In the longer term, it is expected that there will be an
increase in the number of personnel assigned to the group in accordance with
an increased number of certified laboratories covered by the program.
There is an additional operational difference which concerns
the development of written and practical tests for operators. In the near-
term structure (first 2 years or so), this task has been assumed to be per-
formed for EPA by an outside contractor. After this period, EPA will have
an option in this regard. One is for EPA to assume this task. This is the
procedure used by the FAA (e.g., aviation mechanic written examinations)
and the AEC (nuclear power plant operator written and practical tests).
Exercise of this option would probably require additional EPA personnel.
Because of the factors of (a) increased number of staff
members, (b) increased clerical work load, and (c) examination development
requirements, it may be advisable in the longer term to provide a more
formal organizational structure for the laboratory certification group. One
such option is delineated in Figure S-4. Here, the "laboratory certification
group" is pictured as a branch of an OMSAPC division in Ann Arbor. Three
sections are included in accordance with the three principal functional task
areas: office technical work, field work, and clerical work. The Certifica-
tion Processing Section is charged with responsibility for ensuring that all
in-office certification activities are accomplished in a timely and effective
manner. In this regard, then, the principal function of this section is
coordination of application processing. Corollary functions would include
S-26
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LABORATORY
AND OPERATOR
CERTIFICATION
GROUP
DIVISION OR
BRANCH
STAFF
• SPECIAL
COORDINATOR
CLERICAL
OFFICE
SECTION
CERTIFICATION
PROCESSING
SECTION
OPERATIONS
SECTION
CLERICAL
PROCESSING
FILING &
STORAGE
REGULATIONS
AND APPLICATIONS
EXAMINATION
DEVELOPMENT
APPLICATION
PROCESSING
COORDINATION
TEST OPERATIONS
AND OPERATOR
EXAMS
FACILITY AND
EQUIPMENT
ANALYSIS AND
INSTRUMENTATION
Figure S-4. Organization of Laboratory Certification Group—A Long-Term Option
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(a) the development of examinations for operators, and (b) changes and
updating of the regulations pertaining to laboratory and operator certifica-
tion, as well as any necessary changes in the application forms. When the
inspectors were not on laboratory field inspections, then, their in-office
efforts would be available to this section for completion of the necessary
work.
The Operations Section would be charged with the responsi-
bility of conducting all field activities, including the scheduling of the
inspectors for each trip and the coordination required between the laboratory
and the laboratory certification group with regard to inspections and other
on-going quality control activities. As noted in Figure S-4, if the number
of inspectors on the staff were large enough, it might be advisable to further
segregate the inspection staff into areas of special expertise or proficiency,
as indicated.
The third section, Clerical, would be charged with all
paperwork processing, filing, and information storage functions. In the long
term, if a sufficiently large number of laboratories and operators apply for
certification, a separate Clerical Office Section may be essential for effi-
cient operation of the laboratory certification group. This is particularly
true because the individual inspectors are assumed to be engaged in field
work for a high percentage of the time.
S.4.5 Special Problems
S.4.5.1 Inspector Training
It is unlikely that a sufficient number of personnel will be
available initially who have the requisite recent "hands-on" experience with
emission control test equipment. Accordingly, a training program would
have to be instituted prior to full-scale implementation of the laboratory
certification program. Such a program could consist of working in the EPA
Testing Laboratory (OPM) at Ann Arbor, under the direction of normal
laboratory line supervision. The work should entail basic instrument and
S-28
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equipment operation, calibration, maintenance, and trouble-shooting. For
a person with no prior experience in these specific areas, but who possesses
the proper technical background and good motivation, it is estimated that
about three months' full-time work under these conditions would be required
to establish the necessary knowledge and skills.
S.4.5.2 Program Startup
A subject of concern is the possible conflict that might arise
on program startup, due to initial overloading of the capabilities of the
laboratory certification group. For example, consider the worst-case
occurrence and assume that all 17 laboratories of the near-term scenario
were to apply immediately upon announcement by EPA of implementation of
the certification program. An analysis was performed for this case with
two three-man teams working on the processing of the applications. Each
team was assumed to work on two applications concurrently. The analysis
resulted in an estimate of from 7 to 12 months required to complete the
processing of all 17 initial applications, depending upon the degree of com-
plexity encountered in the application processing activity. This time allot-
ment accounts for all unannounced and periodic inspections which come due
during the 7 to 12 months for those laboratories which receive early
certification.
The situation may arise in which it is desirable to augment
temporarily the inspection staff during the startup period by borrowing
personnel from other branches or divisions of OMSAPC. This case was
investigated by assuming that enough additional personnel were available to
permit continuous activity by three three-man teams. An average applica-
tion processing complexity was assumed, resulting in a time requirement
of less than 6 months to complete the processing of all 17 applications.
In summary, under the assumed worst-case condition of
simultaneous application by 17 laboratories, the initial certification process
can be completed in between 6 months to 1 year, the exact time depending
on the degree of technical complication encountered in application processing,
S-29
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and on the availability of temporary support personnel for the laboratory
certification staff. This does not appear to be an unreasonable schedule,
and it gives a good indication that in actual practice the start-up process
should not present any major roadblocks to efficient program implementation,
It is seen, however, that a likely result of the initial certifi-
cation schedule would be to produce an undesirable, asymmetrical certifica-
tion cycle. That is, there would be a preponderance of renewal applications
and inspections coming due within a period of a few months to a year. This
can be avoided if EPA retains the discretionary option of extending the
certification period of selected facilities. This device can be used to smooth
out the certification cycle and produce a more uniform work load for the
laboratory certification group.
S.4.6 Extension of Analysis Results to Longer-Term
Implementation
It is considered likely that up to 26 independent laboratories
could be involved in this program after a few years. A review of the
analysis details used to obtain the results for the near-term scenario of
17 laboratories leads to the conclusion that, to a good approximation, both
personnel staffing and travel expenses would be increased in direct propor-
tion to this increase in the number of certified laboratories. That is, a
factor of about 1. 5 should be applied, giving a staff requirement of 11 to
13 inspectors, which would probably require a total of two or three super-
visory or administrative positions. Annual travel expenses (at present
rates) would be approximately $94,000.
S.5 COST OF EPA-OPERATED CERTIFICATION
TEST FACILITIES IN EUROPE AND JAPAN
An alternative to certification of independent foreign testing
laboratories would be for EPA to own and operate an emission testing
laboratory in Europe and one in Japan, to perform certified testing in those
areas. A cost estimate was performed for such an arrangement, for
S-30
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comparison with the proposed laboratory certification program for foreign
laboratories and also for comparison with existing certification test costs
at the EPA Ann Arbor testing laboratory. The estimate was performed
for one laboratory in Europe and one in Japan to perform near-term vehicle
certification tests of 360 and 210 per year; respectively. The cost estimate
for these foreign facilities was structured to the same format as that used
by EPA to determine cost of certification testing at Ann Arbor. These cost
estimates do not represent official EPA figures, however. They are esti-
mates prepared during this study based on general guidance from EPA.
The workload and staffing estimates for these laboratories
are shown in Table S-12.
The cost estimates for this laboratory structure are shown
in Table S-13. The staff burden was based on a fixed dollar rate salary for
each position (exclusive of clerical). The salary rate used was chosen to
be 10 percent higher than the comparable figure used in conjunction with
the EPA Ann Arbor testing laboratory. Computer-related costs were
assumed to be fixed at $100 per test. The estimate for facility rental was
arrived at on the basis of a comparable dollar figure per test cell, as that
allocated at the Ann Arbor facility. The program support fund is an over-
head-related item, and was based on an equivalent rate as that allocated to
the Ann Arbor testing function. ' The equipment depreciation value applies
primarily to emissions test equipment and instrumentation, and was again
selected on a comparable basis to that attributed to the EPA Ann Arbor
testing laboratory.
It is seen that, by this method of accounting, the total cost to
perform 570 certification tests in these two foreign laboratories is approxi-
mately $917,000 or $1610 per certification test. The equivalent figure for
EPA Ann Arbor testing (using a similar accounting system) is approximately
$1000 per test to perform about 3100 certification tests annually. The higher
cost per test of the foreign laboratories is a result of the inherently lower
personnel and equipment utilization efficiency in a small facility compared
S-31
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Table S-12. EPA Laboratory in Europe and Japan—Workload
and Staffing Estimates
Parameters
Number of Certification
Tests per Year
Number of Dynamometer
Test Cells
Staff
Supervisor
Emission Test Specialist
Manufacturer Liaison
Subtotal, EPA Staff
a
Operators
Total Personnel
Europe
360
2
1
2
3
6
7
13
Japan
210
1
1
1
2
4
4
8
Combined
570
3
2
3
5
10
11
21
Notes:
Possibly local nationals, provided on contract basis
Exclusive of clerical
S-32
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Table S-13. Cost Estimates for EPA Laboratories
in Europe and Japan
Cost Category
Staff Burden
Computer Charge
Facility Rent
Program Support Fund
Equipment Depreciation
Total
Cost per Certification
Test
Cost Estimate, in dollars
Europe
280,000
36,000
200,000
24,000
20,000
560,000
1560
Japan
172,000
21,000
140,000
14,000
10,000
357,000
1700
Combined
452,000
57.000
340,000
38,000
30,000
917,000
1610
to that of a much larger one. The analysis performed herein indicates that
is not until the volume of testing can justify at least three or four test cells
per test laboratory that costs per test could become significantly closer to
the Ann Arbor level.
The cost of certifying just the four European and one Japanese
independent laboratory as part of the overall laboratory certification program
is estimated to be approximately $156,000 per year. Thus, the proportionate
share of staff burden attributable just to the foreign laboratories is approxi-
mately 30 percent, or an annual burden of approximately $120,000. The
travel cost allocable to the foreign laboratories is approximately $36,000
per year.
S-33
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1. INTRODUCTION
1. 1 BACKGROUND, OBJECTIVES, AND SCOPE
Except for a few heavy duty vehicle (HDV) emission
certification tests performed for EPA by the Southwest Research Institute
and those emission tests permitted by EPA to be performed abroad, all other
emission certification tests [including light duty vehicles (LDVs) and light
duty trucks (LDTs] are performed at the emission testing laboratory of the
EPA located in Ann Arbor, Michigan. For example, foreign automakers have
only the 4000- and 50, 000-mile LDV emission certification tests performed
at EPA and are allowed to send in their own test results for the intermediate
mileages.
A significant increase in certification test work load, such as
could be caused by new certification regulations (e.g., motorcycles, truck
CVS tests, etc. ), increased frequency of foreign vehicle emission certifica-
tion tests, and retrofit device tests, might require either an increase in the
Ann Arbor test laboratory facilities and personnel, or a means whereby
independent laboratories could be certified to perform emission tests.
This potential problem is further accentuated by the fact that
there are a number of inventors or other entrepreneurs who •wish to evaluate
new devices or ideas applicable to emission control for new cars, after-market
parts, or used-car retrofit. Currently, the Ann Arbor laboratory cannot
accommodate these people and must refer them to a list of about about ten
independent laboratories who do perform exhaust emission testing. At the
present time there is no mechanism for certifying that such laboratories have
the facilities, equipment, and personnel necessary to meet the emission test-
ing requirements published by EPA in the Federal Register.
Therefore, the present study was initiated to explore and
characterize alternative means whereby laboratories such as these could be
certified. This characterization could aid in the implementation of a
1-1
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laboratory certification process and/or enable a tradeoff between such
laboratory certification and the continuation of all emission certification
testing by EPA. The specific study objectives were to examine the emission
laboratory certification process under consideration by EPA and (a) identify
the functional tasks required to .be performed by EPA during the initial and
continuing phases of certifying the test facilities of domestic and foreign
independent testing laboratories for performing exhaust emission tests per
the requirements of the Federal Register, (b) identify a logical work flow
sequence of the EPA tasks necessary for the above functions, (c) identify a
reasonable EPA organization structure for performing the necessary work
tasks, and (d) provide information to support the preparation of laboratory
certification requirements to be promulgated in the Federal Register.
The above objectives were met by means of (a) the acquisition
of available data concerning all aspects of the test laboratory certification
process from organizations/agencies which certify laboratories and/or
personnel for auto-related areas and scientific or engineering test measure-
ment purposes, (b) a review of the test procedures and equipment require-
ments as set forth in the Federal Register for currently controlled vehicles
and engines, (c) an analysis of the functional tasks required to enable certifi-
cation by EPA of domestic and foreign independent laboratories, (d) an
analysis of the work flow sequences required to implement and maintain the
laboratory certification processes, and (e) an assessment of the management
organizational structure, size, or manpower required in EPA to perform the
initial and on-going quality control and certification tasks.
With regard to manpower and cost estimations, major emphasis
was focused on an initial scenario in which it was assumed that 17 such
independent emissions testing laboratories would apply to EPA for certifica-
tion. These laboratories were geographically distributed as follows: 12 lab-
oratories in the continental United States, 4 laboratories in Europe (e.g.,
England, France, Italy, Germany), and 1 laboratory in Japan. A limited
1-2
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amount of effort was devoted also to estimating the manpower and cost
requirements to EPA for staffing and operating EPA-owned emission test
facilities in Europe and Japan (one laboratory at each location).
1.2 ACQUISITION OF RELEVANT DATA
Nearly all the data reported herein were acquired and developed
between 1 March 1974 and 31 August 1974 from technical reports and technical
discussions held with representatives of federal and state regulatory agencies
having responsibility for laboratory or operator certification or licensing;
companies engaged in emission-testing-related activities (e.g., operators
of test facilities, equipment suppliers, etc. ) also provided information.
Table 1-1 summarizes the government agencies from whom data were acquired.
Appendix A contains a listing of significant visits or communications, includ-
ing date of contact, agency/company contacted, and personnel involved.
1. 3 ORGANIZATION OF THIS REPORT
Section 2 presents a review of the contemporary on-going
certification activities of a number of federal and state regulatory agencies.
It identifies what their regulatory duties are, how they go about implementing
their functions, their organizational structure, work flow sequences, and the
number and types of personnel involved.
Section 3 describes a brief review of the emission test pro-
cedures and equipment requirements as promulgated by EPA in the Federal
Register. A requirements matrix is developed which compares the facility,
equipment, and procedural requirements for certification testing in any cur-
rently promulgated subpart, for 1975-1977 model years of LDVs and LDTs,
and 1974 HDV engine testing.
The functional tasks selected as appropriate for EPA use in
implementing a laboratory certification program are delineated in Section 4
for both laboratories and operators. They encompass initial certification,
renewal of certification, and on-going quality control functions.
1-3
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Table 1-1. Principal Data Sources
Agency/Company
Type of Information
Federal Aviation Adminis-
tration (FAA)
Atomic Energy Commission
(AEC)
California Bureau of Auto-
motive Repair (BAR)
California Department of
Public Health (DPH),
Laboratory Field Service
Pennsylvania Department of
Transportation, Bureau
of Traffic Safety (BTS)
New Jersey Department of
Environmental Protection
(DEP)
Certification activities related
to:
a. Aircraft repair stations
b. Aviation mechanic training
schools
c. Flight and ground schools
d. Aviation mechanics
e. Designated mechanic
examiners
f. Designated pilot examiners
g. Flight ratings
Certification activities related
to operators of nuclear power
plants
Certification activities related
to:
a. Motor vehicle pollution con-
trol (MVPC) device installers
b. MVPC stations
Certification activities related
to:
a. Clinical laboratories
b. Clinical laboratory
technologists
Certification activities related
to:
a. Safety inspection mechanics
b. Safety inspection stations
Voluntary program for training
mechanics
1-4
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Section 5 describes and discusses detailed expansions of the
selected basic functional tasks in terms of work flow sequences. The number
and types of work flow elements are defined, and the interrelation of work
flow elements between the laboratory (or operator) and the EPA laboratory
certification control group are extensively illustrated by means of flow sheet
diagrams.
Section 6 identifies a reasonable EPA management organiza-
tional structure for performing the necessary work tasks identified in Section
5. Staffing requirements, personnel requirements, and management plan
options are identified, together with cost estimates for implementing an
independent laboratory certification program involving 17 such laboratories.
Cost and staffing estimates are developed also for the case of establishing
EPA-owned-and-operated emission testing laboratories in Europe and Japan.
1-5
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2. REVIEW OF CONTEMPORARY ON-GOING
CERTIFICATION ACTIVITIES
A review of contemporary on-going certification activities
was made by contacting a number of federal and state regulatory agencies
who have responsibility for laboratory or operator certification or licensing.
These included:
a. The Federal Aviation Administration (FAA)
b. The Atomic Energy Commission (AEC)
c. The California Bureau of Automotive Repair (BAR)
d. The California Department of Public Health (DPH)
e. The Pennsylvania Department of Transportation, Bureau
of Traffic Safety (BTS)
f. The New Jersey Department of Environmental
Protection (DEP)
The purpose of this review was to determine (a) what their regulatory duties
were, and (b) how they go about implementing their functions, particularly
with regard to organizational structure, work flow sequence, number and
types of personnel involved, and work load.
This review has resulted in a comprehensive picture of
established regulatory procedures as used in the certification process in
general. As summarized in Section 2. 7, there is a consensus as to basic
principles of certification requirements and implementation techniques; this
consensus was drawn upon in selecting the recommended functional tasks
for implementation of the laboratory certification program analyzed in this
study (Section 4).
Details of the review for each agency contacted are presented
in the following sections.
2-1
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2. 1 THE FEDERAL AVIATION ADMINISTRATION (FAA)
2. 1. 1 Certification Functions and Scope of Activities
The FAA certification activities examined were confined to
those having the closest analogy to the proposed EPA laboratory certification
processes. These certification measures are those used by the FAA Flight
Standards Division, general aviation section. There are many other FAA
activities related to other types of certification which were not examined
because they were not directly relevant.
In the category of facility certification, three activities were
selected. The first activity concerns aircraft repair stations. A repair
station must be certified to perform maintenance and repair of aircraft and
equipment, and to perform certain required inspections. The second activity
concerns aviation mechanic training schools. These schools provide training
covering the knowledge, skill, and experience required for mechanic ratings.
Such a school must be certified for this training to be accepted by the FAA.
The third facility certification activity is that for flight and/or ground schools.
Certification is not a requirement to conduct a flight or ground school, but a
certified school enjoys certain advantages which may affect its operation,
principally a lower minimum flight time requirement for its students.
Four types of personnel certification procedures were selected
for examination. The first is that of aviation mechanic. This classification
was examined in greater deta.il since it was more directly related to the pro-
posed EPA operator certification activity. An aviation mechanic must be
certified in order to perform, supervise, or sign-off certain types of air-
craft maintenance or alterations. There are two ratings, airframe and
powerplant, and many mechanics hold both ratings. The second class of
personnel certification is that for personal flight ratings, such as private
pilot, commercial pilot, instrument rating, etc. The third and fourth clas-
sifications refer to examiners (non-FAA employees) designated by the FAA
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to give the practical test to applicants for the mechanic and flight ratings.
These personnel are referred to as designated mechanic examiner (DME)
and designated pilot examiner (DPE), respectively.
The material presented below covers the aspects of initial
certification procedures (and renewal, if applicable) and on-going quality-
control or surveillance. With respect to this latter function, attention is
also given to the "SWAP" quality control activities. "SWAP" is an acronym
for Systems Worthiness Analysis Program, and refers to a procedure
whereby very detailed inspections of certain facilities are performed, lasting
1 to 2 weeks or more. These inspections are carried out by a different
team of inspectors than those who perform the initial, renewal (if applicable),
and normal quality control inspections.
2. 1. 2 Management Structure and Staffing
The management structure of the Flight Standards Division
is shown in Figure 2-1. Also shown in the figure are the basic functions
performed at the national, regional, and district office levels. Staffing
levels for the national, regional, and district offices are shown in Tables 2-1
through 2-3, respectively.
The job duties and qualifications for the various positions are
as follows. Maintenance inspectors are responsible for certification activities
relating to aviation mechanics, mechanic training schools, and repair stations.
A maintenance inspector must be an FAA-certified mechanic, and have specific
experience as a working mechanic, including a minimum of 2 years supervisory
experience over certified mechanics doing work on aircraft. Operations in.-
spectors are responsible for certification activities concerning all the personal
flight ratings, and flight/ground schools. An operations inspector must hold *
valid FAA pilot ratings appropriate to his specific certification activities, have
a minimum of 1500 hours total flying time, and meet minimum flight time
requirements in each of certain applicable categories. Electronics inspectors
and accident prevention specialists are primarily concerned with activities
other than those covered in this section, and are not described further.
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NATIONAL OFFICE
(WASHINGTON. D.C.)
ESTABLISHES BASIC PROCEDURES
AND POLICY GUIDELINES
REGIONAL OFFICES
(12)
• ADMINISTER INTERPRETATION OF
POLICY GUIDELINES TO SPECIFIC
FIELD SITUATIONS AT DISTRICT
OFFICES
DISTRICT OFFICES*
(84)
• ADMINISTER CERTIFICATION AND
OTHER FAA FUNCTIONS TO ALL
FACILITIES, PERSONNEL, AND
ACTIVITIES. CERTIFIED FACILITIES
AND PERSONNEL HAVE CONTACT
WITH DISTRICT OFFICE ONLY
•GENERAL AVIATION
Figure 2-1. Management Structure —Flight Standards Division
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Table 2-1. Staffing — National Office
(Flight Standards Division)
Personnel
Administrative
General Aviation (G/A) Specialist
Air Carrier (A/C) Specialist
Clerical
Total
Maintenance
Division
3
18
18
12
51
Operations
Division
3
21
29
18
71
Table 2-2. Staffing — Regional Offices
(Flight Standards Division)
Personnel
Regional
Administrative
Maintenance Specialist
Operations Specialist
Other G/A Specialist
Clerical
Total
SWAP Teamb
Administrative
G/A Maintenance Specialist
G/A Operations Specialist
A/C Specialist
Manufacturing Inspector
Clerical
Total
Total, All
Regional Offices
12
22
25
11
27
97
10
37
41
101
35
39
263
Western
Regional Officea
1
3
3
1
3
11
1
9
9
23
7
8
57
aFor California, Arizona, and Nevada (in Los Angeles)
bBoth general aviation (G/A) and air carrier (A/C) staff are included in the
SWAP level as it is an integral part of these offices.
2-5
-------
Table 2-3. General Aviation Staffing — District Offices
(Flight Standards Division)
Personnel
Administrative
Maintenance Inspector
Electronics Inspector
Operations Inspector
Accident Prevention
Specialist
Clerical
Total
Total, All
District
Offices
68
303
50
419
84
300
1224
Twelve District
Offices in
Western Region
7
48
7
67
12
45
186
Santa Monica
District
Office
1
3
1
5
1
4
15
Maintenance and operations specialists at a regional office
must have prior experience as inspectors at a district office. Job requirements
for specialists at the national office are similar to those for the regional office.
Although it is not a specific requirement, the usual procedure is to fill vacancies
in the national office with qualified specialists from a regional office.
The numerical scope of certification activities is summarized in
Table 2-4.
2. 1.3
Specific Certification Activities
The following sections describe in more detail the certification
procedures in use for each of the three facility and four personnel categories
listed in Section 2. 1.
2. 1. 3. 1
Aircraft Repair Stations
A repair station applying for certification must submit an
application in which it must demonstrate that the station has the necessary
equipment and facilities, and that it has the necessary certified personnel in
2-6
-------
Table 2-4. Scope of Activities — General Aviation
(Flight Standards Division)
Facility /Function
Mechanic Training
Schools
Repair Stations
Flight/ Ground Schools
Designated Mechanic
Examiners
Designated Pilot
Examiners
New Mechanic Ratings
(1972)
New Pilot Ratings (1972)
Total, All
District
Offices
138
2, 735
2, 562
487
1, 540
8, 138
83, 877
Twelve District
Offices in
Western Region
25
591
373
82
288
Santa Monica
District
Office
2
73
28
13
11
its employ. An inspection visit is made to verify each of these factors.
Certification, if granted, is valid indefinitely unless suspended. On-going
quality control has consisted of quarterly inspection visits, but this is in
the process of being put on an as-required basis. This basis will be deter-
mined by monitoring the station's activity. Information and data relating to
the routine activities of a repair station are routed through the inspector's
office in the normal course of events. Certification is suspended if a repair
station loses the services of its certified employees, and remains suspended
until they are replaced by new certified personnel.
2-7
-------
2. 1. 3. 2 Aviation Mechanic Training Schools
A school desiring certification must submit an application
covering details of curriculum, physical plant, and facilities; number and
qualifications of instructors; and number of students. Instructors of shop
courses (in which the students acquire the experience requirement of their
training) must hold the appropriate FAA mechanic rating. The curriculum
is compared with the detailed requirements specified in a Federal Air
Regulation (FAR). Noncompliance with these FAR requirements causes
rejection of an application at this stage. If all parts of the application are
in order and meet all applicable FAR requirements, an inspection visit is
made to verify the accuracy of the information contained in the application.
Certification, if granted, is valid indefinitely unless suspended. This initial
certification process is illustrated in Figure 2-2.
There are three aspects to the on-going surveillance of a
certified school, as shown in Figure 2-3. First is the normal semiannual
inspection visits performed by maintenance inspectors from the cognizant
district office. This inspection normally lasts a day for a two- or three-man
team. They sit in on lectures and shop courses, examine school curriculum
and records, and check for certification of shop instructors. Additional
shorter quarterly visits may also be made.
The second quality control aspect involves the national office
for technician training at Oklahoma City. This office is responsible for
establishing the basic criteria for certification of mechanic training schools
and has sole jurisdiction over preparation, grading, and record keeping of
the written examination required of all applicants for the mechanic ratings.
This group periodically reviews the examination grades of the graduates of
each certified school. The grades are compared with a national norm based
on the school's size. If the average results fall below this norm, corrective
action is required on the part of the school. The Oklahoma City office
participates in determining the nature of their action, but the actual enforce-
ment of these changes remains with the district office.
2-8
-------
CsJ
SUBMIT \
APPLICATION
FAA FORM ,~
^310-6 /
1
1
1
r_J__ ,
I MAKE i
i RFOUIRFD [^
! CHANGES P^
! i
PROCESS APPLI-
CATION BY FAA
INSPECTORS AT
DISTRICT OFFICE
S
H
Z
UJ
o
1
N /
REJECT
REASONS
REQUIRE
APPLICAh
CORRECT
INSPECTION
S VISIT BY DISTRICT
) f OFFICE MAINTE-
/ NANCE INSPECTOF
-c.
Z
ui
2
ttO
< III
u_ a.
r
ACTION
•IT TO
?s V
/ DROP
I APPLICA-
\ TION
\
N
RATINGS
(AIRFRAME,
POWER PLANT,
OR BOTH)
MAX. NUMBER
OF STUDENTS
DAY/EVENING
CLASSES
Figure 2-2.
Sequence of Initial Certification Procedures
Aviation Mechanic Training School
-------
DISTRICT
OFFICE
FLIGHT
STANDARDS
REGIONAL
OFFICE
FLIGHT
STANDARDS
NATIONAL
OFFICE
SWAP STAFF
(REGIONAL)
MINOR
CHANGES
REQUESTED
SEMI-
ANNUAL
INSPECTION
VISIT
CERT.
CONTINUES
IN FORCE
NON
COMPLIANCE
ACTION
BY
SCHOOL
INSPECTION VISIT;
SEPARATE, OR COM-
BINED WITH SEMI-
ANNUAL VISIT
CHANGES
REQUIRED
OF SCHOOL
REVIEW OF
GRADUATES
GRADES ON
WRITTEN
EXAM
TECHNICIAN
TRAINING
BRANCH
(OKLAHOMA CITY)
INPUTS ON
INSPECTION
POLICY
COMPARE WITH
NATIONAL NORM
BASED ON
SCHOOL'S SIZE
(FAR PART 147)
CONFER WITH
DISTRICT
OFFICE AS TO
REMEDIAL
ACTION
ENFORCE
MENT BY
DISTRICT
OFFICE
UNSATISFACTORY
CONFER
WITH
DISTRICT
OFFICE
SWAP
INSPECTION,
EVERY2
YEARS
ENFORCE
MENT BY
DISTRICT
OFFICE
FAA REVIEW
(REGIONAL
OFFICE)
Figure 2-3.
Sequence of On-Going Quality Control Procedures —
Aviation Mechanic Training School
-------
The third facet of surveillance is the SWAP inspection,
performed at approximately Z-year intervals to schools above a certain
minimum size. This special class of quality control inspection is described
in Section Z. 1. 3. 8. It need only be remarked here that this is an in-depth
inspection lasting about Z weeks, in which maintenance specialists at the
regional level observe classroom and shop procedures daily over this period,
as well as examining school records and facilities. Any corrective actions
generated by this inspection are worked out in conjunction with the district
office, which again retains sole jurisdiction over implementation.
Z. 1. 3. 3 Flight and/or Ground Schools
An application is required covering three main areas. The
first is a detailed description of the training curriculum, which is compared
against FAR requirements. The second is a description of the facilities,
including aircraft and training aids, showing compliance •with FAR require-
ments as to maintenance and procedures. Third is a listing of instructors,
with evidence of certification of each.
If all applicable FAR requirements appear to be satisfied, an
inspection visit is performed to verify the accuracy of the information con-
tained in the application. This visit must include a flight check of the chief
flight instructor. The term of certification is Z4 calendar months. The
renewal process is identical to that for initial certification.
On-going quality control is primarily of an operational nature.
The chief control is that eight out of the ten most recent graduates of a given
school flight tested by an FAA inspector must pass the test on the first trial.
Failure to meet this requirement will require corrective action on the part
of the school, and possible loss of certification. In addition, random spot
checks may be made of the facility.
Z. 1. 3. 4 Aviation Mechanics
There are three requirements for these ratings; namely,
experience, knowledge, and skill. These requirements must be established
in the order given. The experience requirement is established by graduating
Z-ll
-------
from a certified training school, or by demonstrating satisfactory experience
in industry or the military. The knowledge and skill requirements are demon-
strated by passing an FAA written examination, and an FAA practical test,
respectively.
The procedure is as follows (see also Figure 2-4). The applicant
must present an application showing fulfillment of the experience requirements
to an FAA maintenance inspector. If the applicant is not a graduate of a certi-
fied training school, he must demonstrate 18 months approved experience for
either rating alone, or 30 months approved experience for both ratings. It is
the responsibility of the applicant to present this information in sufficient
detail and in a form which permits the inspector to evaluate it properly. The
inspector has sole authority to approve or disapprove the experience.
If this requirement is established, the inspector signs an
authorization for the applicant to take the FAA written examination at any
district office. Upon passing this examination, the applicant is eligible to
take the practical test. This may be given either by an FAA maintenance
inspector, or by a designated mechanic examiner (DME). The mechanic
rating is granted upon passing this test. The certificate is valid indefinitely,
unless suspended. There are no formal contacts required as to on-going
surveillance. There are recency of experience requirements, however, which
state that a certified mechanic may not exercise his privileges unless he has
had 6 months experience as a mechanic in the last Z years, or has been
checked out and approved by an FAA inspector.
Z. 10 3. 5 Designated Mechanic Examiner (DME)
A person wishing to obtain this rating must submit an applica-
tion to the nearest district office. In this application he must show that he is
an FAA certified mechanic with appropriate experience, and that he has access
to equipment and facilities (normally requiring a complete aircraft) necessary
to give a practical test to applicants for the mechanic rating. The FAA does
not necessarily give a test for this rating. Most DME's are on the faculty of
certified training schools, but this is not a requirement.
Z-1Z
-------
RECOMMENDATION
BY CERTIFIED
SCHOOL
T
(FOR APPROVED STUDENTS NEAR END OF COURSE)
-4
—*
N)
i
ESTABLISHMENT
OF EXPERIENCE
REQUIREMENTS
GRADUATE FROM
CERTIFIED TRAIN-
ING SCHOOL
PRESENT CERTI-
FICATE OF COM-
PLETION TO FAA
MAINTENANCE
INSPECTOR
TYPICAL DURATION
8 ma- 2 yr, DEPEND-
ING ON WHETHER 1
RATING OR BOTH,
TYPE OF SCHOOL
AQUIRE EXPERIENCE:
18 mo. FOR
EITHER RATING
ALONE, 30 mo. FOR
BOTH
PROVIDE DETAILS
OF EXPERIENCE
TO FAA MAINTEN-
ANCE INSPECTOR
TAKE WRITTEN
EXAM: ADMINIS-
TERED BY FAA,
5 hrs PER RATING
DISAPPROVE
FAA MAINTENANCE
INSPECTOR HAS
AUTHORITY TO
APPROVE OR DIS-
APPROVE EXPER-
IENCE
APPROVE
Figure 2-4. Steps in Certification Process for Aviation Mechanics
-------
(FOR APPROVED STUDENTS NEAR END OF COURSE)
i
h—i
X
N.
1
f GRANT \
I CERTIFI- t+_ _ _,
. CATION y
\
y
-•*
TAKE WRITTEN
EXAM: ADMIN-
ISTERED BY FAA,
5 hrs PER
RATING
(PASS
1
,/
\
^
X PASS ^
V^+
:
ALL STEPS AFTER PASSING
WRITTEN EXAM MUST BE
COMPLETED WITHIN 24 mos.
i
ir
SCHEDULE
ORAL AND
PRACTICAL
EXAM
FAIL \ OR
MORE PARTS
1
1
MAY BE GIVEN
BY FAA MAIN-
TENANCE
INSPECTOR
MORE
OFTEN
GIVEN
DME
BY
r
TAKE
ORAL
EXAM
•
*- f ^^- ^.
^^^x ^^^^
1
1 - 2
HOURS
1
MAY BE GIVEN
BEFORE, AFTER
OR DURING
PRACTICAL EXAM
i
TAKE
PRACTICAL
EXAM
X
1
FAIL
10 - 16hrs
BOTH
RATINGS
r ^
PASS
FAIL
MAY APPLY FOR
RETEST AFTER
30 DAYS FROM
DATE OF FAILING
MAY APPLY FOR
RE-TEST AFTER
>5 hr ADDITIONAL
CERTIFIED IN-
STRUCTION
Figure Z-4.
Steps in Certification Process for Aviation Mechanics
(Continued)
-------
The term of certification is 1 year. Annual renewal is normally-
obtained by demonstrating a satisfactory level of activity as a DME, and by
satisfactory performance during the semiannual contact with an FAA mainte-
nance inspector. The latter may consist of a standardization check by the
inspector, or he may observe while the DME gives a test to an applicant.
The FAA supplies information concerning suggested topics for both the oral
and practical phases of the test, but the actual makeup of a test is the pre-
rogative of the individual DME. •
The purpose of the DME rating is to reduce the workload on
the FAA inspectors. The main advantage to the applicant is that the DME
supplies all the equipment for the test, whereas this becomes the responsibility
of the applicant if the practical test is given by an FAA inspector. The DME
receives no compensation from the FAA. He is authorized to charge the
applicant for his services, but in practice this charge is a nominal one which
normally does not cover the cost of giving the test.
Z. 1. 3. 6 General Aviation Flight Ratings
An applicant for a flight rating must apply to an FAA operations
inspector or Designated Pilot Examiner (DPE) for the flight test. There are
three essential requirements to this application. The first is a notice by the
FAA that the applicant has passed the written examination appropriate to the
rating sought. The second is that he must show evidence of the required
instruction (properly annotated log book) plus a statement by the instructor
recommending him for the test. Third is a valid medical certificate appro-
priate to the rating sought.
The inspector or examiner gives an oral test covering ground
and flight handling of aircraft, navigation, and FAA flight rules. The practical
test consists of a flight test in which the applicant must demonstrate safe,
proficient handling of the aircraft during maneuvers and procedures specified
for each flight rating. It is the responsibility of the applicant to supply a
suitable aircraft for this test.
2-15
-------
Certification is valid indefinitely unless suspended. The only
formal on-going contact required between the individual and the FAA (for
that particular rating) is periodic renewal of the medical certificate. There
are recency of experience requirements, however, which place certain
restrictions on an individual who does not meet them.
2. 1. 3. 7 Designated Pilot Examiner (DPE)
Application for this rating must show that an applicant meets
the same basic requirements as those for FAA operations inspectors, defined
in Section 2. 1. 2. A flight check by an operations inspector is required. The
term of certification is 1 year. Annual renewal is dependent on the analogous
conditions as described for the DME in Section 2. 1. 3. 5. On-going quality
control consists of semiannual contacts with an operations inspector. In one
contact, the inspector gives a standardization flight check to the examiner.
In this check, the inspector defines the flight maneuvers to be used in the
test, and observes the performance of the examiner in performing them.
The second semiannual check consists of the inspector observing from the
back seat while the examiner gives a flight test to an applicant. As with the
DME, the reason for the DPE rating is to reduce the work load on the FAA
inspectors. About 90 percent of all general aviation flight tests are given
by DPE's. The DPE also receives no compensation from the FAA. A nominal
fee is charged the applicant for his services by the DPE.
2. 1. 3. 8 Systems Worthiness Analysis Program (SWAP)
This relatively new quality control activity is in addition to
the primary quality control procedures described in the preceding sections.
It consists of a special team of maintenance and operations specialists
operating at the regional level to support certification activities of the dis-
trict offices within that region. Their work consists of in-depth quality
control inspections of certified facilities above a minimum size. The dura-
tion of the inspection of a given facility is 1 or more weeks. The inspection
2-16
-------
team is typically two to four men, depending on the facility and function being
examined. These visits are scheduled to occur at approximately 2-year
intervals at a given facility. The inspection results are reviewed with the
cognizant district office, which retains sole jurisdiction over enforcement.
The facilities described herein that are subject to SWAP
inspections are: technician schools with more than 100 students, repair
stations with more than 25 employees, and certified flight schools with
more than 6 aircraft.
2. 1. 3. 9 Summary of FAA Certification Procedures
For the initial certification process, it is seen that there
are two main phases, namely, an application and an inspection visit. The
application must include all the essential elements necessary to make an
initial assessment of compliance with FAR requirements. As appropriate,
this must include information on prior certification of personnel, curriculum
details (for schools), description of physical plant and equipment, staff
members (number and qualifications), prior training and/or experience, and
availability of essential equipment and facilities.
If the completed application gives good evidence that all
statutory requirements are satisfied, an inspection visit is scheduled to
verify accuracy of the information contained in the application, and in some
cases to administer required personnel operational checks.
Examinations required for the various personnel ratings fall
into the following categories. Written exams are required for all mechanic,
flight, and ground instructor ratings. Oral and practical tests are required
for all mechanic and flight ratings. Standardization flight checks are required
of DPE's, and the chief flight instructor of a certified school.
For aircraft repair stations, mechanic training schools, and
all mechanic, flight, and ground instructor ratings, certification is valid
indefinitely unless suspended. The period of certification for flight and/or
ground school is 24 calendar months, while that of the designated examiners
is 1 year.
2-17
-------
The on-going quality control or surveillance procedures fall
into the following categories. Semiannual (and sometimes quarterly) inspect-
tion visits are made to aircraft repair stations and mechanic training schools.
For those personnel ratings which have an indefinite term of certification,
there are recency of experience requirements. These place restrictions (or
a total ban) on the certification activities of the persons so affected until
these requirements are fulfilled. Semiannual (and sometimes quarterly)
FAA contacts are made with designated examiners. These contacts normally
take the form of a standardization check, or observation during a test being
administered by the examiner. Operational performance checks on certified
flight schools are performed by administering spot flight checks to their
graduates.
Finally, the detailed SWAP quality control inspections, applied
to facilities above a minimum size, support the primary on-going quality
control activities.
2. 2 THE ATOMIC ENERGY COMMISSION (AEG) - LICENSING
OF NUCLEAR POWER PLANT OPERATORS
2. 2. 1 Certification Functions and Scope of Activities
This AEC office, located at Bethesda, Maryland, has
responsibility for licensing all operators of nuclear power plants in the U.S.
The personnel ratings licensed are "operators" and "senior operators. " The
operator rating designates personnel who manipulate the controls of licensed
nuclear facilities. The senior operator rating refers to those personnel who
directly supervise the activities of operators. Employment of licensed
operators is a requirement for facility licensing. The operator's license is
valid only at the facility where granted.
Facilities with personnel licensed by this office consist of
42 operating power plants and 85 research facilities. These facilities have
nationwide distribution. The research facilities are primarily associated
with the larger universities, while the power plants tend to follow population
distribution. There are approximately 1600 licensed operators and senior
operators, with 410 new personnel licenses issued in 1973.
2-18
-------
Two types of examinations are administered: written and
operating. The former covers theory and practice of nuclear plant operation --
in general and for the specific facility at which the applicant is employed. The
practical test consists of "hands-on" performance by the applicant as he manip-
ulates the plant controls (either real or simulated) through the full range of
normal and emergency positions appropriate to the applicant's job classifica-
tion. The term of the license is 2 years.
The above tests are given to all new applicants for a rating, and
until recently were also given to renewal applicants. This office is now estab-
lishing a requalification program at each facility, which is basically a continuous
training and job upgrading activity conducted by the facility under approval of
the Bethesda office. Operators and senior operators who successfully complete
an approved requalification program need not take the renewal written and
practical tests.
2. 2. 2 Management Structure and Staffing
The Bethesda office deals directly with all licensed nuclear
facilities; there are no district offices. The staff is structured as follows.
There is one supervisor, three group leaders, five examiners, and two
clerical. The group leaders are senior examiners who participate in field
work to the same extent as examiners. In addition, there are 21 consultants
throughout the nation who participate in administering examinations at certain
licensed facilities. There is a functional breakdown of the staff within the
office, based on three classifications of reactor types, but they do not have
separate staffs for preparation of examinations, administering examinations,
and surveillance of requalification programs. Basically, everyone is involved
in all phases of the work.
The entrance level job requirements for the examiner position
are a B.S. degree in an appropriate engineering or science discipline, plus
3 years of nuclear power plant experience. A GS-14 grade would require
5 years nuclear power plant experience, with part of that time in training
2-19
-------
work. A group leader position would require at least 7 years experience,
but the preferred approach is for these people to work up from the staff,
rather than being hired in as a group leader.
Z. Z. 3 Specific Activities
Z. Z. 3. 1 Examination Preparation and Administration
This task is performed by the staff of the Bethesda office.
A new written examination is prepared for each visit to a facility. It may
contain some questions in common with a former examination for that facility.
The examination questions are nearly all essay type, drawing schematics
from memory, etc. They avoid multiple choice questions. They do have
some questions where, for example, a series of operations and manipula-
tions are listed, and the applicant is asked to list them in the correct
sequence. They have a bank of approved examination questions. About
half of the questions on a given test are generic, covering basics which are
common to nearly all facilities. The remainder of the questions are tailored
to the specific facility. This facility-specific information is obtained from
information contained in the facility license applications (which are not
processed by this Bethesda office, but are available to them), • from periodic
reports required of each licensed facility, and from personal observations
of their staff during previous trips to that facility.
There is no specific time limit for the written test. The
operator and senior operator tests are normally completed within 7 and 6
hours, respectively, but an applicant is usually given more time if he needs
it. A senior operator applicant must take the operator written test first,
then the senior operator examination on the next day.
The operating test is structured entirely to the specific
facility, and to a certain extent, the specific job assignment of the applicant.
The sequence of manipulations which the applicant will be asked to perform
are established beforehand in check list form. These manipulations normally
involve the actual controls of an operating plant whenever possible, including
2-ZO
-------
facility start up, shutdown, and other normal and emergency procedures.
For a new facility, at which the operators must be licensed before the plant
can go into operation, the control movements are of necessity simulated.
The operating examination normally takes 5 hours.
The administration of these tests proceeds in the following
manner. Each examiner makes an average of approximately one trip per
month, and the average trip duration is 1 week, for a travel schedule of
approximately 60 days per year per examiner. The usual procedure is
to give all the operator written examinations the first day, and senior opera-
tor written examinations the second day. Operating tests are also started
the second day. If several applicants are to take operating tests (which is
the usual case) the examinations are arranged for minimum interference
with plant operations, but each applicant takes the test by himself; they do
not walk through a group of applicants at the same time. They try to keep
the number of operating tests per trip to six or less. This does not apply
to a new facility, in which all the operators must be licensed. Normally
there is one examiner per trip, except for the first trip to a new facility,
where there may be as many as 30 applicants.
All examinations, written and operating, are returned to the
Bethesda office for grading. The minimum passing grade on the written
test is 70 percent. The operating tests are conducted in accordance with a
check list upon which the administering examiner makes comments and notes.
He uses this annotated check list as the basis for a pass/fail recommendation.
The final decision is made by the group supervisor, after discussing the
completed check list with the examiner. The applicant is notified of the
results by mail.
2. 2. 3. 2 Operator Licensing
The examinations described in the preceding section form the final
basis as to whether or not a license is awarded, but they represent only part
of the licensing procedure, an overview of which is shown in Figure 2-5.
2-21
-------
I
DO
REJECT
ON MEDICAL
GROUNDS
WRITTEN TEST:
GIVEN BY AEC
AT FACILITY OF
LICENSEE
PASS
OPERATING TEST:
GIVEN BY AEC AT
FACILITY OF
LICENSEE
UNSATISFACTORY
[FAIL
MAY FILE NEW
APPLICATION
AFTER:
i
GRANT
OPERATOR
LICENSE
APPLICANT MAY
REQUEST RE-TAKE
OF ONLY THE FAILED
EXAM. AEC DISCRETION
STATEMENT BY FACILITY
LICENSEE OF DETAILS OF
ADDITIONAL TRAINING RE-
CEIVED BY APPLICANT,
AND CERTIFICATION THAT
HE IS READY FOR RE-EXAM-
INATION
SUBSEQUENT
APPLICATIONS
VALID FOR
2 YEARS
LIMITED TO
FACILITY OF
ISSUE
IF LICENSEE NOT
ACTIVE FOR >
4 MONTHS, MUST
DEMONSTRATE
PROFICIENCY TO
AEC
AEC MAY ACCEPT
AS EVIDENCE, A
CERTIFICATION
BY FACILITY
LICENSEE
NOTIFY AEC OF
SPECIFIED MED-
ICAL DISABILITIES!
WITHIN 15 DAYS
Operators and Sr. operators of nuclear production and utilization facilities (Ref. 10CFR55)
Figure 2-5. Sequence of AEC Licensing Procedures5'
-------
The licensed facility which employs the applicant is heavily involved in
all aspects of the personnel licensing procedure. The expansion of the
initial application format given in Figure 2-6 shows that the facility licensee
must request and recommend that the applicant be tested by the AEC.
2. 2. 3. 3 Requalification Program
The operator and senior operator license renewal procedures
are shown in overview in Figure 2-7. The renewal application content is
expanded in Figure 2-8. The requalification program, about which the
license renewal process is structured, is outlined in Figure 2-9. Details
of the program are shown in the succeeding three breakdowns of Figures 2-10,
2-11, and 2-12.
2. 2. 3. 4 Summary of AEC Procedures
It is seen that the initial license is based on an application,
which must demonstrate extensive training and qualification requirements
as well as a recommendation by the facility licensee. The latter must also
demonstrate that there is a need for the personnel license, by requesting
that the applicant be tested. A medical examination, per AEC format, is
required. This is followed by comprehensive written and practical tests
administered by the AEC at the facility at which the applicant is employed.
The term of license is 2 years, with currency of experience requirements.
The license is valid only at the facility for which it is granted.
License renewal is by application, which must show evidence
of proficient operation during the term of the current license, and satis-
factory completion of an approved requalification program.
On-going quality control consists of the AEC approved
requalification program, which is conducted by the facility licensee. This
program is a continuous retraining and job upgrading activity, which must
include features tailored to the specific needs of each individual licensed
operator.
2-23
-------
INITIAL
APPLICATION
I
IN)
PERSONAL
DATA
PRESENT
EMPLOYMENT
EDUCATION,
PERTINENT
tXHERIcNCE &
RESPONSIBILITY
PREVIOUS OPERA-
TOR LICENSE NO.
& EXPIRATION
DATE
i
FACILITY AT
WHIPH 1 IfTNKF
IS SOUGHT
i
REQUEST BY
rA/-*ll |TV 1 1
CENSEE THAT
OPERATING
TEST BE
GIVEN TO
APPLICANT
EVIDENCE THAT
ADDI If* AMT UAQ
LEARNED TO
OPERATE CON-
TROLS PROPERLY
AND HAS NEED
FOR LICENSE
i
AEC MAY ACCEPT
AS PROOF A
CERTIFICATION
BY FACILITY
LICENSEE
•
THIS MUST GIVE
DETAILS OF
TRAINING
PROGRAM
.T^TTT!^
MEDICAL
(T Y A M D C* P
AEC FORMAT
NFW K/IFDirAL EXA
MAY BE SUBMITTE
AT ANY TIME
i ^^~^^n
| TRAINING
|
| TYPE
•
1 NUMBER
1 OF HOURS
| INSTRUCTION
| COURSES
•
1 NUMBER OF
1 COURSE HOURS
Figure 2-6. Initial Application Content
-------
\ APPLICATION/
[SJ
Ul
REJECT
ON MEDICAL
GROUNDS
REVIEW APPLI-
CANT QUALIFI-
CATIONS. ITEMS
B, C, D & NEED
FOR LICENSE
SATISFACTORY
RENEW
LICENSE
ITEMS C & D NOT
SATISFIED (AEC
OPTION)
OPTION
/\ AEC OPT
AEC OPTION
WRITTEN TEST:
GIVEN BY AEC
AT FACILITY OF
LICENSEE
OPERATING TEST:
GIVEN BY AEC AT
FACILITY OF
LICENSEE
Figure 2-7. Sequence of AEC Renewal Licensing Procedures
-------
(RENEWAL \
I APPLICATION!
Isle
PERSONAL
DATA
EXPERIENCE OF
APPLICANT UNDER
EXISTING LICENSE
1 1
PRESENT
EMPLOYMENT
1
SERIAL NO.
OF LICENSE TO
BE RENEWED
APPROX. NO. OF
hrs WHICH APPLI-
CANT HAS OPER-
ATED FACILITY
STATEMENT BY
FACILITY LICENSEE
THAT APPLICANT
HAS SATISFAC-
TORILY COMPLETED
REQUALIFICATION
PROGRAM,
DURING
TERM OF
APPLICANT'S
PRESENT LICENSE
1 E I
EVIDENCE OF
PROFICIENT
OPERATION
1
AECMAY ACCEPT
AS EVIDENCE A
CERTIFICATION BY
FACILITY LICENSEE
MEDICAL EXAM
PER A EC FORMAT
Figure 2-8. Renewal Application Content
-------
PROGRAM FOR LICENSED OPERATORS AND SENIOR OPERATORS
OF NUCLEAR PRODUCTION AND UTILIZATION FACILITIES
IN)
PROGRAM CONDUCTED BY FACILITY LICENSEE, APPROVED BY AEC
PURPOSE
STRUCTURE
PARTICIPANTS
CONTENTS
EVALUATION
RECORDS
ALTERNATIVE
TRAINING
PROGRAMS
BREAKDOWN "A"
[SEE FIGURE 2-10]
BREAKDOWN "B"
[SEE FIGURE 2-11]
(SEE FOLLOWING SHEETS)
BREAKDOWN "C"
[SEE FIGURE 2-12]
Figure 2-9. Requalification Program — Overview
-------
SEE FIGURE 2-9
PURPOSE
STRUCTURE
PARTICIPANTS
IV
00
PROVIDE FOR CON-
TINUOUS OPERATOR
PROFICIENCY, AND
UPGRADING OF
KNOWLEDGE
AND SKILLS
SUPERCEDES FORM-
ER PROCEDURE IN
WHICH OPERATOR
WAS REQUIRED TO
DEMONSTRATE
PROFICIENCY EVERY
2 yrs AS PART OF
LICENSE RENEWAL
CONTINUOUS PRO-
GRAM OF < 2 yrs
DURATION. UPON
COMPLETION,
PROMPTLY RE-
PEATED
TAILORED TO
DEMONSTRATED
NEEDS OF INDI-
VIDUAL LICENSED
OPERATORS
LICENSED OPERA-
TORS & SR. OPER-
ATORS WHO ARE
ACTIVELY ENGAGED
IN THEIR LICENSED
ACTIVITY
LICENSED PERSON-
NEL WITH RESTRIC-
TED ACTIVITY OR
RATINGS MUST
PARTICIPATE, EX-
CEPT FOR SPECIFIC
RETRAINING IN
CERTAIN AREAS
Figure 2-10. Requalification Program — Breakdown "A1
-------
SEE FIGURE 2-9
CONTENTS
I
INSTRUCTION
LECTURES; PRE-
PLANNED, REGULAR
& CONTINUOUS BASIS
THRU OUT LICENSE
PERIOD
SPECIFICALLY AS
INDICATED BY
ANNUAL WRITTEN
EXAMS GIVEN TO
LICENSED OPER-
ATORS
MAY INCLUDE
OTHER TRAINING
AIDES, BUT CAN-
NOT CONSIST ONLY
OF FILMS, VIDEO
TAPES, AND/OR
INDIVIDUAL STUDY
ON-JOB-TRAINING;
EACH LICENSED
OPERATOR MUST:
MANIPULATE
REACTOR CONTROLS
>10 TIMES DURING
TERM OF LICENSE
DEMONSTRATE
UNDERSTANDING
OF APPARATUS,
MECHANISMS, AND
PROCEDURES IN
AREA OF LICENSE
BE COGNIZANT OF
CHANGES IN FACIL-
ITY DESIGN, PRO-
CEDURES, FACILITY
LICENSE
REVIEW ALL AB-
NORMAL AND
EMERGENCY PRO-
CEDURES ON REG-
ULARLY SCHEDULED
BASIS
Figure 2-11. Requalification Program — Breakdown "B1
-------
SEE FIGURE 2-9
N)
I
1
EVALUATION
1
ANNUAL WRITTEN
EXAM TO DETER-
MINE AREAS IN
WHICH RETRAINING
IS NEEDED
1 RECORDS 1
DOCUMENT PARTI-
CIPATION OF EACH
LICENSED OPERATOR
IN REQUALIFICATION
PROGRAM
1
WRITTEN EXAMS ON
SUBJECTS COVERED
IN REOUALIFICATION
PROGRAM; AB-
NORMAL AND EMER-
GENCY PROCEDURES
1
SYSTEMATIC OBSER-
VATION & EVAL-
UATION OF PERFOR-
MANCE OF LICENSED
OPERATORS BY
SUPERVISORS AND/OR
TRAINING STAFF
1
SIMULATION OF
ABNORMAL AND
EMERGENCY
CONDITIONS
1
PROVISION FOR
ACCELERATED RE-
QUALIFICATION PRO-
GRAMS FOR LI-
CENSED OPERATORS
WHEN NEEDED
COPIES OF WRITTEN
EXAMS GIVEN, AN-
SWERS BY LICENSEE
RESULTS OF
EVALUATIONS
DOCUMENT ADDI-
TIONAL TRAINING
GIVEN IN AREAS IN
WHICH LICENSEE HAS
SHOWN DEFICIENCIES
1
ALTERNATIVE TRAIN-
ING PROGRAMS
1
MAY BE CON-
DUCTED BY PERSON-
NEL OTHER THAN
FACILITY LICENSEE
PROVIDED:
1
REQUALIFICATION
PROGRAM IS SIMILAR
TO THAT DEFINED
HERE
1
ALTERNATIVE PRO-
GRAM MUST BE AP-
PROVED BY AEC
Figure 2-12. Requalification Program — Breakdown "C"
-------
There is thus extensive involvement by the employer of the
applicant in every phase of the licensing procedure.
2. 3 THE CALIFORNIA BUREAU OF AUTOMOTIVE
REPAIR (BAR)
This agency is part of the California Department of Consumer
Affairs. It has the responsibility for licensing motor vehicle pollution control
(MVPC) installation and inspection stations, and MVPC device installers
(personnel). All legally required MVPC retrofit devices must be installed
or approved by a licensed installer. Employment of a licensed installer is
a requirement for licensing of a station.
The management structure and staffing of this bureau are
shown in Figure 2-13. The scope of its MVPC activities are shown in Fig-
ure 2-14. The scope of its safety check activities is included as Figure 2-15
and complete the definition of the overall management structure and staffing
of this bureau.
The licensing procedure applicable to MVPC device installation
and inspection stations is shown in Figure 2-16. The essential parts to
this procedure are an application plus inspection visit. The license is valid
for 1 year, with the renewal procedure being identical to that for the initial
application. There are thus no separate on-going quality control methods,
although an inspector has the right to re-examine a licensed facility at any
time.
The licensing procedure for the personnel rating is given in
Figure 2-17. The certification control techniques are an application, in
which the applicant must supply evidence of proficiency or training, plus a
written exam. The trend is toward new applicants using school training for
the proficiency requirement, rather than the certificate of competence signed
by a station licensee. Exact figures are not available, but is is estimated
that at least 50 percent of new applicants are currently using school training.
Community college vocational courses are predominant in this respect, with
2-31
-------
BAR
SACRAMENTO
8 DISTRICT OFFICES
CONTROL AND LICENSING OF MVPC,
BRAKE, AND LAMP INSPECTION STATIONS
AND PERSONNEL. BAR FORMED IN 1972,
AT WHICH TIME THIS FUNCTION WAS
TRANSFERRED FROM CALIF. HIGHWAY
PATROL
STAFF:
ADMINISTRATIVE 14
INSPECTORS 47
EXAM SPECIALISTS 2
EXAM PROCTORS 45
CLERICAL 42
JOB QUALIFICATIONS
INSPECTORS:
EXAM SPECIALISTS:
EXAM PROCTORS:
MVPC
BRAKES
5 YEARS IN AUTOMOTIVE
TECHNOLOGY
FAMILIARITY WITH EXAMINING
PROCEDURES AND THEORIES,
AND AUTOMOTIVE TECHNOLOGY
OVER 21 AND TRUSTWORTHY
(SOME ARE PART-TIME)
LAMP
Figure 2-13. Management Structure and Staffing — California BAR
-------
MVPC
i
u>
UJ
11,000 STATION
LICENCES
I
ACTIVITIES LISTED BELOW
MUST BE ACTUALLY PER-
FORMED BY LICENSED IN-
STALLER WORKING IN LI-
CENSED STATION
INSTALL/APPROVE ALL
LEGALLY REQUIRED MVPC
RETRO-FIT DEVICES. VE-
HICLE OWNER MAY INSTALL
THEM, BUT WORK MUST BE
APPROVED
INSPECT AND CORRECT ALL
MVPC VIOLATION CITATIONS
PERSONNEL
LICENSING
10,000 WRITTEN
EXAMS ADMINIS-
TERED ANNUALLY
1 EXAM PRESENTLY
IN USE. PLAN 4 NEW1
EXAMS PER YEAR
Figure 2-14. Scope of MVPC Activities — California BAR
-------
BRAKES
LAMP
I
(THESE TWO CATEGORIES
COMBINED FOR THIS SUMMARY)
1
7000 STATION
LICENSES
ACTION BY A LICENSED
INSTALLER, WORKING
IN LICENSED STATION,
IS REQUIRED TO CORRECT
A DEFECT CITED BY LAW
ENFORCEMENT AGENCY
LICENSED INSTALLER
MUST EITHER PERFORM
THE WORK OR SUPER-
VISE IT, AND MUST SIGN
THE WORK OFF
PERSONNEL
LICENSING
6000 WRITTEN EXAMS
ADMINISTERED
ANNUALLY
PLAN 2 NEW
EXAMS PER YEAR
EACH CATEGORY
Figure 2-15. Scope of Safety Check Activities -«- California BAR
-------
BAR
DISTRICT
OFFICE
INSPECTION
VISIT
I
u>
LICENSED MVPC
DEVICE
INSTALLER
IN EMPLOY
FACILITY,
EQUIPMENT,
ETC
RETURN
APPROVED
APPLICATION
TO STATION
REVIEW
APPLI-
CATION
SEND APPROVED
APPLICATION &
$10 FEE
BAR
SACRAMENTO
OFFICE
VALID ONLY WHILE
LICENSED MVPC
DEVICE INSTALLER
IS IN EMPLOY
IF NOT, STOP ALL
MVPC DEVICE WORK
REMOVE STATION
LICENSE SIGNS
RENEWAL PROCE-
DURE IS IDENTICAL
TO THAT FOR INI-
TIAL APPLICATION:
EXCEPT FEE IS S5 IF
RECEIVED PRIOR TO
EXPIRATION OF
LICENSE
IF LICENSED IN-
STALLER NOT HIRED
IN 60 DAYS, SUR-
RENDER STATION
LICENSE TO BAR
BAR SENDS FRE-
QUENT TECHNICAL
AND REGULATORY
UPDATES TO EACH
STATION LICENSEE.
LATTER MUST POST
THESE FOR READY
USE BY LICENSED
INSTALLERS
Figure 2-16.
Licensing Procedures for MVPC Device Installation and
Inspection Stations — California BAR
-------
LO
1 APPLICATION
CERTIFICATE OF
COMPETENCE:
SIGNED STATEMENT
BY STATION LICENSEE
THAT APPLICANT HAS
DEMONSTRATED COM-
PETENCE
1
AT BAR DISCRETION,
MAY ACCEPT IN LIEU
OF ABOVE, EVIDENCE
THAT APPLICANT HAS
SATISFACTORILY COM-
PLETED COURSE IN
ENGINE TUNE-UP BY:
BAR ANNOUNCE
EXAM SCHEDULE
1
44 LOCATIONS
THRU-OUT STATE
(SCHOOL FACIL-
ITY)
1
EXAMS GIVEN ON
TUESDAY EVENINGS,
EVERY WEEK AT
SOME, ONCE PER
MONTH AT OTHERS,
ETC
1
IF> 15 APPLICANTS
AT ONE TRAINING
FACILITY, PROCTER
MAY GIVE EXAM
THERE
APPLICANT TAKE
WRITTEN EXAM
72 QUESTIONS,
MULTIPLE CHOICE'
MINIMUM PASSING
GRADE = 80%. 3
HOUR EXAM
1
VEHICLE
MANU-
FACTURER
1 1 1 1
DEVICE
MANU-
FACTURER
TUNE-UP
EQUIPMENT
MANUFAC-
TURER
TRADE
SCHOOL
HIGH SCHOOL
OR JUNIOR
COLLEGE
VALID ONLY DURING
EMPLOYMENT BY
LICENSED STATION
RENEWAL PROCEDURE
IS IDENTICAL TO THAT
FOR INITIAL APPLICA-
TION, EXCEPT FEE IS
$5 IF RECEIVED PRIOR
TO EXPIRATION OF
LICENSE
Figure 2-17.
Licensing Procedures for MVPC Device Installers —
California BAR
-------
some high school vocational courses being accepted, as well as adult
evening extension courses conducted at high school facilities. Typically,
a course satisfying BAR requirements is one semester (4-1/2 months) in
duration. The BAR makes no separate evaluation or inspection of the facility
or curriculum. Training courses conducted by such concerns as oil companies,
auto manufacturers, and device manufacturers do not account for a significant
number of new applications.
The term of the personnel license is 4 years. It is valid only
during employment by a licensed station. The renewal procedure is identical
to that for the initial application. In this case, most renewal applications use
the certificate of competence, signed by the station licensee by whom they are
employed. There are no other on-going quality control requirements, and
there are at present no provisions for actual on-site inspection of an installer's
performance.
2. 4 THE CALIFORNIA DEPARTMENT OF PUBLIC
HEALTH (DPH)
The activity of interest here is the licensing and surveillance
of clinical laboratories, and the licensing and training of clinical laboratory
technologists. Clinical laboratory activities pertain to biomedical testing
and analyses concerning diseases inhuman beings. Test samples are
received from, and results reported to, physicians and other licensed prac-
tioners of the healing arts, exclusively. The activities described herein are
performed by the Laboratory Field Service unit of the California DPH.
There are approximately 1800 licensed clinical laboratories,
of which approximately ZOO are approved training laboratories. The latter
are subject to additional inspection criteria such as library, audio-visual
training aids, number and types of specimens analyzed, and ratio of licensed
laboratory personnel to trainees. The DPH differentiates between "licensing"
and "certification. " The latter refers to laboratories connected with federal
Medicare programs. These facilities require additional inspection details to
satisfy Medicare requirements.
2-37
-------
There is no personnel licensing at the technician level.
Clinical laboratory technologists must have a B. S. degree plus 1 year as a
trainee in an approved training laboratory. They must then pass a written
examination. The examinations are administered by DPH, but preparing
and grading of the tests is contracted out to private testing firms. The DPH
reviews the examinations and can make changes. The DPH also has an
advisory committee which determines the passing grade, usually taken as
one sigma below the mean. The examinations are given twice a year, at
two locations (Los Angeles and Berkeley) using state-owned facilities. Ap-
proximately 1ZOO examinations are administered per year. The tests are
multiple choice, of 3 to 4 hours duration. The license is valid for 1 year,
but is renewable simply by paying a $6 renewal fee. There are approximately
15, 000 licensed laboratory personnel in the state.
There are two Laboratory Field Service offices; a main office
at Berkeley, and a district office at Los Angeles. The staffing of both offices
combined is as follows:
Administrative 1
Senior Examiner 3
Examiner I and II 16
Clerical 12
Total 32
The job qualifications for these positions are as follows. The Examiner I
position requires a B. S. degree in an appropriate science discipline, plus
licensing both as a clinical laboratory technolgist and as a certified public
health microbiologist, plus 2 years approved experience. The requirements
for Examiner II include those for Examiner I, plus 2 additional years approved
experience plus an M. S. degree (or equivalent extra experience or training).
The Senior Examiner position includes the requirements for Examiner II,
plus 2 additional years approved experience, plus a Ph. D. degree (or
equivalent extra experience or training).
2-38
-------
The licensing procedures for facilities are shown in Figure 2-18
The application requires all owners and directors to be identified, and the
directors must give their California license numbers, and the hours per week
to be spent in the laboratory. It is the responsibility of the directors to define
three main aspects of laboratory operation. The first is to select laboratory
procedures, techniques, and reagents to be used. The second is to establish
and maintain an internal quality control program. Last, they must establish
and maintain record keeping procedures, which provide for retention of full
information for Z years on each sample analyzed. A list of all licensed
laboratory personnel and trainees must be included with the initial application.
An inspection visit is performed to interview the directors,
examine the facility and procedures, and check for licensed personnel.
The renewal procedure is similar to that for initial application.
However, the DPH is not always able to perform the facility inspection for
renewal application, and some facilities have gone 18 to 36 months between
visits. The "certified" Medicare laboratories take priority, and here the
annual inspection rate is maintained. Inspection visits average approximately
1Z hours of examiner time; Z to 4 hours in the laboratory, with the remainder
in travel and report writing.
On-going quality control for the laboratories consists of parti-
cipation in a DPH-approved laboratory testing program. In this program, an
approved proficiency testing service (APTS) prepares standard "unknown"
clinical samples for distribution at least four times per year to each partici-
pating clinical laboratory. Each laboratory reports its analysis results
to the APTS, which in turn reports the results from all participating labora-
tories to DPH. The latter monitors the procedures used by the APTS to pre-
pare, distribute, and cross-check specimens. At present there are four
APTS (all private firms) and each clinical laboratory may choose the APTS
with which it is to participate.
Z-39
-------
DPH REVIEW OF
APPLICATION
SATISFACTORY
APPROVE
INSPECTION
VISIT
INTERVIEW
DIRECTORS
CHECK
LICENSED
PERSONNEL
CHECK-LIST EX-
AMINATION OF
FACILITIES AND
EQUIPMENT
Cv)
I
LETTER TO APPLI-
CANT, STATING
REASONS, WITHIN
60 DAYS OF RECEIPT
OF APPLICATION
I 1
| CHANGES j
I BY LAB r*
I 1
/' N
/ DROP
-I APPLI-
\ CATION
\^_^
VALID FOR
CALENDAR YEAR
JAN 1 TO DEC 31,
OR REMAINDER
THEREOF
AUTOMATICALLY
REVOKED IN 30
DAYS IF MAJOR
CHANGE IN OWNERS
OR DIRECTORS
RENEWAL:
RENEWAL
APPLICATION
FORM + $65 FEE
DIRECTORS MUST
SUPPLY NAMES OF
LICENSED PER-
SONNEL TO DPH
ANNUALLY BY
DEC 15
Figure 2-18.
Licensing Procedures for Clinical Laboratories —
Laboratory Field Service, California DPH
-------
The license of a clinical laboratory may be suspended if its
analysis results to the APTS (based on the average of the preceding four
quarters) exceed a specified tolerance for three consecutive quarters.
2. 5 THE PENNSYLVANIA BUREAU OF TRAFFIC
SAFETY (BTS)
This bureau is part of the Pennsylvania Department of
Transportation, and has administrative responsibility for the state vehicle
safety inspection certification program. This is a federally-funded program
(DOT) which started July 1972, and ends June 30, 1974. It is aimed exclu-
sively at experienced mechanics (-80, 000) working in approved inspection
stations (-17, 000) of an old program which has been in effect for about
20 years. The new program first involved working with vocational schools
throughout the state, certifying facilities and equipment, and establishing
details of a brief mechanic upgrading course. Mechanic training started in
January 1973. After June 1974 the program will continue at a much lower
level, certifying only new mechanics entering this field.
Pennsylvania is developing an emission test inspection pro-
gram which is scheduled to go into effect January 1975, but the details have
not yet been finalized. At present the mechanic visually inspects emission
control devices during the safety inspection to see if they have been tampered
with.
All administrative work is done at the Harrisburg, Pennsylvania
office. The staff is concerned almost exclusively at present with application
processing. The staff consists of two administrative positions and 62 clerical.
The bureau has prepared one examination of 50 multiple choice questions
which has been used throughout this program. One new examination is plan-
ned per year.
Program enforecement is the responsibility of the state police.
There are 67 state police garage supervisors, each of whom is assigned
approximately 250 certified safety inspection stations. The garage supervisor
2-41
-------
examines each station twice a year. He examines records of station inspection
activity, and inspects facility and equipment. The state policeman also admin-
isters the practical test to each applicant for mechanic certification. The
practical test consists of a complete safety inspection of a vehicle, performed
in the presence of the garage supervisor. He may also give a repeat practical
test to certified mechanics at his discretion, based on customer complaints,
general observations, or inspection of station records.
Program training is performed by vocational schools located
in 61 counties throughout the state. These schools conduct an 8-hour training
course, at the conclusion of which they administer and grade the 1-hour written
examination. There is no charge to the applicant in this program, other than
personal transportation expenses to attend the training course.
The procedure whereby a station obtains appointment as an
official inspection station is shown in Figure 2-19. The application form
requires personal and business data for the owner and operator, and identifies
any other automotive-related business ventures in which they may be involved.
The applicants must also supply technical information concerning certain
inspection procedures, and list the certified mechanics in their employ. The
BTS evaluates the technical aspects of the application, while the state police
garage supervisor performs the facility inspection to verify that state inspec-
tion requirements are satisfied. The state police run a character check of
the owners and certified mechanics; a station license may be denied on these
grounds. The certificate of appointment is valid indefinitely unless suspended.
The procedure for certifying mechanics is shown in Fig-
ure 2-20. The term of certification is 3 years, but renewal is accomplished
by completing a renewal application form, with no additional tests required.
2. 6 THE NEW JERSEY DEPARTMENT OF ENVIRONMENTAL
PROTECTION (PEP)
New Jersey has a mandatory vehicle emissions inspection
program in effect since February 1974. There was no pre-existing mechanic
2-42
-------
U>
ST
PO
J CATION \ . E
r\ (SUBMIT '^^
PERSONAL DATA
ON OWNER AND
OPERATOR
LOCATION AND
FACILITY, TOOLS,
EQUIPMENT
CERTIFIED
MECHANICS
— — . rHftPf
*TE ^ CHECK
LICE ^ OWNE
i
CTER
OF
« AND
^NICS
r
TS TION BY
POLICE
INSPEC-
j
STATE
POLICE
A
Bl
t
,
4 AC
k
CHANGES BY~"V
STATION
REJECT
APPLICATION " ~ 1
i
DISAPPROVE
BTS — ^
\
TIONS REQUIRED
1
TION BY /
ATION * \^
>
t
\APPROVE w
/ f
r
?
VALID INDEFINITELY
UNLESS SUSPENDED
VEHICLE INSPECTIONS
CAN BE PERFORMED
ONLY BY CERTIFIED
MECHANICS, AND ONLY
IN DESIGNATED AREA
OF THE STATION
MECHANICS NOT
FAMILIAR
EQUIPMEN
ATIONS RE
TO FACILI
WITH
T, ALTER-
QUIRED
TY, ETC
\
15 DAY DELAY
STATION MUST BE
OPEN, WITH CERTI-
FIED MECHANIC ON
DUTY, 8 NORMAL
BUSINESS HOURS PER
DAY,>5 DAYS PER
WEEK
FOR CORRECTION J_
I- -t' \
\ X
ON-GOING QUALITY
CONTROL:
SEMI-ANNUAL IN-
SPECTION OF STA-
TION BY STATE
POLICE
CHECK RECORDS,
VOLUME OF INSPEC-
TION ACTIVITY VS
STATION SIZE AND
NUMBER OF MECH-
ANICS
INVESTIGATE CUS-
TOMER COMPLAINTS
/ \
/ DROP \
i APPLICA- I
> TION '
\ /
\ X
Figure 2-19. Procedures for Licensing as Official Inspection Station —
Pennsylvania BTS Program
-------
SATISFACTORY
INSTRUCTOR GRADE
EXAM. VERIFY ATTEN-
DANCE
REQUIREMENTS:
VALID PENN.
DRIVER'S LICENSE
ISJ
a YEARS MECHANIC
EXPERIENCE, OR 2
YEAR AUTO VOCA-
TIONAL COURSE PLUS
6 MO. JOB TRAINING
EMPLOYED >1 YEAR
AS MECHANIC AT
OFFICIAL INSPECTION
STATION AT TIME OF
APPLICATION
APPROVED VOCATION-
AL SCHOOLS IN 61
COUNTIES, SPONSORED
BY BTS, CONDUCTED
BY SCHOOL INSTRUC-
TORS
TWO 4 HOUR SESSIONS.
LECTURE PLUS VISUAL
AID
COVERS ALL OPER-
ATIONS INVOLVED
IN A VEHICLE INSPEC-
TION
OFFICIAL INSPECTION
STATION WHERE APPLI-
CANT IS EMPLOYED
STATE POLICE GIVES
PRACTICAL TEST TO
APPLICANT AT STA-
TION WHERE HE IS
EMPLOYED
MUST REQUEST TEST
FOR APPLICANT
TEST CONSISTS OF
A COMPLETE VE-
HICLE INSPECTION
UNSATISFACTORY
1 HOUR WRITTEN
EXAM IMMEDIATELY
AFTER 2nd 4 HOUR
SESSION
50 QUESTIONS,
MULTIPLE CHOICE
VALID 3 YEARS,
RENEWAL BY
COMPLETED APPLI-
CATION FORM, NO
ADDITIONAL TESTS
MECHANIC MAY BE
ASKED TO RETAKE
PRACTICAL TEST AT
ANY TIME, AT STATE
POLICE DISCRETION
CERTIFICATION
15 SUSPENDED DURING
ANY PERIOD THAT
DRIVERS LICENSE IS
SUSPENDED
Figure 2-ZO.
Procedures for Certifying Mechanics — Pennsylvania
BTS Vehicle Safety Inspection Program
-------
certification program to build on, and DEP had no technical instructors
on their staff. Therefore, they arranged with the state Department of
Education for a vocational instructor to initiate a training program. This
is an informal, voluntary program for training mechanics in practical,
hands-on aspects of emission control systems. At the present time there
is only one instructor in the program, although they expect to have about
ten instructors in the field shortly.
The program started in 1971, consisting of familiarization
clinics with a generalized slide presentation covering the basics of emis-
sion control systems and state procedures and requirements. In 1972,
these became 8 to 12 hour clinics with equipment provided by manufacturers.
In 1973 the number of clinics was expanded, covering much of the state.
By March 1974, approximately 4000 mechanics had attended clinics and
received hands-on experience. In these clinics the instructor introduced
typical faults, such as a defective spark plug, improper carburetion, etc. ,
and demonstrated the effect on emissions. The clinic attendees would
then repair the defect and measure the emissions afterward to note the
improvement. The New Jersey DEP is trying to have this program expanded,
possibly involving certification of mechanics. For the present, however,
this is an example of an agency trying to establish some form of personal
contact at the technician level, in an area where none has formerly existed
and with tight budget constraints. Therefore, they chose to concentrate their
limited resources entirely on providing a measure of hands-on training to
mechanics, prior to any formalizatLon of procedures and documentation.
2. 7 OVERVIEW OF CONTEMPORARY CERTIFICATION
REQUIREMENTS AND PROCEDURES
The essential features of facility and operator certification
procedures and techniques are summarized in this section for those federal
and state agencies reviewed in detail in Sections 2. 1 through 2. 6. The
concensus as to general functional requirements, as delineated below, is
2-45
-------
used in Section 4 as the basis for selecting the functional tasks required
for the EPA independent laboratory and operator certification program.
2. 7. 1 Facility Certification
2. 7. 1. 1 Initial Certification Requirements
Table 2-5 summarizes the principal functional requirements
utilized by the federal and state agencies listed in the process of certifying
the facilities indicated. As can be seen, the application for certification
plus inspection visits to verify the information contained in the application
are the principal tools used in the facility certification process. Testing,
per se, is not involved, except in the case of an FAA-approved flight
school where the chief flight inspector is required to undergo a standardiza-
tion flight check. Application fees are required in some instances.
Because of the universal reliance on the application, the
critical or essential elements of the facility application are summarized in
Table 2-6. Here again, there is a consensus in that all cases listed require
that the application explicitly list (a) certified personnel on the staff and
(b) adequate definition and description of the facility's physical plant and
equipment. Aside from training schools, the other information required,
in some instances, relates to personal information on the owner, operator,
or directors of the facility. The information required in the application
is considered necessary in order to make both initial and final assess-
ments of compliance with regulatory requirements.
2. 7. 1. 2 Renewal and/or On-going Quality Control
Requirements
Table 2-7 summarizes the renewal and/or on-going quality
control requirements for facilities, other than those associated with initial
certification. As can be seen, in most cases extensive inspection visits/
checks are used for the quality control of facilities. In every case, regular
inspection visits are used, however, the frequency of the scheduled
2-46
-------
Table 2-5. Summary of Initial Facility Certification Requirements
i
^
-vl
• FAA
• AIRCRAFT REPAIR STATIONS
• AVIATION MECHANIC TRAINING
SCHOOLS
• APPROVED FLIGHT/GROUND
SCHOOLS
• CALIFORNIA BAR
• INSTALLATION AND
INSPECTION STATIONS
• CALIFORNIA DPH
• CLINICAL LABORATORIES
• PENNSYLVANIA BTS
• SAFETY INSPECTION STATIONS
APPLICATION
>X
NX
NX
NX
NX
NX
INSPECTION
VISITS<2>
NX
NX-
NX
NX
NX
NX
TESTING
(1)
FEE
$10
$100
(1) STANDARDIZATION FLIGHT CHECK OF CHIEF FLIGHT INSTRUCTOR
(2) TO VERIFY INFORMATION CONTAINED IN APPLICATION
APPLICATION PLUS INSPECTION VISITS ARE
PRINCIPAL TOOLS FOR FACILITY CERTIFICATION
-------
Table 2-6. Summary of Critical Elements of a Facility Application'^
00
• FAA
• AIRCRAFT REPAIR STATIONS
• MECHANIC TRAINING
SCHOOLS
• FLIGHT/GROUND SCHOOLS
• CALIFORNIA BAR
• INST. & INSP. STATIONS
• CALIFORNIA DPH
• CLINICAL LABS
• PENNSYLVANIA BTS
• INSPECTION STATIONS
CERTIFICATION
OF
PERSONNEL
-
^
-
-
-
-
PHYSICAL
PLANT
AND
EQUIPMENT
DESCRIPTION
-
^
^
^
^
-
CURRICULUM
DETAILS
-
^
OTHER
STAFF
MEMBERS
NX
NUMBER
AND
QUALIFICATIONS
NO. OF
STUDENTS
^
PERSONAL
INFORMATION
ON OWNERS
AND
DIRECTORS
GENERAL DATA
ON OWNER OR
OPERATOR
\f
^Essential elements necessary to make initial assessment of compliance
with, requirements.
-------
Table 2-7. Summary of Renewal and/or On-Going Facility
Quality Control Requirements
'FAA
• AIRCRAFT REPAIR STATIONS
• MECHANIC TRAINING SCHOOLS
• FLIGHT/GROUND SCHOOLS
• CALIFORNIA BAR
• INST. & INSP. STATIONS
• CALIFORNIA DPH
•CLINICAL LABS
• PENNSYLVANIA BTS
• INSPECTION STATIONS
INSPECTION VISITS/CHECKS
REGULAR
QUARTERLY, OR AS REQUIRED
SEMI-ANNUAL(QUARTERLY
MAY BE ADDED)
EVERY 2 YEARS AS IN
ORIGINAL CERTIFICATION
EVERY YEAR AS IN
ORIGINAL CERTIFICATION
ANNUAL INSPECTIONS(SOME
GO 18-36 MONTHS EXCEPT
FOR MEDICARE-CERTIFIED
LABS)
SEMI-ANNUAL INSPECTIONS
SPECIAL
SWAP(2)
SWAP (2)
SPOT-CHECKS OF RECENT
GRADUATES IN FLIGHT TESTS
SWAP(D
LAB. SAMPLE CHECKS 4 TIMES
PER YEAR BY APPROVED
PROFICIENCY TESTING SERVICE
(1) OTHER THAN THOSE ASSOCIATED WITH INITIAL CERTIFICATION
(2) SWAP: SYSTEMS WORTHINESS ANALYSIS PROGRAM. IN-DEPTH Q.C. INSPECTIONS
OF CERTIFIED FACILITIES. ONE TO TWO WEEKS OR MORE IN DURATION.
SCHEDULED AT-TWO YEAR INTERVALS
IN MOST CASES, EXTENSIVE INSPECTION VISITS/CHECKS
ARE USED FOR QUALITY CONTROL OF FACILITIES
-------
inspections varies from a few months to 2 years, depending upon the nature
of the particular facility involved. In four of the six cases shown, addi-
tional special checks are included in the quality control process, as noted.
2. 7.2 Personnel Certification
2. 7. 2. 1 Initial Certification Requirements
For personnel, Table 2-8 summarizes the principal functional
requirements used by the agencies for the personnel classifications shown.
As in the case of facility certification, all agencies utilize the application as
a principal tool. However, testing (both written and practical) instead of
inspection visits or contacts (as in the case of facility certification) is the
other principal tool used in personnel certification. Except for the
Designated Mechanic Examiner (DME) and Designated Pilot Examiner (DPE)
ratings of the FAA, all other personnel ratings are required to pass a writ-
ten examination. Even in the DME and DPE cases, however, these same
personnel have previously passed a written examination when obtaining the
prerequisite aviation mechanic or flight ratings. Practical tests are
required (or optional) in six of the eight cases illustrated. Medical exami-
nations are required only in those cases (FAA flight ratings and AEC nuclear
power plant operators) where inadvertent medical problems could lead to
f
substantial property damage or personal injury as a result of operator
incapacitation.
The critical elements of the application for personnel certi-
fication are summarized in Table 2-9. In all cases there are minimum
requirements for prior experience and/or qualifications which must be
included. For the FAA DME and DPE ratings, prior certification in the
appropriate aviation mechanic or flight rating must be shown. In three
of the eight cases shown, the facility employing the operator is required
to request and recommend that the operator be certified.
2-50
-------
Table 2-8. Summary of Initial Personnel Certification Requirements
• FAA
• AVIATION MECHANICS
• FLIGHT RATINGS
• DME'S
• DPE'S
• AEC
• OPERATORS OF NUCLEAR
POWER PLANTS
• CALIFORNIA BAR
• MVPC DEVICE INSTALLERS
• CALIFORNIA DPH
• CLINICAL TECHNOLOGISTS
• PENNSYLVANIA BTS
• MECHANICS
APPLICATION
NX
NX
NX
NX
NX
NX
NX
NX
INSPECTION
VISITS
OR CONTACTS
TESTING
WRITTEN
\X
NX
NX
NX
NX
\X
PRACTICAL
NX
NX
(1)
NX
NX
NX
MEDICAL
NX
NX
FEE
$10
$15
(1) MAY BE GIVEN AT DISCRETION OF EXAMINER
APPLICATION PLUS TESTS ARE PRINCIPAL
TOOLS FOR PERSONNEL CERTIFICATION
-------
Table 2-9. Summary of Critical Elements of Personnel Application
(1)
• FAA
• AVIATION MECHANICS
• FLIGHT RATINGS
• DME'S
• DPE'S
• AEC
•OPERATORS
• CALIFORNIA BAR
• MVPC DEVICE INSTALLERS
•CALIFORNIA DPH
• CLINICAL TECHNOLOGISTS
• PENNSYLVANIABTS
• MECHANICS
FACT OF
PRIOR
CERTIFICATION
NX
NX
PRIOR
EXPERIENCE AND
QUALIFICATIONS
NX
NX
NX
NX
NX
NX
(2)
NX
NX
AVAILABILITY OF
ESSENTIAL
EQUIPMENT AND
FACILITIES
NX
RECOMMENDATION
BY
FACILITY
NX
NX
NX
(1) ESSENTIAL ELEMENTS NECESSARY TO MAKE INITIAL ASSESSMENT
OF COMPLIANCE WITH REQUIREMENTS
(2) MAY BE ACCEPTED IN LIEU OF RECOMMENDATION BY FACILITY
-------
Z. 7. Z. Z Renewal and/or On-going Quality Control Requirements
Table 2-10 summarizes the spectrum of renewal and/or
on-going quality control requirements utilized in the personnel certification
process. Except for AEC operators and the FAA DME and DPE ratings,
very little actual quality control is exercised over personnel. In these
cases, where operator proficiency may be considered to be more closely
related to potential property damage or personnel injury, periodic inspec-
tion contacts and checks are made. The AEC operator is required to
participate in a requalification program, which is essentially a continuous
updating and retraining program.
Z. 7. 3 Term of Certification
Table Z-ll describes the variability of term of certification
for both facilities and personnel. As can be seen, for both facilities and
personnel, the term of certification varies from 1 year to valid indefinitely.
For those facilities having definite certification period
durations (i. e. , other than indefinite validation), the renewal period is
Z years or less. Similarly, for personnel having definite certification
periods, in four of the six cases shown the period was also Z years or
less.
However, there does not appear to be any real consensus
as to term of certification, either for facilities or personnel. Rather,
it appears the term of certification is somewhat arbitrarily selected in
each case to fit the needs of the particular organization involved in the
certification process.
Z-53
-------
Table 2-10. Summary of Renewal and/or On-Going Personnel
Quality Control Requirements
t\>
en
>FAA
• AVIATION MECHANICS
• FLIGHT RATINGS
• DME'S
• DPE'S
• AEC
•OPERATORS
• CALIFORNIA BAR
• MVPC DEVICE INSTALLERS
• CALIFORNIA DPH
• TECHNOLOGISTS
• PENNSYLVANIA BTS
• MECHANICS
INSPECTION
CONTACTS
TWO SEMI-ANNUAL CON-
TACTS. STANDARDIZA-
TION CHECKS OR
OBSERVATION OF TEST.
TWO-SEMI-ANNUAL CON-
TACTS. ONE STANDARDI-
ZATION CHECK. ONE
FLIGHT TEST OBSERVAT'N
MAY BE ASKED TO TAKE
PRACTICAL TEST AT ANY
TIME BY STATE POLICE
RECENCY
OF
EXPERIENCE
6 MONTHS
WITHIN LAST
2 YEARS
\S
LOG OF
OPERATING
TIME
UNDER
vXEXISTING
LICENSE
REQUAL.
PROGRAM
\S
(2)
MEDICAL
EXAM
\/
^s
REQUEST
OF
FACILITY
v/
(1) OTHER THAN THOSE ASSOCIATED WITH INITIAL CERTIFICATION
(2) ESSENTIALLY A CONTINUOUS UPDATING AND RETRAINING PROGRAM
EXCEPT FOR AEC OPERATORS, DME'S AND DPE'S, VERY LITTLE
ACTUAL QUALITY CONTROL IS EXERCISED OVER PERSONNEL
-------
Table 2-11. Summary of Term of Certification
I
IJi
Ul
• FACILITIES
• FAA
• AIRCRAFT REPAIR STATIONS
• MECHANIC TRAINING SCHOOLS
• FLIGHT/GROUND SCHOOLS
• CALIFORNIA BAR
•INST. & INSP. STATIONS
• CALIFORNIA DPH
•CLINICAL LABS
• PENNSYLVANIA BTS
• INSP. STATIONS
•PERSONNEL
• FAA
• AVIATION MECHANICS
• FLIGHT RATINGS
• DME'S
• DPE'S
• AEC
OPERATORS
• CALIFORNIA BAR
• DEVICE INSTALLERS
• CALIFORNIA DPH
• TECHNOLOGISTS
• PENNSYLVANIA BTS
• MECHANICS
(1) UNLESS SUSPENDED
VALID
INDEFINITELY*1'
4 YEARS
3 YEARS
2 YEARS
1 YEAR
V
-------
-------
3. REVIEW OF TEST PROCEDURES AND
EQUIPMENT REQUIREMENTS
A brief review of emission test procedures and equipment
requirements, as specified in 40 CFR 85 , was made to provide a reference
base for subsequent task activities. This review encompassed the vehicle
categories of LDV-G, LDV-D, LDT-G, HDV-G, and HDV-D. Test and
equipment requirements were segregated into the following categories:
a. Basic test parameters
b. General facility requirements
c. Gas sampling and instrumentation
d. Test conditions
e. Other significant factors
As a result of this review, a matrix •was prepared (see
Table 3-1). This matrix defines and compares the facility, equipment, and
procedural requirements for certification testing in any currently promul-
gated subpart of 40 CFR 85; for 1975 to 1977 model years of LDVs and LDTs,
and 1974 engine testing for HDVs. The information in this matrix was used
in developing many of the work flow elements required to demonstrate that
laboratory and operator certification measures were sufficient to ensure
that emission tests performed by independent laboratories would be made
in accordance with 40 CFR 85.
The laboratory certification procedures described in Sections
4 and 5 are presented for the example of subpart A (LDV-G), 1975 model year
requirements. This is the largest volume subpart (along with subpart C) with
respect to facility and procedural requirements. Thus, any changes in
detailed certification procedures which might be required for certification
in the other subpart areas can be determined directly from examination of
the matrix (Table 3-1).
3Code of Federal Requlations Title 40, Part 85.
3-1
-------
Table 3-1. Emission Test Requirements
C/3
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TYPE OF TEST: VEHICLE, V,
OR ENGINE, E
NATURE OF DYNO TEST
TYPE OF GAS SAMPLING
FEDERAL EMISSION STDS
1974
1975,76 NATL
1975.76 CALIF
1977
1978
DURABILITY DRIVING TRACK
TEMP. CONTROLLED ROOMS
FOR VEHICLE STORAGE
DURATION PER TEST UNIT. HR
TEMP. RANGE, °F
DYNO ROOM TEMP, °F
DYNO ROOM BAROMETRIC, IN Hg
DYNAMOMETER REQUIREMENTS
MAX VEHICLE WT, Ib
INERTIA SIMULATION
POWER ABSORPTION UNIT
CALIB. OF FRICTION LOSS
READ OUT OF SPEED AND TORQUE
RECORDING OF SPEED AND TORQUE
CVS SYSTEM OF 300-350
CFM CAPACITY. WITH ALL
ASSOCIATED EQUIP.
GAS ANALYSIS INSTRUMENTS
CO
C02
NOX
HC
SEPARATE. CONTINUOUS
SAMPLING OF HC VIA
HEATED SMPL LINE
EXHAUST GASEOUS EMISSION TEST
LDV-G
y
LDV-D
V
LDT-G
FEDERAL 23 MINUTE CYCLE
CVS: INGEST ENTIRE VEHICLE
EXHAUST, DILUTE WITH AMBIENT AIR,
COLLECT BAG SAMPLES
HC CO NOX
GRAM/MI
3.4 39 3.1
1.5 15 3.1
0.9 9 2.0
0.41 3.4 2.0
0.41 3.4 0.4
NO
YES
> 12
60-86
76-86
68- 86
CHASSIS
CAN BE > 6000
YES
YES
YES
YES
NO
YES
NDIR
NDIR
CL
FID
NO
HC CO NOX
GRAM /Ml
1.5 15 3.1
1.5 9 3.1
0.41 3.4 2.0
0.41 3.4 0.4
NO
YES
> 12
68-86
68-86
CHASSIS
CAN BE > 6000
YES
YES
YES
YES
NO
YES
NDIR
NDIR
CL
HFID
YES
HC CO NOX
GRAM/MI
3.4 39 3.1
2.0 20 3.1
2.0 20 3.1
NO
YES
212
60-86
76-86
68- 86
CHASSIS
6000
YES
YES
YES
YES
NO
YES
NDIR
NDIR
CL
FID
NO
HDV-G
E
9 MODE, SERIES
OF BRIEF STDY
STATES
HDV-D
E
13 MODE
SERIES OF
STDY STATES
CONTINUOUS SAMPLING
AND RECORDING OF PORTION
OF EXHAUST
[HC + NOX1 CO
GRAM/BHP HR
16 40
NO
NO
> 1
60- 86
68-86
ENGINE
YES
NO
NDIR
NDIR
NDIR {NO ONLY)
NDIR {HIGH HCI
NDIR (LOWHC)
NO
[HC + NOX] CO
GRAM/BHP HR
16 40
NO
NO
< 86
<31
ENGINE
YES
NO
NDIR
NDIR
NDIR INOONLY)
HFID
YES
FUEL EVAPORATIVE
EMISSIONS TEST
LDV-G
LOT
V
FEDERAL 23 MIN. CYCLE
TRAP VAPORS IN
WEIGHED CONTAINERS
GRAM/TEST
2.0
2.0
2.0
2.0
2.0
YES
GRAM/TEST
2.0
2.0
2.0
2.0
2.0
YES
YES
> 12
60- 86
76-86
68-86
CAN BE > 6000
YES
YES
YES
YES
NO
6000
YES
YES
YES
YES
NO
ADSORB FUEL VAPORS
IN ACTIVATED CHARCOAL
TRAP. DETERMINE AMOUNT
COLLECTED BY WEIGHT
DIFFERENCE
EXHAUST
SMOKE TEST
HDV-D
c
TRANSIENT,
ACCELERATION AND
LUGGING MODES
PASS LIGHT
BEAM THROUGH
EXHAUST PLUME
% OPACITY
ACC. LUG. PKS
20 15 50
NO
NO
S86
ENGINE
YES
TORQUE
SMOKEMETER
{LIGHT EXTINCTION
METERI
-------
Table 3-1. Emission Test Requirements (Continued)
z
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K§
8
ELECTRONIC INTEGRATOR
FOR COMPUTING TOTAL HC
TEST PHASES INVOLVED
IN GAS SAMPLING
APPROX. CONC. OF EACH
POLLUTANT CORRESPONDING
TO SPEC. LIMIT, AS MSRD. ppm
HC CO NOX 1974
ASC, 1975. 76 NATL
1975, 76 CALIF
1977
1978 „
INTERCHANGEABILITY OF GAS
ANALYSIS INSTRUMENTS
HC )
NOx(l974 FOR HDV
CO2 1 1975 -78 FOR LDV
co )i975. TG NATL)
1977 1 FOH LDV
1978 )
CALIBRATION GASES
HC
NOX (NO, DILUENT N_>
•*
CO (DILUENT N )
CO2 [DILUENT N2)
TEST UNIT PRE-CONDITIONING
EXHAUST GASEOUS EMISSION TEST
LDV-G
NO
LDV-D
YES
LDT-G
NO
COLD START TRANSIENT
HOT START TRANSIENT
400 1500 80
240 900 50
110 340 50
110 340 10
A
B
C
0
D OR D2
D2
D2
400 1 500 80
900
110 340 50
110 340 10
A2
C1
D-j
D-, OR D2
D2
°2
640 2000 80
540 2000 80
A1
B1
cl
D1
o
ALL IN NOMINAL % FS
(PROPANE, DILUENT AIRI 50, 100
50, 100
10, 25, 40, 50, 60. 70. 85. 100
10, 25, 40, 50, 60, 70, 85. 100
SOAK>.1 HR 76-86°F
SOAK>10 HR 60-86°F
SOAKS! HR 76-86°F
(NORMALLY ACCOM-
PLISHED AS PART OF
EVAP EMISSIONS
TEST]
RUN ONE 23
MIN. CYCLE ON
DYNO.
SOAK >12HR
68-86 F
SOAK >1 HR 76-86°F
SAOK >10HR60-86°F
SOAK *l HR 76-B6°F
(NORMALLY ACCOM
OF EVAP EMISSIONS
TESTI
HDV-G
NO
SAMPLE
THRUOUT TEST
1700 6700 1120
A3(HIGH HC)
A4(LOVU HC)
B2
C2
D3
(DILUENT N2)
LOW HC, ppm
HEXANE 100,
200, 300, 400,
600.800, 1000
[DILUENT N2I
HIGH HC, ppm
HEXANE 600,
1000, 15OO,
2500, 4000.
6000. 8000.
10,000
NO, DILUENT N2,ppm
250,500,750,1000
1500. 2000. 2500.
3000. 3500, 4000
BLEND OF CO 8. CO2
DILUENT N2
COPLUSCO2
0.5 16.0
1.0 15.0
2.0 14.0
3.0 13.0
4.0 12.0
6.0 10.0
8.0 8.0
10.0 6.0
>1 HR 60~86°F
RUN 5 MIN
ON DYNO
HDV-D
NO
SMPL CONT. FOR
AT LEAST LAST
5 MIN EACH MODE
1330 5300 890
A2
B2
D3
NOMINAL % FS
NOT SPECIFIED
25,50,75,100
25.50,75,100
25,50,75.100
RUN 10MIN
ON DYNO
FUEL EVAPORATIVE
EMISSIONS TEST
LDV-G
LOT
DIURNAL BREATHING LOSS
RUNNING LOSS
HOT SOAK LOSS
1 HR DRIVING ON DURABILITY
TRACK ONE 23 MIN
CYCLE ON DYNO.
SOAK>1 HR 76-B6°F
SOAK >1 Hfl 76-86°F
(DIURNAL LOSS MSRD HERE)
EXHAUST
SMOKE TEST
HDV-D
RECORD CONT.
THHUOUT TEST
NEUTRAL DENSITY
FILTERS OF % OPACITY
10
20
40
RUN 10MIN
ON DYNO
-------
Table 3-1. Emission Test Requirements (Continued)
OJ
MDITIONS
a
OTHER
DYNAMOMETER TEST
MODES PER TEST CYCLE
APPROX, MIN. DYNO TEST TIME
TEST CONTROL PARAMETERS
EXHAUST SYSTEM
EXHAUST BACK PRESSURE
INLET AIR SYSTEM
VEHICLE/ENGINE
FLOW MEASUREMENTS
TYPE OF EMISSION DATA RECORD
MOOE UPON WHICH
EMISSION CALCS. ARE BASED
USED IN EMISSION CALCS
BASIC COMPUTATION
PROCESS
EXHAUST GASEOUS EMISSION TEST
LDV-G LDV-D LDT-G
INTERRUPTION, CONTINUE WITH.)
COLD START STABILIZED. COLLECT BAS SMPLE =Z
10MIN SOAK ON OYNO.
(FIRST 505 SEC OF FED. DRIVING CYCLE)
38 MIN
DYNO SPEED VS TIME
CVS
±5 IN H2O 15 IN HjO ±5 IN H-O.
±1INH20 niNH2OON i!1NH20
ON REQUEST REQUEST ON REQUEST
READ OUT OF READ OUT OF READ OUT OF
BAG SMPL CONC BAG SMPL CONC BAG SMPL CONC
* CONT. TRACE
WITH INTEGRATION.
OF HCCONC. VS
CONTINUOUS
HUMIDITY
ACCOUNT FOR POLLUTANT CONC OF DILUENT
AIR. FROM BAS SMPL CONC. * TOTAL VOLUME
TEST PHASE FINAL RESULT IS
(GRAM/MI )| = [0.43 YC| * 0.57 YM * Y( /7.5
HDV-G
9
A
18 MIN
XCPT IDLE.
CT TO FL
MANIFOLD
PRESSURE
CHASSIS TYPE
CONTINUOUS
RECORDING
LAST 3 SEC
IXCPT ALL 43
SEC OF CT MODE)
FUEL FLOW
HUMIDITY
FLOW RATE 8. C
BALANCE. CMPTE
EACH MOOE.
BRAKE SPCFC
v (MASS f WF. 1 AVG B.S. MASS FOR LAST 2 CYCLES - B
B.S.(MASS)( = ~- ! --- ! COMBINE AS (0.3SA * 0.65BI
HDV-D
13
1
2HR 10MIN
MAX HP
ENGINE RPM
& HP
15 IS' FROM
XHSTMNFLO.
CHASSIS TYPE
MUFFLER
SPCFD PER
MNFCTR'S
LIT.
SPCFD PER
MNFCTR'S LIT
AIR FLOW (OR
EXHAUST FLOW)
CONTINUOUS
RECORDING
LAST 60 SEC
FUEL & AIR
ENGINE RPM &
TORQUE, HUMIDITY
PLLNT EACH MODE
FROM CONC. X EX-
EACH BY WF FOR
(BCJ XIMASS, « WFI
' ' LlHHP x WFI
FUEL EVAPORATIVE
EMISSIONS TEST
LDV-G
LOT
ANSIENT
(RUNNING LOSS M5RO HERE}
VAPOR LOSS NOT MSRD DURING
10 MIN SOAK OR HOT START
SOAK 1 HR HOOD DOWN 76-86°F
23 MIN
FED. DRIVING CYCLE
RECORD WEIGHT CHANGE
OF COLLECTION TRAP
CONTINUOUS
ALL 3 CYCLES
EXHAUST
SMOKE TEST
HDV-D
2
3
>20MIN
IDLE TO RATED
SPEED 0 TO MAX HP
ENGINE RPM
& DYNO LOAD
15 '5- FROM
XHST MNFLO.
CHASSIS TYPE
MUFFLER
SPCFD PER
MNFCTR'S LIT
SPCFD PER
MNFCTR'S LIT.
CONTINUOUS
RECORDING
CONTINUOUS
DIVIDE EACH MODE INTO
INTRVLS IN LUGGING MOOE. & 3
"LUGGING" VALUE = AVG OF 15 VALUES
-------
-------
4. FUNCTIONAL TASK SELECTION
A set of discrete basic requirements and procedures were
selected to form the basis of a sound certification program for both lab-
oratories and test operators. These functional task selections were made
after reviewing the status of established regulatory procedures used by other
federal and state certification agencies (Section 2. 7) and noting the consensus
as to functional task requirements in the comparable certification processes.
Also considered in the selection process were the specific requirements of
40 CFR 85 regarding facilities, procedures, and test operations (Table 3-1).
4. 1 LABORATORY CERTIFICATION
4. 1. 1 Initial Certification and Renewals
Table 4-1 lists the specific functional tasks required of EPA
and the laboratory requesting certification, both for initial certification and
renewals.
The EPA tasks are directed to:
a. Application form preparation
b. Application processing and review after receipt
c. Laboratory inspection
d. Final review of inspection results and determination as
to issuance or denial of certification.
The laboratory tasks are solely concerned with preparing and
submitting the application for certification to EPA. The basic information
required, as noted in Table 4-1, would be concerned with (a) certified
operators on the staff of the laboratory; (b) a complete description of the
facility, equipment, and test procedures used by the laboratory (to permit
an initial determination as to compliance with 40 CFR 85 requirements);
and (c) other organizational and financial data which might be relevant to the
desirability or suitability of certifying the laboratory for emission testing
4-1
-------
Table 4-1. Initial and Renewal Laboratory Certification
CO
LABORATORY TASKS
• PREPARE AND SUBMIT APPLICATION (FOR
SUB-PART RATING DESIRED)
• LISTING CERTIFIED OPERATORS ON
STAFF
• IDENTIFY FACILITY, EQUIPMENT, AND
TEST PROCEDURES USED IN ACCORDANCE
WITH 40 CFR 85 REQUIREMENTS
• PROVIDE OTHER INFORMATION
• DIRECTORS
• RELATIONSHIPS WITH OTHER
ORGANIZATIONS
• FINANCIAL AND BUSINESS DATA
EPA TASKS
• PREPARE APPLICATION FORMS
• PROCESS AND REVIEW APPLICATION DETAILS
• SCHEDULE INSPECTION VISIT
• PERFORM INSPECTION OF LABORATORY
• TESTING
• CALIBRATION
• PROCEDURES
• EQUIPMENT
• REVIEW INSPECTION RESULTS
• ISSUE OR DENY CERTIFICATION
-------
purposes. For example, if the laboratory were a part of another organization
which manufactured or sold retrofit or emission-control-related parts, it
might be considered a conflict of interest to permit certification of the
laboratory.
4.1.2 On-Going Quality Control
The specific functional tasks selected for quality control are
listed in Table 4-2. The basic EPA tasks consist of:
a. Periodic scheduled (semi-annual) laboratory inspections
b. Unannounced (random) laboratory inspections
c. Naming the laboratory's calibration gases on EPA equipment
The scheduled inspections would be extensive and consist of test observations,
inspection of calibration procedures, checking for certified personnel, exam-
ination of facility data and records, and observation of the general facility,
equipment, and operations. The unannounced inspections would be less
extensive in nature, and would be principally directed to verifying that
proper calibration schedules were being followed.
The laboratory would be required to transmit a complete set
of emission test data to EPA for each certified test made; this would permit
the opportunity for a direct observation of the quality of the test data.
Quarterly measurements of EPA gas cylinder "unknowns" would be required
to verify the laboratory's gas sampling instrumentation accuracy. During
EPA inspection visits, the laboratory would be required to perform any tests,
calibrations, or other checks required by EPA inspectors. In addition, any
changes in certified operators, equipment loss or change, etc., would have
to be provided to EPA to permit temporary suspension of certification or
reinspection, if necessary.
4-3
-------
Table 4-2. On-Going Laboratory Quality Control
LABORATORY TASKS
• TRANSMIT TO EPA COMPLETE DATA SET FOR
EACH CERTIFIED TEST MADE
• TRANSMIT TO EPA ANY STATUS CHANGES
• EQUIPMENT LOSS OR CHANGE
• CERTIFIED OPERATORS
• ETC.
• MAKE QUARTERLY MEASUREMENTS OF
EPA GAS CYLINDER "UNKNOWNS"
• TRANSMIT TO EPA
• PERFORM ANY TESTS, CALIBRATIONS, OR
OTHER CHECKS REQUIRED BY EPA
DURING INSPECTION VISITS
EPA TASKS
• PERIODIC SCHEDULED INSPECTIONS OF LABORATORY
• SEMI-ANNUAL
• OBSERVE TESTS
• CHECK FOR CERTIFIED PERSONNEL
• INSPECT CALIBRATION PROCEDURES
• EXAMINE DATA AND RECORDS
• OBSERVE STATUS OF
• FUEL HANDLING OPERATIONS
• AUXILIARY EQUIPMENT
• GENERAL FACILITY
• UN-ANNOUNCED LABORATORY INSPECTIONS
• RANDOM, AVERAGE 2 PER YEAR
• VERIFY PROPER CALIBRATION SCHEDULES
• NAMING OF LABORATORY'S CALIBRATION
GASES ON EPA EQUIPMENT
-------
4. 2 OPERATOR CERTIFICATION
4. 2. 1 Initial Certification and Renewals
Table 4-3 lists the specific functional tasks required of EPA
and the operator requesting certification, both for initial certification and
renewals. The principal EPA tasks are directed to:
a. Preparing application form
b. Processing and reviewing application after receipt
c. Preparing, administering, and grading written examinations
d. Preparing, administering, and grading practical examinations
e. Granting or denying certification
The operator's tasks are concerned with:
a. Preparing and submitting the application
b. Taking and passing the written examination
c. Taking and passing the practical examination
With regard to the application, a preferred approach is to have the employer
request that the operator be certified and verify the minimum job experience
requirements of the applicant. It would appear, however, that an alternative
path should be available whereby the applicant can apply directly to EPA.
Similarly, it would be preferred to have the written and practical tests given
at the employer's facility, but it may be necessary to permit such testing at
the EPA test facility.
4. 2. 2 On-Going Quality Control
As noted in Section 2.7, ordinarily there is very little on-going
quality control exercised over operators (except in the specific case of AEC-
licensed nuclear power station operators). However, as listed in Table 4-4,
the nature of the task functions selected for the laboratory certification pro-
cess make it possible to exercise a reasonable degree of control over the
quality of the work performed by the operator.
4-5
-------
Table 4-3. Initial Operator Certification*
OPERATOR TASKS
• PREPARE AND SUBMIT APPLICATION (FOR
SUB-PART RATING DESIRED)
• HAVE EMPLOYER REQUEST THAT HE
BE CERTIFIED**
• HAVE EMPLOYER VERIFY APPLICANT
HAS MINIMUM JOB EXPERIENCE
REQUIREMENTS**
• TAKE AND PASS WRITTEN EXAMINATION
• AT EMPLOYERS FACILITY
• TAKE AND PASS PRACTICAL TEST
• AT EMPLOYERS FACILITY
* SAME TASKS INVOLVED IN CERTIFICATION RENEWAL,
EXCEPT FOR VERIFICATION OF EXPERIENCE
**AN ALTERNATIVE PATH IS FOR THE APPLICANT
TO APPLY DIRECTLY TO EPA FOR EXAMINATION
AT EPA ANN ARBOR FACILITIES
EPA TASKS
• PREPARE APPLICATION FORMS
• PROCESS AND REVIEW APPLICATION DETAILS
• SCHEDULE EXAMINATIONS
• PREPARE WRITTEN EXAMINATION
• ADMINISTER AND GRADE WRITTEN EXAM
• PREPARE PRACTICAL TEST
• ADMINISTER AND GRADE PRACTICAL TEST
• GRANT OR DENY CERTIFICATION
-------
Table 4-4. On-Going Operator Quality Control
OPERATOR TASKS
• VERIFY CERTIFIED TEST DATA
TRANSMITTED TO EPA
• PARTICIPATE IN OR PERFORM ANY
TESTS, CALIBRATIONS, OR OTHER
CHECKS REQUESTED BY EPA AT
TIMES OF SCHEDULED OR UN-ANNOUNCED
INSPECTIONS OF LABORATORY BY
EPA PERSONNEL
EPA TASKS
• SCREEN CERTIFIED TEST DATA
SUBMITTED FOR COMPLIANCE WITH
PROCEDURES
• OBSERVE OPERATOR'S PERFORMANCE
DURING SCHEDULED AND UN-ANNOUNCED
INSPECTIONS OF LABORATORY
-------
First, the operator is required to verify (by signature) that
the certified test data submitted to the EPA by the laboratory has been per-
formed under his surveillance and control. This permits EPA to screen
the submitted test data for compliance with procedures. Second, the operator
can be required to participate in or perform any tests, calibrations, or other
checks requested by EPA inspectors at times of laboratory inspections (sched-
uled or unannounced). This permits direct observation of the operator's per-
formance and techniques.
4. 3 USE OF THE FUNCTIONAL TASKS
The selected functional tasks, as described above, are the basic
building blocks of the laboratory and operator certification processes. They
provide the basis for further breaking down the certification process into more
definitive work elements (or steps) which can be developed to assure meeting
the specific requirements of 40 CFR 85 as well as permitting a simple and
logical sequencing of required work elements. The so-developed work flow
sequences are described in detail in Section 5.
4-8
-------
-------
5. WORK FLOW SEQUENCE ANALYSIS
5. 1 INTRODUCTION
This section presents the results of an analysis of the work
flow sequence required to actually perform the selected basic functional tasks
for laboratory and operator certification as delineated in Section 4. The
analysis was directed to a detailed expansion of the selected basic functional
tasks, to identify the number and types of work elements involved, and to
indicate the interrelation of work flow elements between the laboratory (or
test operator) and the EPA laboratory certification control group.
During the analysis effort, emphasis was directed to:
a. Simple and logical work flow elements
b. Minimum sequencing of operations
c. Minimum EPA staff requirements
d. Adequate control over key activities of the certified
laboratory
e. Minimum interference with day-to-day activities of
the laboratory
f. Minimum involvement of the employer in the operator
certification process.
The analysis resulted in the formulation of work flow sequences
or steps in the form of logic or flow sheet diagrams. These flow sheets are
necessarily detailed in nature in order to adequately describe both the nature
of the work flow elements involved and their relationship to one another.
Therefore, the results are presented in graphical form with a minimum of
discussion to identify and describe the flow sheet, per se.
5.2 LABORATORY CERTIFICATION
The work flow sequence analysis for laboratory certification
was principally directed to defining two levels of expansion of the selected
5-1
-------
functional tasks of Section 4. In the first level of expansion, each significant
work task area was identified and assigned a "block number" for reference
purposes. Then a basic task flow sequence was established to define the inter-
relationship of the work task areas. In the second level of expansion, the
principal work elements (or steps) within each work task area were identified.
This work element description was used as the basis for defining the scope of
the laboratory certification group work load, and enabled the definition of
staffing requirements, schedules, and costs as described in Section 6.
In two areas, application form preparation and application
processing, a third level of expansion was carried out as examples of the
level of detail to which each key block area can be further expanded. This
degree of expansion identified detailed work processes performed by individ-
uals in accomplishing specific work elements.
The total number of flow sheets developed in the analysis
activity is shown in Table 5-1. These flow sheets are described in the fol-
lowing sections.
5. 2. 1 Initial and Renewal Certification
Figure 5-1 describes the overall process of laboratory certifi-
cation (both initial and renewal) in flow sheet format. The major work task
areas are identified by a roman numeral "block number", and Block X is
further sub-identified by letter for further work element definition purposes.
As can be noted, a 2-year certification term was selected as appropriate in
view of the frequency of scheduled and unannounced quality control inspection
visits described in succeeding flow sheets. Although not addressed in this
study, a provision for appeal by a rejected applicant laboratory is included
in the overall certification program. The major work elements are described
below.
5. 2. 1. 1 Application Requirements
Figure 5-2 outlines the essential informational areas which
should be included in an application for certification for sub-parts "A" and
5-2
-------
Table 5-1. Flow Sheet Breakdown — Laboratory Certification
(Work Flow Sequence Analysis)
FLOW SHEET NO.
FIRST LEVEL OF EXPANSION
/ LABORATORY CERTIFICATION BASIC WORK AREAS 201
{INITIAL AND RENEWAL)
SECOND LEVEL OF EXPANSION
/ BLOCK I: INFORMATION REQUIRED IN APPLICATION 2011-1
BLOCK IA: BASIC INFORMATION ON LABORATORY 2011-2
BLOCK 1C: EXHAUST EMISSION MEASUREMENT 2011-3
INFORMATION
/ BLOCK U: OVERVIEW OF APPLICATION PROCESSING 201-A
BLOCK II: PROCESSING OF APPLICATION 2012-1
BLOCK II: PRELIMINARY PROCESS SCREENING 2012-2
/ BLOCKS III THROUGH VII: APPLICATION CORRECTION LOOP 2013
/ BLOCK VIII: ORGANIZE AND SCHEDULE INSPECTION VISIT 2018
/ BLOCK IX: TEST OBSERVATIONS 2019
/ BLOCK X: DETAILED OBSERVATIONS OF EQUIPMENT, 2010-1
TEST AND CALIBRATION PROCEDURES 2010-2
/ BLOCK XI: INSPECTION VISIT REVIEW 20111
THIRD LEVEL OF EXPANSION
/ BLOCK I: ROUGH DRAFT OF APPLICATION FORM APPENDIX B
/ BLOCK U: PROCESSING OF GAS HANDLING SYSTEM AND GAS
ANALYSIS INSTRUMENTS SECTIONS OF APPLICATION
SCHEMATICS AND COMPONENT LISTS 2012-Cl(i)
CALIBRATION OF CVS SYSTEM ZOlZ-Cl(ii)
VERIFICATION OF CVS SYSTEM 2012-C1 (iii)
GAS ANALYSIS INSTRUMENTS 2012-C2
-------
FLOW SHEET 201
Ui
i
r
rip-la-
1 FIED "
L.P.ELA!
[CHANGE
1 BY LAB
i
TE
P
INFORMATION ON
DIRECTORS,
RELATIONSHIPS
WITH OTHER
ORGANIZATIONS,
FINANCIAL AND
BUSINESS DATA
1
DETAILED
TECHNICAL
INFORMATION
r
CERTIFIED
PERSONNEL
'DROP \
/APPLICAJ
TION /
J *
I V *
J V
APPLICATION SATISFACTORY J ffi,Nn°FR^
II 1 ' 111 VII 1" n Jvill
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SFACTORY
'ION FUNDAMENTALLY UNSATI
0
-J
Q.
Q.
1
, £
k. ' FDA A 1 EPA y\. iuB
\f , oSfton^n __ fc REVIEW >/> . -•ir.HEDULE _^ INSPECTION _^/\vls
/. 'CHANGES * «» t|JA \/^ INSPECTION •* VISIT \/
f ' (•*• *^ V VISIT Y
! liv
• 'A<
XIV
~x
\ /DENY \
REASONS 1— ICERTIFI-1
J \CATION /
V J VI
TBANCUIT , 1ST VISIT
-^. 'ib0' UN-"- —^ RESULTS 1
APPLICANT TOEPA T IX
OBSERVE COMPLETE AT EPA
CHANGES UNSATISFACTORY TEST OF SUB-PART DISCRE
THOSE
( ,
EPA INSPECTION TEAM SPLIT
UP FOR DETAILED OBSERVATION,
TESTING, OR CALIBRATION OF
SPECIFIC PROCEDURES AND
EQUIPMENT
. 1
SEQUENT
TS
XIII
TION,
T ONLY
AREAS
TO BE
ENT
A| B \ C| D| | F 1 0 1
^NotlNG ^^CLE fN^UME^T! ?™CVS) FH l^ulp^T
GENERAL
FACILITY
II III
i XI
EPA
REVIEW
CHANOES ^S »/$rir^«
REQUIRED W *lcAT!oNT
APPEAL DENIAL
OFCERFICIATIONJ
Figure 5-1. Initial and Renewal Laboratory Certification
-------
TASK BLOCK 201-1
TASK SHEET 2011-1
SEE
TASK SHEET
2011 -2
I
Ui
c
EXHAUST
EMISSION
MEASURING
EQUIPMENT
i i
SEE
TASK SHEET
201 1 -3
r
ROLL
AND
FRAME
D
DYNAMOMETER
LIST EACH TO
BE USED IN
CERTIFIED
TESTS
MANUFACTURER
AND MODEL NO.:
BASIC DESIGN OR
PERFORMANCE
PARAMETERS
POWER
ABSORPTION
UNIT
[
E
EVAPORATIVE
EMISSIONS
MEASUREMENT
1
SCHEMATIC
DRAWING OF
CANISTERS
1
BALANCE:
MANUFACTURER
AND MODEL NO.,
CALIBRATION
PROCEDURE
AND SCHEDULE
1
INERTIA
SIMULATION
UNIT
1
DESCRIBE ANY
IN-HOUSE MODS
VEHICLE PREPARATION
DRIVING SCHEDULE FOR
I HR PREP: SHOW ROUTE,
MILEAGE, TYPICAL SPEEDS,
PROXIMITY TO LAB
FUELS HANDLING
STORAGE
TEMPERATURE
CONTROLLED SOAK
ROOMS ADEQUATE TO
CONTAIN ALL TEST
VEHICLES FOR THE
FOLLOWING
SEQUENTIAL SOAKS,
WITH NO PRECIP.
ON TEST VEHICLES
1
1 1
DELIVERY UNIT;
i.e., 55 GAL. DRUM,
TANKER TRUCK
TRANSFER TO
HOLDING TANK, ETC
STORAGE UNIT
FROM
WHICH FUEL IS
ROUTINELY DRAWN
FOR LAB USE
76
- 86° F, >1
HR
1
60 - 86° F, >10HR
76 - 86° F, >1 HR
TEMPERATURE AND
VENTING CONTROL
FOR EACH STORAGE
CONDITION
LONG TERM
(between withdrawals)
1
SHORT TERM
(prior to and during
withdrawal)
1
DYNO, 68 - 86° F
1
ROLL
SPEED
1
FRICTION
LOSSES
TORQUE
MEASUREMENT
SCHEMATIC OF FUEL
PLUMBING FROM
DELIVERY UNIT TO
DISPENSING POINT
IN LAB
Figure 5-2. Application for Subparts "A" and "C" Certification
-------
"C" ratings. Variations for other subpart ratings may be determined by
inspection from the matrix of requirements presented in Table 3-1. Figure
5-3 further illustrates the level of detail required in the area of information
concerning the laboratory proper, and Figure 5-4 notes the level of informa-
tional detail required for the exhaust emission measurement systems.
It is considered that the application must contain statements,
drawings, etc. , in sufficient detail to permit the EPA laboratory certification
staff to make a preliminary finding of compliance with 40 CFR 85 test pro-
cedures and equipment requirements (see Table 3-1) prior to scheduling an
inspection visit to verify compliance. Appendix B describes the format for
a typical application form which would require the inclusion of the necessary
detailed information.
5. 2. 1.2 Application Processing and Evaluation
Figure 5-5 presents an overview of the application processing
and evaluation function. It is visualized that submitted applications would fit
into one of four categories:
a. The test procedures and equipment delineated in the
application are identical to or very similar to the
requirements of 40 CFR 85.
b. The procedures or equipment delineated are different from
40 CFR 85 requirements but demonstrated to be equivalent
or closely comparable.
c. The procedures or equipment are different from 40 CFR 85
requirements, but a variance is granted by EPA.
d. The procedures or equipment are not reconcilable with
40 CFR 85 requirements and certification is denied.
As graphically depicted in the lower half of Figure 5-5, the overall work
involved in comparing the test procedures and equipment proposed by the
applicant laboratory with the specific requirements of 40 CFR 85 falls into
four basic "block-number" work areas:
a. Block II - application processing
b. Blocks III to VII - application correction loop
5-6
-------
I
-v]
OWNERSHIP
1a
TYPE,i.e.,CORPORATION,
INSTITUTE, ASSOCIATION,
GOVERNMENTAL ENTITY,
etc.
1b
NAME AND TITLE OF
PERSON AUTHORIZED
TO REPRESENT LAB IN
ALL TRANSACTIONS
WITH EPA
1C
LIST NAMES OF ALL
MEMBERS OF BOARD OF
DIRECTORS, OR OTHER
CONTROL LING GROUP
BASIC INFORMATION
ON LABORATORY
2a
BRIEF BUSINESS
HISTORY OF LAB
2b
FINANCIAL STATEMENT
OR OTHER INFORMATION
NORMALLY DISTRIBUTED
TO DIRECTORS OR SHARE
HOLDERS, SHOWING FIN-
ANCIAL STATUS OF LAB
2c
APPROXIMATE LEVEL
OF BUSINESS:
2(i)c
ALL LABORATORY
OPERATIONS OF PARENT
ORGANIZATION
(if applicable)
EMISSION MEASUREMENT
ACTIVITY AT THIS
FACILITY
GENERAL FACILITY
3a
DESCRIBE PHYSICAL
PLANT, LOCATION
3b
APPROXIMATE INVEN-
TORY OF EMISSION TEST
EQUIPMENT, i.e.,
NUMBER OF DYNO TEST
CELLS, etc.
3c
APPROXIMATE NUMBER
OF PERSONNEL
3d
DOES LOCAL LAW, OR
LABORATORY POL ICY, OR
ANY OTHER CONDITION,
FORBID OR RENDER
IMPRACTICAL, THE
RIGHT OF ENTRY OF EPA
INSPECTORS AS DE-
SCRIBED IN 85.1306 (b)
Figure 5-3. Laboratory Information Requirements
-------
TASK BLOCK 201-1 G
TASK SHEET 2011-3
EXHAUST
EMISSION
MEASUREMENT
I
00
CALIBRATION
OF CVS
SYSTEM
(iii)a
VERIFICATION
OF CVS
SYSTEM
(iii)lb
PROCEDURE
VERIFICA-
TION DATA
GAS
ANALYSIS
INSTRUMENTS
LIST BY GAS,
MANUFACTURER,
MODEL NO.
2b
IN-HOUSE
MODIFICATIONS
2c
CALIBRATION
CURVES
CALIBRATION
AND SPAN GASES
DATA LINK
3a
4a
LIST BY GAS,
MANUFACTURER.
CONCENTRATION,
TOLERANCE
3b
LIST ALL WHICH
ARE NBS
TRACEABLE
SPECIFY FORM
OF PERMANENT
RECORD
4b
FUNCTIONAL
BLOCK DIAGRAM
4c
DESCRIBE
SIGNAL FLOW
4d
CALIBRATION;
PROCEDURE
AND SCHEDULE
Figure 5-4. Exhaust Emission Measurement Details
-------
TASK SHEET 201-A
APPLICATION PROCESS MUST COVER ALL ASPECTS
OF 40CFR 85, SUB-PARTS A AND N. EACH APPLI-
CABLE PARAGRAPH OF THESE SUB-PARTS MUST BE
COMPARED WITH THE CORRESPONDING PROCEDURE
OF THE APPLICANT, AND THE RELATION BETWEEN
THE TWO MUST BE EVALUATED AND PROCESSED
INTO ONE OF FOUR CATEGORIES:
APPLICANT PROCEDURE IS
IDENTICAL OR VERY SIMILAR
TO THAT OF40CFR 85
DIFFERENT PROCEDURE IS
USED WHICH APPLICANT
DEMONSTRATES TO BE
EQUIVALENT OR CLOSELY
COMPARABLE TO THAT OF
40CFR 85
APPLICANT USES A DIFFER-
ENT PROCEDURE FOR WHICH
A VARIANCE IS GRANTED BY
EPA
PROCEDURES NOT RECON-
CILABLE; CERTIFICATION
DENIED
THIS EVALUATION AND PROCESSING OCCUR
SEQUENTIALLY. BY TASK BLOCK NUMBER
(of flow sheet 201, as follows:)
xO
Z 0
UJ Z
2 <
Ocoo:
LJ-,<
-------
c. Block IX - observation of actual subpart test during the
inspection visit
d. Block X - detailed observations of testing, calibrations,
procedures, and equipment during the inspection visit.
Figure 5-6 (left-hand side) summarizes a step-by-step method of processing
the application from initial receipt through final evaluation by the EPA labo-
ratory certification group, using the information obtained from a through d
above. Also shown in Figure 5-6 (right-hand side) is the sequence of oper-
ations involved in evaluating the application using a four-point grading sys-
tem as noted on the figure.
Because of the level of detail included in the application, it may
be advisable to perform a preliminary examination of the completed application
immediately upon receipt to identify possible causes for denial or areas of
obvious uncertainty. This information is required to communicate with the
laboratory and resolve such issues prior to scheduling the inspection visit.
Figure 5-7 denotes a brief critical scan path which can be followed in pre-
liminary application processing activities.
An application correction loop (Blocks III through VII of Fig-
ure 5-1) is included in the certification work flow process. Its purpose is to
ensure that, prior to the inspection visit, there is every indication that certi-
fication is warranted, i. e. , that the application, on its face, is felt to be in
compliance with the test procedures and equipment requirements of 40 CFR
85. Figure 5-8 illustrates the work flow elements involved in the process of
making corrections to the application until the necessary degree of compliance
with requirements appears in the application proper.
As an example of the level of detailed work that has to be per-
formed in order to qualitatively and quantitatively evaluate the application,
Figures 5-9 through 5-12 were prepared. In checklist fashion, they illustrate
specific items that should be examined and denote questions which must be
5-10
-------
DIVIDE APPLICATION INTO FUNCTIONAL SECTIONS,
BY THE STRUCTURE SHOWN FOR BLOCK 201-1,
FLOW SHEETS 2012-A THRU -G.
Q Q
INPUTS FROM ALL REVIEWERS
EACH SECTION IS ASSIGNED TO AN INDIVIDUAL
REVIEWER. AN EXAMPLE SECTION IS THAT OF
FS 2012-CI (i) "GAS HANDLING SYSTEM -
SCHEMATICS AND COMPONENT LIST"
EACH REVIEWER PROCESSES THAT SECTION IN
ACCORDANCE WITH THE APPROPRIATE CHECK
LIST. THE EXAMPLE CHECK LIST IS DETERMINED
FROM FLOW SHEET 2012-Cl|i)
FOR EACH CHECK LIST ITEM, REVIEWER GRADES APPLICATION
AS 1 A, 1, 2, OR 3
1A QUANTITATIVELY IN ACCORDANCE WITH 40 CFR 85, NO
SIGNIFICANT JUDGMENT FACTOR REQUIRED. NEXT INPUT
OCCURS DURING INSPECTION VISIT.
1 JUDGMENT ITEM, CONSIDERED SATISFACTORY, WITH NO
FURTHER ACTION REQUIRED UNTIL INSPECTION VISIT.
2 ADDITIONAL INFORMATION NEEDED, OR CHANGES
RECOMMENDED OR REQUIRED.
3 FUNDAMENTALLY DEFICIENT; RECOMMEND REJECTION
OF APPLICATION.
SATISFACTORY; NO
FURTHER INPUTS UNTIL
INSPECTION VISIT.
ENTER LOOP OF
BLOCKS III -•• VII,
FLOW SHEET 201
STOP PROCESSING
OF REMAINDER OF
APPLICATION
IMMEDIATELY
EACH ITEMGRADED 1, 2, OR 3 IS REVIEWED BY EPA STAFF,
AND THE FINAL GRADE ESTABLISHED.
THIS PROCESS IS INDICATED ON THE RIGHT SIDE OF THIS
CHART.
(Block XIV of
Flow Sheet 201|
Figure 5-6. Processing of Application
-------
FLOW SHEET 2012-2
'RECEIPT^
OF COM-
PLETED
APPLICA-J
BRIEF CRITICAL PATH SCAN OF APPLICATION TO
PICK OUT POSSIBLE CAUSES FOR DENIAL. KEY
ITEMS TO BE CHECKED INCLUDE THE FOLLOWING:
INDEPENDENT STATUS
OF LAB MAY BE
QUESTIONED; i.e.,
OWNERSHIP,
CONTROL, OR
STRONG INFLUENCE
BY AUTOMOTIVE
MANUFACTURING
INTERESTS
1C
EXHAUST EMISSIONS MEASUREMENT
CHECK RECORDS
OF CERTIFIED
OPERATORS TO
VERIFY THAT
THEY HAVE
APPLICABLE
SUB-PART
RATINGS
I A3
GENERAL FACILITY
(Jl
I
RESTRICTION TO
RIGHT OF ENTRY
OF EPA INSPECTORS
Cl
GAS HANDLING
SYSTEM
DYNAMOMETERS
C2
GAS ANALYSIS
INSTRUMENTS
C3
CALIBRATION
AND SPAN GASES
IG
FUEL HANDLING
CALIBRATION
PROCEDURE
GREATLY
DIFFERENT
FROM PART 85
SCHEMATICS DIFFER
SIGNIFICANTLY FROM
FIGURES A75-1 AND/
OR A75-2
UNAPPROVED
TYPES OF
ANALYZERS
CVS CALIBRATION
AND/OR
VERIFICATION
PROCEDURES
DIFFERENT FROM
PART 85
USE FLOW MIXING
PROCESS FOR IN-
HOUSE PREPARATION
OF MIXTURES
NUMBER OR
ACCURACY OF
GASES NOT
ADEQUATE
LACK OF PROPER
TEMPERATURE AND
VENTING CONTROL
DURING FUEL
WITHDRAWAL
ANY OTHER
SECTIONS IN WHICH
THERE APPEARS
TO BE A
SIGNIFICANT
DISCREPANCY FROM
REQUIREMENTS OF
PART B5
NO SIGNIFICANT DISCREPANCIES
IF ANY OF THE ABOVE ITEMS LOOK AS IF
CERTIFICATION IS QUESTIONABLE, REVIEW
THESE ITEMS FIRST, IN DETAIL, INCLUDING
BLOCKS III—»-VII OF FLOW SHEET 201
I DISCREPANCIES RESOLVED ADEQUATELY
/\TO JUSTIFY BLOCK 201-VIII
PROCEED WITH PROCESSING
OF REMAINDER OF
APPLICATION, PER FLOW
SHEET 2012-1
SEE FLOW
SHEET 201
Figure 5-7. Preliminary Processing of Application
-------
FLOW SHEET 2013-
CORRECTION LOOP OF BLOCKS I
-VII
THE FUNCTION OF THIS LOOP IS TO INSURE THAT,
PRIOR TO THE INSPECTION VISIT, THERE IS EVERY
INDICATION THAT CERTIFICATION IS WARRANTED.
IF THIS IS NOT THE CASE FOR ANY ITEM, THE
CORRECTION LOOP MUST BE ENTERED, AND
REPEATED IF NECESSARY, UNTIL EITHER THAT
ITEM IS SATISFACTORY, OR THE APPLICATION IS
DENIED BECAUSE OF NON-COMPLIANCE.
INPUTS FROM BLOCK 201-11
(FS 2012-1)
INPUT FROM BLOCK XI
(after inspection visit]
EACH ITEM IS DISCUSSED WITH
APPLICANT BY TELEPHONE
AND/OR MAIL.
DISCREPANCY OR UNCERTAINTY IS
DESCRIBED TO APPLICANT, WITH
PROPOSED OR REQUIRED CHANGES,
CORRECTIONS OR EXPLANATIONS.
Figure 5-8. Application Correction Loop
-------
FLOW SHEET 2012-Cl(i)
IC1 (I)b
COMPONENT LIST
EXHAUST GAS SAMPLING
SYSTEM Cf. FIG. A7S-1
EXHAUST GAS ANALYSIS
SYSTEM Cf. FIG. A75-2
FITTINGS AND
COMPONENTS
i.
MATERIALS OF
CONSTRUCTION
incwTii-Ai 1 MINOR CHANGES,
IDENTICAL NOT CONSIDERED
1 AFFECTING RESULTS
A A
MORE EXTENSIVE
CHANGES TO SCHEMATIC
^
SATISFACTORY
EXPLANATION THAT
SYSTEM PERFORMS
EQUIVALENT FUNCTION?
1
SCHEMATIC
SIGNIFICANTLY
DIFFERENT,
RAISES BASIC
QUESTION AS TO
EQUIVALENCE
OF RESULTS
1
IS OPERATIONAL
PROCEDURE CLEAR,
INCLUDING PRE-AND-
POST-TEST OPERATIONS?
GO THRU COMPONENT
LIST. CHECK IF EACH
IS OF CORRECT TYPE
FOR THIS APPLICATION
LIST ALL MATERIALS
WHICH CONTACT GAS
STREAM TO BE ANALYZED
UNDILUTED
EXHAUST
DILUTED
EXHAUST
THRU CVS
PUMP
SAMPLE
STREAM TO
GAS COLLEC-
TION BAGS
GAS COLLEC-
TION BAG TO
ANALYZERS
I
h—"
^
YES
PREPARE LIST OF
COMPONENTS FOR
WHICH MORE
INFORMATION IS
NEEDED, OR FOR
WHICH REPLACEMENT
IS RECOMMENDED
OR REQUIRED
I
YES
ARE COMPARATIVE
TEST DATA PRESENTED
TO DEMONSTRATE
EQUIVALENCE, AND
ARE THESE DATA OF
BROAD SCOPE AND
STATISTICALLY
SIGNIFICANT?
ITEMIZE MATERIALS
FOR WHICH REPLACEMENT
IS RECOMMENDED OR
REQUIRED, OR FOR WHICH
MORE INFORMATION IS
NEEDED
YES
Figure 5-9. Checklist for Exhaust Gas Sampling and Analysis System
-------
FLOW SHEET 2012-Cl(ii)
ICI(il) a
CALIBRATION
OF CVS SYSTEM
PROCEDURE cf.
PART 85 APP III
CALIBRATION DATA
cf. SUBPART N
| IDENTICAL |
PROPER FORMAT AND PRESENTATION
MINOR CHANGES,
NOT CONSIDERED
CAPABLE OF
AFFECTING RESULTS
I
MORE EXTENSIVE
CHANGES
SATISFACTORY
EXPLANATION,
INCLUDING SUPPORTING
DATA, THAT
PROCEDURE PERFORMS
SAME FUNCTION?
Ul
I
(Ji
PROCEDURE SIGNIFI-
CANTLY DIFFERENT,
RAISES BASIC QUESTION
AS TO EQUIVALENCE OF
RESULTS
_L
IS OPERATIONAL
PROCEDURE CLEARLY
AND COMPLETELY
DESCRIBED?
£6 DATA POINTS FOR EACH FLOW
RANGE OF CVS PUMP
>.40 mm Hg RANGE OF PUMP INLET
PRESSURES COVERED BY DATA POINTS
ARE COMPARATIVE
TEST DATA PRE-
SENTED TO
DEMONSTRATE
EQUIVALENCE, AND
ARE THESE DATA OF
BROAD SCOPE AND
STATISTICALLY
SIGNIFICANT?
<. 0.5% DEVIATION OF EACH DATA PT. OF
/o vs Xn) AND £ 0.25% DEVIATION OF EACH
•ATA PT. OF (N vs Pp), FROM LEAST SQUARES
BEST FIT LINES THRU ALL DATA POINTS
(V
Dt
YES
IIB>
m
Figure 5-10. Checklist for CVS System Calibration
-------
FLOW SHEET 2012-Cl(iii)
i
PROPANE OR
CO INJECTION
PER APP. Ill
MA]
PROCEDURE cf.
PART 85 APP III
1
t
CRITICAL FLOW
I
DEVICE
DOES APPLICANT PROVIDE
DETAIL SCHEMATIC OF TEST
ARRANGEMENT, AND CLEAR
DESCRIPTION OF OPERATING
PROCEDURE?
t
| OTHER 1
|
DOES APPLICANT PROVIDE CLEAR
DESCRIPTION OF METHOD, AND OF
OPERATIONAL PROCEDURE,
INCLUDING DETAILED SCHEMATICS
OF TEST ARRANGEMENT?
VERIFICATION DATA
cf. PART 85, APP III
I
: ACCURACY S 2%?
ARE FULL CALCULATIONS
GIVEN?
APPLICANT MUST SUPPLY
INFORMATION CONCERNING:
1) DESCRIPTION AND
DIMENSIONS OF SPECIFIC
DEVICE USED (caution:
sharp-edge orifices are not
true critical flow devices)
2) MANUFACTURER AND PART
NO., OR FAB. DWGS. IF
MADE IN-HOUSE
3) CALIBRATION (actual calibration
data or documents examined in
block XD of inspection visit)
ARE COMPARATIVE TEST DATA
PRESENTED TO DEMONSTRATE
EQUIVALENCE TO MASS INJECTION
TECHNIQUE, AND ARE THESE DATA
OF BROAD SCOPE AND
STATISTICALLY SIGNIFICANT?
Figure 5-11. Checklist for CVS System Verification
-------
FLOW SHEET 2012-C2
CHECK EACH ANALYZER
AGAINST EPA APPROVED
LIST
ARE ANY ANALYZERS
NOT ON APPROVED LIST?
HAS ANY ANALYZER BEEN MODIFIED
SIGNIFICANTLY IN SAMPLE TRAIN
SECTION, OR IN ELECTRONICS BY
OTHER THAN THE INSTRUMENT
MANUFACTURER?
EXAMINE CALIBRATION CURVES FOR EACH
ANALYZER REMAINING AFTER C2a AND C2b
YES
I
t—'
-vl
IS EACH CURVE MADE WITH > THE SPECIFIED
NUMBER OF GASES, AND ARE THESE OF
APPROXIMATELY THE SPECIFIED NOMINAL
COMPOSITION?
NO
IS APPLICANT'S IN-HOUSE
DESIGNATION OF ANALYZERS
SIMPLE AND UNAMBIGUOUS?
ARE THE MODIFICATIONS DESCRIBED
CLEARLY AND COMPLETELY?
DOES APPLICANT MAKE A SATISFACTORY
SHOWING THAT THE MODIFICATION IS
NECESSARY, OR DISTINCTLY ADVANTAGEOUS,
FOR FACILITY-SPECIFIC REASONS?
NO
DELETE THOSE ANALYZERS
FROM APPLICANTS INVENTORY
IS THERE AT LEAST ONE
COMPLETE SET OF
APPROVED ANALYZERS
LEFT (HC, NO , CO, C021?
REQUEST APPLICANT TO ADJUST
PROPOSED TEST CELL ARRANGEMENT
IN ACCORDANCE WITH REDUCED
NUMBER OF ANALYZERS
ARE COMPARATIVE DATA PRESENTED TO
DEMONSTRATE EQUIVALENT PERFORMANCE
TO AN UNMODIFIED ANALYZER OF THE
SAME MANUFACTURER AND MODEL NO.,
AND ARE THESE DATA OF BROAD SCOPE
AND STATISTICALLY SIGNIFICANT?
NO
| ALL ANALYZERS |
DEVIATION BETWEEN ANY DATA
PT. AND MATHEMATICAL CURVE
FIT THRU ALL PTS. < ± 2% OF CURVE
VALUE, AND < ± l°/t OF FULL
SCALE VALUE?
DO ANALYZERS COVER PROPER RANGE OF CONCENTRATIONS
FOR SUB-PART RATING AND MODEL YEAR TESTING PLANNED?
ANALYZER RANGE MUST BE
EXPANDED OR CONTRACTED,
IF FEASIBLE, OR THAT
ANALYZER DELETED
DOES APPLICANT PROPOSE USE OF RANGES 2 AND 3
FOR CO MULTI-RANGE ANALYZERS?
LIST THOSE ANALYZERS, FOR
OBSERVATION OF NOISE LEVEL
DURING INSPECTION VISIT
Figure 5-12. Checklist for Gas Analysis Instruments
-------
answered or resolved to evaluate the gas handling system and gas analysis
instruments sections of the application. In each instance shown, the item
being reviewed is evaluated until a numerical grade can be assigned (num-
bers shown in figures correspond to grading system of Figure 5-6).
A suggested approach for accomplishing the application pro-
cessing function is described below.
5. 2. 1. 2. 1 Suggested Application Processing Approach
The purpose of this application processing approach is to
categorize each functional part of the application into one of four classifica-
tions which are given number designations as follows:
1A. Item is quantitatively in accordance with requirements of
40 CFR 85, with no significant judgment factor required.
Next input occurs during inspection visit, Blocks IX and
X of flow sheet 201 (FS201).
1. Judgment item, considered to be satisfactory, with no
further action required until inspection visit.
2. Additional information needed, or changes recommended or
required by EPA. These items to be processed in the
correction loop of Blocks III through VII of FS 201.
3. Item is fundamentally deficient. Rejection of application
is recommended.
The application is divided into several sections for processing,
each section assigned to one reviewer. The latter performs his task in
accordance with a check list based on the task flow sequences contained in
the appropriate 2012-X series flow sheet.
The result of this first stage of processing is the four-way
classification for each item described above. At this stage, the classification
represents the recommendation of the individual reviewer, with the completed
check list for each item to justify that recommendation.
5-18
-------
The second stage of application processing is a critique (actually
a number of separate review sessions) in which each item graded 1 through 3
by every individual reviewer is presented for discussion to at least one other
staff member of the laboratory certification branch. In this stage, a recom-
mendation for application rejection (path 3) may, for example, be softened to
a request for changes or for additional information (path 2); or vice versa.
The second stage decision is final for Block II. Items graded 1A are not
subjected to the second stage processing.
The review continues until every functional item of the applica-
tion has been classified as path 1 or 2, or until an item has been declared
path 3 (denial) at the second stage. In the latter case, all remaining work
on application processing ceases immediately, and the applicant laboratory
is notified that certification has been denied, with the reason for this action.
The laboratory is also informed as to which parts of its application were not
completely processed.
For parts graded as path 2, the correction loop of Blocks III
through VII of FS 201 may be entered while other parts of the application are
still undergoing Block II processing.
Four flow sheets at the third level of expansion for Block 201-11
are provided (Figures 5-9 through 5-12) to indicate the scope of detail involved.
These are designated as FS 2012-C1 (i), -Cl(ii), -Cl(iii), and -C2. In these
flow sheets all of the output paths 1, 2, and 3 are at the first stage of review
and therefore must be subjected to the second stage review before activity on
that item is completed for Block II.
An additional preliminary process is considered advisable.
Due to the large amount of work required for the complete processing of an
initial application, it is worthwhile to initially subject the application to a
brief critical-path scan, to pick out those areas which are most likely to
raise a fundamental question as to whether or not certification is warranted.
This process is shown as FS 2012-2, (Figure 5-7) which indicates these
potentially critical areas. These sections are processed first, including
5-19
-------
the correction loop of Blocks 201 III through VII, if necessary, to determine
if there is a fundamental deficiency in these areas. If this is the case, the
application may be rejected at an early stage. If not, the remainder of the
application is processed as described above.
5.2.1.3 The Inspection Visit
An inspection visit is included in the overall certification pro-
cess (Figure 5-1) to verify that the information contained in the application
is correct and to observe first-hand that the procedures set forth in the
application are being followed satisfactorily. However, there are a number
of activities associated with the inspection visit which must precede it; these
are summarized in Figure 5-13. First, a checklist of items requiring
detailed observation and examination at the specific test laboratory should
be prepared. This checklist should be based on the results of the applica-
tion evaluation and give special attention to any items which were rated as
questionable in view of the specific requirements of 40 CFR 85. Next, the
number, type, and concentration of EPA gas cylinder "unknowns" should be
selected and shipped to the applicant laboratory so that they will arrive prior
to the scheduled date of the inspection visit. If a special test correlation
vehicle is to be used in the inspection process, it should also be shipped at
this time. Finally, the EPA inspection team should be selected and the
inspection visit scheduled and coordinated with the laboratory to ensure that
a complete subpart test will be performed on the date of the visit.
During the inspection visit, the inspection team observes a
complete test of the subpart rating applied for (Block IX of Figure 5-1)
and then splits up to make detailed observations of other tests, calibrations,
procedures, and equipment (Block X of Figure 5-1). Figure 5-14 indicates
the detailed work elements involved in the subpart test observation activity
(Block IX) and Figure 5-15 denotes similar work elements required in the
detailed observations and procedural checks required in the Block X activities.
5-20
-------
TASK BLOCK 201-VIII
FLOW SHEET 2018
FACILITY SPECIFIC INPUTS
FROM BLOCKS 201-11, III—^V
(Si
i
IN)
REQUIREMENTS OF 40CFR
85, SUB-PARTS A AND N
-
-
PREPARE FACILITY SPECIFIC
CHECK-LISTS FOR
INSPECTION VISIT
BLOCK IX
(Observe demonstration
test)
BLOCK X
(Also influenced by
observations of Block IX)
i
1
SELECT NUMBER, TYPE, AND
CONCENTRATION OF EPA GAS
CYLINDERS ("unknowns") TO
BE SHIPPED TO LAB FOR
MEASUREMENT DURING
INSPECTION VISIT
1
r
SHIP EPA GAS CYLINDERS (and
correlation vehicle, if applicable)
TO APPLICANT LAB. MUST
ARRIVE PRIOR TO INSPECTION
VISIT
SELECT EPA INSPECTION TEAM
i
r
SCHEDULE INSPECTION VISIT.
VERIFY THAT A COMPLETE
SUB-PART A TEST WILL BE
PERFORMED (may be correla-
tion vehicle supplied by EPA)
Figure 5-13. Organize and Schedule Inspection Visit
-------
TASK BLOCK 201-IX
FLOW SHEET 2019
BASIC ACTIVITIES COVERED BY BLOCK IX ARE:
85.075-11
-12
-13
-21
85.075-15
-16 THRU -18
-19
-22
-24
-25
VEHICLE PREP AND FUEL
EVAPORATIVE EMISSIONS
EMISSIONS TEST DYNO
DRIVING SCHEDULE
FACILITY-SPECIFIC CHECK-LIST FOR
BLOCK IX ACTIVITIES:
BASIC SUB-PART PROCEDURES AS
ANNOTATED BY INPUTS FROM BLOCKS
201-11, AND III —»-VII
PREPARED AS PART OF BLOCK VIII
I
FACILITY-SPECIFIC INPUTS FROM
APPLICATION PROCESSING BLOCKS
201-11, AND III —»-VII
THESE INPUTS ARE IN THE FORM OF
SPECIFIC ITEMS REQUIRING
ATTENTION OF EPA INSPECTORS
BLOCK IX ACTION
EPA INSPECTORS ARE TO OBSERVE
ALL THE MANIPULATIVE ACTIVITIES
INVOLVED IN THE SUB-PART
PARAGRAPHS SPECIFIED ABOVE
VEHICLE PREP AND FUEL
EVAPORATIVE EMISSION
TECHNIQUES
THE FIRST PART OF THIS CATEGORY
MAY BE PERFORMED ON VEHICLE 'A',
AND THE SECOND PART (after the
10 hour soak at 60 - 86 F) MAY BE
PERFORMED ON VEHICLE 'B'.
DYNO DRIVING SCHEDULE FOR
EMISSIONS TEST
VEHICLE 'B'
VEHICLE 'A'
85.075-12 AN EPA INSPECTOR MUST BE
IN THE VEHICLE DURING THE DRIVING
PREP, OR THRU AT LEAST ONE
COMPLETE CYCLE, IF A CYCLICLE
ROUTE IS USED
85.075-11
-21 THRU |e)(3)
85.075-15
-19
-24; -20 |b)(3) THRU (5)
-16 THRU -18 (as applicable]
-22
-25
DURING THE DYNO DRIVING TEST,
AN EPA INSPECTOR MUST BE IN A
POSITION TO OBSERVE THE DRIVING
TRACE. AND THE MANIPULATIONS
OF THE DRIVER
VEHICLE 'B'
85.075-13 (after 10 hour soak)
85.075-21 (e) (4) THRU (6]
Figure 5- 14.
Block IX Work Element Details — Observe Complete
Test of Subpart Rating Applied For
-------
TASK BLOCK 201-X
FLOW SHEET 20110-1
FACILITY-SPECIFIC INPUTS FROM APPLICATION
PROCESSING BLOCKS 201 -II, AND III —" VII
THESE INPUTS ARE IN THE FORM OF SPECIFIC
ITEMS REQUIRING ATTENTION OF EPA INSPECTORS
BLOCK X
MUST COMPLETE EVALUATION OF
COMPLIANCE WITH ALL APPLICABLE
REQUIREMENTS OF SUB-PARTS A AND N
INPUTS FROM OBSERVATIONS OF
DEMONSTRATION TEST (Block IX).
MAY REQUIRE CLARIFICATION,
SUPPORTING DATA, DEMONSTRATION
OF PROCEDURES, ETC.
4 I
FUELS HANDLING
VEHICLE PREP
BLOCK X ACTION
FACILITY-SPECIFIC CHECK LIST OF DETAILED
OBSERVATION, TESTING, OR CALIBRATION OF
SPECIFIC PROCEDURES AND EQUIPMENT, ALSO
COVERS REQUIRED EXAMINATION OF DATA
AND RECORDS
1
GAS HANDLING SYSTEM
1 ||
........ AUXILIARY GENERAL
DYNOS EQUIPMENT FACILITY
(Jl
INJ
IDENTIFY DELIVERY
AND STORAGE UNITS
(as applicable). TRACE
PLUMBING FROM
DELIVERY UNIT TO FUEL
DISPENSING POINT IN LAB
CHECK LOCATIONS AND
TYPES OF TEMPERATURE
SENSORS IN SOAK AND
TEST AREAS, AND
HUMIDITY AND PRESSURE
SENSORS IN TEST AREA
EACH UNIT MUST BE EXAMINED BY EPA, BUT THE OPERATIONS
DESCRIBED BELOW MAY BE PERFORMED ON ONLY ONE UNIT,
UNLESS DIFFERENT PROCEDURES IN USE IN OTHER TEST CELLS.
THESE OPERATIONS ARE PERFORMED BY LABORATORY PERSONNEL
AND OBSERVED BY EPA INSPECTORS.
INSPECT FACILITY,
PROCEDURE, AND
RECORDS USED TO
PERFORM OR
DOCUMENT
CALIBRATIONS OF:
CHECK FOR
ADEQUATE SPACE
AND SECURITY
FOR PR E- AND
POST-TEST
VEHICLES
INSPECT TEMPERATURE
AND VENTING CONTROLS
FOR EACH STORAGE
CONDITION
EXAMINE RECORDS
OF FUEL ANALYSES.
CHECK FOR TYPE
AND FREQUENCY
OF ANALYSES
DETERMINE ACCURACY
AND RESPONSE OF
RECORDERS (from
manufacturers specs) FOR
ABOVE SENSORS. CHECK
FOR COMPLIANCE WITH
SUB-PART N
EXAMINE RECORDS
OF ABOVE SENSORS,
CHECK FOR
COMPLIANCE WITH
SUB-PART N
FOLLOW-UP ON ANY
ACTION ITEM FROM
OBSERVATIONS
OF BLOCK IX
SAMPLING
SYSTEM
CVS PUMP
CALIBRATION
CVS
VERIFICATION
COMPARE
PLUMBING
WITH
SCHEMATIC
OF APPLICATION;
OTHER
REQUIREMENTS
OF B5.075-20{b)
PERFORM FULL
CALIBRATION
FOR ONE RANGE
OF CVS PUMP,
INCLUDING
REDUCTION AND
PLOTTING OF
DATA
PERFORM
VERIFICATION
OF CVS UNIT,
WITH COMPLETE
DATA REDUCTION
1
PERFORM
DAILY LEAK
CHECK
VERIFY NBS-
TRACEABLE
CALIBRATION
OF EACH
LAMINAR FLOW
ELEMENT (or
other type of ftow
measuring device
in use)
PERFORM DYNO
CALIBRATION,
COMPRISING:
TORQUE READOUT
ROLL SPEED
DYNO FRICTION
INCLUDING DATA
REDUCTION AND PLOTTING
EXAMINE CALIBRATION
DATA AND RECORDS
FOR EACH DYNO
a) ELECTRONIC
READ-OUT
INSTRUMENTS
b) RECORDERS
cl PRESSURE GAGES
d) TEMPERATURE
PROBES
ANY OTHER
MEASURING
EQUIPMENT
WHOSE
PERFORMANCE
IS IMPORTANT
IN CERTIFIED
TESTING
IS OVERALL
FACILITY LAYOUT
CONDUCIVE TO
SAFE, ACCURATE
AND EFFICIENT
EMISSIONS
TESTING?
Figure 5-15. Block X Work Element Details — Inspection Visit
-------
TASK BLOCK 201-X
FLOW SHEET 20110-2
I
N)
GAS ANALYSIS INSTRUMENTS
GENERAL PROCEDURES:
THESE OPERATIONS ARE PERFORMED BY
LABORATORY PERSONNEL AND OBSERVED
BY EPA INSPECTORS. THE OPERATIONS
DESCRIBED BELOW MAY BE REQUIRED ON
ADDITIONAL ANALYZERS OR ANALYTICAL
SYSTEMS, IF IT APPEARS THAT SIGNIFICANT
DIFFERENCES MAY BE INVOLVED IN
DIFFERENT TEST CELLS
INSTRUMENT SPECIFIC ITEMS: THESE
ACTIVITIES MUST BE PERFORMED
FOR EACH ANALYZER OF THE CLASS
AND TYPE SPECIFIED
MEASUREMENT OF
EPA GAS CYLINDERS
("unknowns")
DATA LINK
HC ANALYZERS
NO, ANALYZERS
CO ANALYZERS
ANALYZER OPERATIONS:
THE FOLLOWING ACTIVITIES
AT LEAST ONE ANALYZER
OF EACH CLASS (HC, NO,,
CO, C02) x
ANALYTICAL 1
SYSTEM |
1
COMPARE PLUMBING
WITH SCHEMATIC OF
APPLICATION
PERFORM ZERO AND SPAN
IN ACCORDANCE WITH DAILY
PROCEDURE (may be
accomplished in Block IX)
DEMONSTRATE CALIBRATION
PROCEDURE. PERFORM >2
POINTS. AS REQUESTED BY
EPA INSPECTOR
EXAMINE DATA AND
RECORDS TO VERIFY
IF THE FOLLOWING
OPERATIONS HAVE
BEEN SATISFACTOR-
ILY PERFORMED:
, 1
OPTIMIZE BURNER
IF ATMOSPHERIC
PRESSURE REACTOR
IS USED IN ANY ANA-
LYZERS, EXAMINE
DATA AND RECORDS
TO VERIFY IF EACH
INSTRUMENT RE-
SPONSE TO CO2 AND
H20 HAS BEEN MEA-
SURED AND IS SAT-
ISFACTORY
IF APPLICANT
PROPOSES USE OF
RANGE 2 OR 3 OF
MULTI-RANGE
INSTRUMENTS, OB-
SERVE NOISE
LEVEL ON EACH
SUCH PROPOSED
RANGE
1
DEMONSTRATE
PROCEDURE FOR
NAMING GASES
ON AT LEAST ONE
ANALYZER
(preferably CO)
PRESSURES
, 1
MEASUREMENT OF
02 RESPONSE
J _,
DEMONSTRATE NO**-
NO CONVERTER
EFFICIENCY TEST
(1 Range)
DEMONSTRATE
ANALYZER RES-
PONSE TO C02
AND H20 VAPOR
PER 85.075-20 (c)
CD
NUMBER, TYPE, AND
CONCENTRATION
DETERMINED IN
BLOCKS 201 -II, AND III
—" VII. CYLINDERS
SHIPPED TO LAB PRIOR
TO INSPECTION VISIT
OBSERVE
CALIBRATION
OR VERIFICATION,
AS APPLICABLE
MEASUREMENTS
PERFORMED BY
LABORATORY
PERSONNEL OB-
SERVED BY EPA
INSPECTOR
PERFORM
MEASUREMENT
OF APPROPRIATE
CYLINDERS ON
EACH ANALYZER
PROPOSED FOR
USE IN CERTIFIED
TESTING
DEMONSTRATE OPERATION
OF ANALYZER IN TEST
MODE, WITH ALL SAMPLING
EQUIPMENT IN OPERATION,
FLOWING SAMPLE FROM
COLLECTION BAG.
CONCENTRATION OF SAMPLE
NEED NOT BE KNOWN, (may
be accomplished in Block IX)
PERFORM DAILY
LEAK CHECK
Figure 5-15. Block X Work Element Details — Inspection Visit (Continued)
-------
As can be noted in Figure 5-14 and 5-15, the elements of work
to be performed by the EPA inspection staff are extensive in number and
detailed and specific in content. Such observations and checks are essential
to ensure that the laboratory is in compliance with the procedural and equip-
ment requirements of 40 CFR 85.
5.2.1.4 Final EPA Review
After the inspection visit, the results of the inspection are
submitted to a final EPA staff review. These inspection visit results consist
of a completed check list evaluation, which provides a paragraph-for-
paragraph comparison of all applicable sections of 40 CFR 85. Each check
list item has been graded by the inspection team. Figure 5-16 graphically
depicts the final EPA review activity, and illustrates the various steps lead-
ing to issuance or denial of certification.
5.3 LABORATORY QUALITY CONTROL
The work flow sequence analysis for laboratory quality control
was performed in a manner similar to that delineated above for the laboratory
certification process (Section 5.2). The flow sheets developed in the analysis
are summarized in Table 5-2 and described below.
5. 3. 1 Periodic Scheduled Inspections
Figure 5-17 describes the overall process of a scheduled
inspection at 6-month intervals in flow sheet format. It is quite similar to
the initial inspection made for initial certification purposes (Figures 5-14
and 5-15) but is less extensive in nature. Major emphasis during the
scheduled inspection is placed on (a) determining if the key calibration and
test procedures are the same as those observed in detail during the initial
or renewal inspection visit (and upon which certification approval was based),
and (b) ensuring that the calibration schedules for key equipment are in
compliance with 40 CFR 85 requirements. Figures 5-18 and 5-19 denote
the key operations which should be carried out in this regard during the
scheduled inspection.
5-25
-------
TASK BLOCK 201-XI
FLOW SHEET 201 11
INPUTS FROM INSPECTION VISIT
THIS CONSISTS OF THE COMPLETED CHECK LIST EVALUATION, WHICH PROVIDES A
PARAGRAPH-FOR-PARAGRAPH COMPARISON OF ALL APPLICABLE SECTIONS OF
40CFR 85, SUB-PARTS A AND N, vs. THE CORRESPONDING PROCEDURE OR PRAC-
TICE OF THE APPLICANT LABORATORY. THE INSPECTION TEAM GRADES EACH
CHECK LIST ITEM AS I, 2, OR 3
I. SATISFACTORY
2. CAPABLE OF MEETING CERTIFICATION STANDARDS
WITH RELATIVELY STRAIGHTFORWARD CHANGES
3. SIGNIFICANT DISCREPANCY. RECOMMEND DENIAL
OF CERTIFICATION
FINAL EPA STAFF REVIEW
IF ONE OR MORE
ITEMS GRADED 2,
RE-ENTER BLOCK
III (FS20I3)
Figure 5-16. Final EPA Review
-------
Table 5-2. Flow Sheet Breakdown — Laboratory Quality Control
FLOW SHEET NO.
• PERIODIC SCHEDULED INSPECTIONS 202
/ SECOND LEVEL EXPANSION OF KEY BLOCKS
INSPECT CALIBRATION AND TEST PROCEDURES 2024
EXAMINE DATA AND RECORDS 2025
f • UNANNOUNCED INSPECTIONS 203
ts)
^ / SECOND LEVEL EXPANSION OF BLOCK IV SIMILAR TO
2025 ABOVE, EXCEPT THAT EMPHASIS IS ON EXAMINING
CALIBRATION SCHEDULE (LESS EMPHASIS ON
EXAMINING PROCEDURES)
• ONGOING QUALITY CONTROL PROCESS 204
• SUMMARY OF CERTIFICATION CONTROL MECHANISMS 206
-------
FLOW SHEET 202
II
CO-ORDINATE WITH
LAB TO INSURE
THAT SPECIFIED
TESTS WILL BE IN
PROGRESS
I
DO
00
OBSERVE COMPLETE
TEST OF TYPE FOR
WHICH RATING IS
HELD
THIS TEST MAY BE
PERFORMED ON
CORRELATION
VEHICLE SUPPLIED
FOR THE OCCASION
VII
RECOMMENDATIONS
BY INSPECTION
TEAM
DYNOS
GAS ANALYSIS
INSTRUMENTS
CALIBRATION AND
MAINTENANCE
ACTIVITY, AND
COMPONENT
REPLACEMENT
Figure 5-17. Periodic Inspection — Scheduled Inspection at 6-Month Intervals
-------
TASK BLOCK 202-IV
FLOW SHEET 2024
THE PURPOSE OF THIS BLOCK IS TO DETERMINE IF KEY
CALIBRATION AND TEST PROCEDURES ARE THE SAME AS
THOSE OBSERVED IN DETAIL DURING THE INITIAL OR
RENEWAL INSPECTION VISIT (FS 201), AND UPON WHICH
CERTIFICATION WAS BASED
IT IS NOT NECESSARY THAT THE ACTUAL CALIBRATION OR TEST ACTIVITY BE
PERFORMED (except as noted below). RATHER IT IS REQUIRED OF THE EPA
INSPECTOR TO ASCERTAIN THE PROCEDURES AND EQUIPMENT USED. THIS
MAY BE ACCOMPLISHED IN MANY CASES BY QUESTIONING LAB PERSONNEL
AND EXAMINING TEST SET-UPS AND EQUIPMENT. THE INSPECTOR MUST
OBTAIN SUFFICIENT VERIFICATION AS TO LEAVE NO DOUBT AS TO THE
EXPERIMENTAL DETAILS. IF NECESSARY, THE LAB MAY BE REQUESTED
TO PERFORM ALL OR PART OF THE PROCEDURE.
IF ANY ITEM OF IDENTIFIED EQUIPMENT USES A CALIBRATION (or verification)
PROCEDURE DIFFERENT FROM ANY PROCEDURE DEMONSTRATED BY THE LAB
DURING THE MOST RECENT FS-201 INSPECTION, THE EPA INSPECTOR MUST
REQUEST THE LAB TO PERFORM ALL OR PART OF THE EXPERIMENTAL
PROCEDURE AND DATA REDUCTION.
OPERATIONS COVERED BY THIS BLOCK ARE:
CVS SYSTEM :
I
C\J
xO
DYNO
CALIBRATION
GAS ANALYSIS
INSTRUMENTS
LEAK CHECK
TORQUE READOUT
THE FOLLOWING ITEMS MUST BE
OBSERVED DIRECTLY BY EPA INSPECTOR
CVS PUMP
CALIBRATION
ROLL SPEED
CVS SYSTEM
VERIFICATION
DYNO FRICTION
LOSSES
IF LAB IS USING RANGE 2 OR 3
OF MULTI-RANGE CO ANALYZERS
FOR CERTIFICATION TESTS, OBSERVE
NOISE LEVEL ON THESE RANGES
GENERAL PROCEDURES:
ALL OR PART OF THESE
REQUIREMENTS MAY BE
ACCOMPLISHED DURING
THE DEMONSTRATION
VEHICLE TEST (Block 202-11)
CALIBRATION OR VERIFICATION
OF DATA LINK, AS APPLICABLE
LEAK CHECK; ZERO AND SPAN
TEST MODE OPERATION
CALIBRATION
Figure 5-18. Scheduled Inspection — Inspect Calibration
and Test Procedures
-------
TASK BLOCK 202-V
FLOW SHEET 2025
THE FUNCTION OF THIS BLOCK IS TO INSURE
THAT CALIBRATION SCHEDULES FOR KEY
EQUIPMENT ARE MAINTAINED IN ACCORDANCE
WITH 40 CFR 85, SUBPARTS A AND N.
THESE RECORDS ARE EXAMINED FOR EACH
EQUIPMENT ITEM IN THE FOLLOWING
CATEGORIES WHICH IS USED IN CERTIFIED
TESTS. ALL RECORDS ACCUMULATED SINCE
THE LAST EPA INSPECTION VISIT ARE EXAMINED
GAS ANALYSIS INSTRUMENTS
CVS EQUIPMENT
U1
W
O
I I
* * * * 1
[CALIBRATION 1 LOG OF [CALIBRATION] VERIFICATION) LOG OF
1 MAINTENANCE 1 1 MAINTENANCE
4
SCHEDULE
4
<30 DAYS AND
4
AFTER
MAINTENANCE
WHICH COULD
AFFECT
CALIBRATION
AND
4
AS MAY BE
INDICATED
BY ANOMALIES
IN DAILY
RECORD OF
INSTRUMENT
PARAMETERS
(gain, tune, etc.)
OR BY OTHER
OPERATOR
OBSERVATIONS
|
NO, ANALYZER
CONVERTER
VERIFICATION
SCHEDULE:
DAILY-TO-
WEEKLY
*
DATA LINK:
APPROPRIATE
TO FACILITY, AS
ESTABLISHED IN
MOST RECENT
FS201
INSPECTION VISIT
DATA
4
SCAN FOR
PRECISION OF
CURVE FIT vs
REQUIREMENT
OF 85.130-4(1]
4
SCAN NO,
ANALYZER
CONVERTER
EFFICIENCY
CHECKS vs
REQUIRE-
MENTS OF
85.075-23(a)
6 AND 85. 1320-
4(g)
I
SCAN DATA
LINK
CALIBRATION
OR
VERIFICATIONS
T «-lJFr>MI F
COMPONENT 4
ANDS1000
HOURS AND
4
AFTER
MAINTENANCE
WHICH COULD
AFFECT
CALIBRATION
AND
4
AS MAY BE
INDICATED BY
VERIFICATION
DATA, OR BY
OTHER
OPERATOR
OBSERVATIONS
4 T T COMPONENT
PRECISION OF AND<10 COMPLIANCE
CURVE FIT HOURS WITH
AND OTHFR APPENDIX III
Figure 5-19. Scheduled Inspection — Examine Data and Records
-------
5. 3. Z Unannounced Inspections
Figure 5-ZO denotes the principal work elements to be performed
during unannounced quality control inspections. The level of activity is much
less extensive than the 6-month scheduled inspection. It is principally con-
cerned with checking for certified personnel and examination of records to
verify calibration frequency and major equipment and instrument maintenance
activity. However, the EPA inspectors may request the demonstration of
equipment, operations, calibrations, etc. , which in their judgment may be
necessary.
5. 3. 3 On-Going Quality Control Process
Figure 5-21 denotes in flow sheet format all the major elements
of the quality control program and their interrelationships. They include:
a. Scheduled periodic inspections
b. Random unannounced inspections
c. Quarterly measurements of EPA gas cylinder "unknowns" by
the laboratory
d. The naming by EPA of the laboratory's calibration gases
e. The transmittal to EPA of a complete set of data, for each
certified test performed by the laboratory
f. The transmittal to EPA of any change of status of equipment,
personnel, procedures, etc.
Any discrepancies discovered by EPA in any element of the quality control
process can be the basis for:
a. Suspension of certification
b. The requirement for changes in the laboratory equipment
or operations, procedures, etc.
c. An additional unannounced inspection for further surveil-
lance of the laboratory.
5-31
-------
FLOW SHEET 203
:HEDULE
FUN-
lANNOUNCE:
WISIT
(Jl
I
oo
CHECK FOR
CERTIFIED
PERSONNEL
EPA MAY REQUEST
DEMONSTRATION OF
EQUIPMENT
OPERATION,
CALIBRATION,
OR MAINTENANCE
VI
RECOMMENDATIONS
BY EPA INSPECTOR
'REVIEW
AND AC-
TION BY
LAB CERT.j
.BRANCH
Figure 5-20. Unannounced Inspection — Random, Average Two per Year
-------
FLOW SHEET 204
PERIODIC INSPECTION
(scheduled,
semi-annual)
UN-ANNOUNCED
INSPECTION
[random]
QUARTERLY
MEASUREMENT
OF EPA GAS
CYLINDERS
("unknowns")
NAMING OF LAB'S
CALIBRATION GASES
ON EPA EQUIPMENT
STATUS CHANGE TRANSMITTAL
FROM LAB: EQUIPMENT,
PERSONNEL. PROCEDURES.
REQUEST FOR AND/OR
NOTICE OF CHANGE
/ SI ISC
/
FND\
1
V
REVIEW BY EPA
LAB CERTIFICA-
TION BRANCH
A
i
oo
1 REASONS]
I
I APPEAL I.
| SUSPENSION I*
I J
[CORRECTIVE '
1 ACTION BY I
I LAB I
REQUIRED CHANGES,
OR CLARIFICATION
OF DISCREPANCY
AT EPA OPTION, MAY
MAKE UN-ANNOUNCED
INSPECTION, OR SPECIAL
VISIT, OR AWAIT NEXT
SCHEDULED VISIT AS
APPROPRIATE
CORRECTIVE
ACTION NOT
COMPLETE
APPRAISAL
BY EPA
-OH
NOTE:
1) ONE RE-INSTATEMENT
REQUEST PERMITTED FOR
EACH SUSPENSION NOTICE
2) A SUSPENSION WHICH IS NOT
REMOVED WITHIN 6 MONTHS
RESULTS IN REVOKING
CERTIFICATION
3) IN THIS CASE, CERTIFICATION
CAN BE ATTAINED AGAIN ONLY
BY MAKING A NEW INITIAL
APPLICATION (flow sheet 201)
AFTER A SPECIFIED DELAY
Figure 5-21. Laboratory Certification — On-Going Quality Control Process
-------
In the event of certification suspension, the various actions required for
reinstatement of certification are indicated in the figure.
Figure 5-22 summarizes all the certification control mechan-
isms, including the initial (and renewal) inspection as well as the periodic
and unannounced inspections discussed above. As noted, overall certification
control over the laboratory has an adequately extensive basis, including EPA
inspection visits, information transfer from the laboratory to EPA, and two
different cross-checks on gas analysis instrumentation accuracy.
5.4 OPERATOR CERTIFICATION
As in the case of laboratory certification, the functional task
areas selected in Section 4 for operator certification were expanded through
two levels of detail in the work flow sequence analysis activity. The resulting
flow sheets developed are shown in Table 5-3 and identified as to number.
These flow sheets are described below.
5. 4. 1 Initial and Renewal Certification
Figure 5-23 illustrates the overall operator certification pro-
cess in flow sheet format. The EPA task assignments are principally related
to preparing, scheduling, administering, and grading both written and
practical examinations. Although the flow process indicated contemplates
that the employer of the applicant request that the operator be certified and
verify that the applicant has the requisite job experience, an alternate appli-
cation path is included. This may be necessary to accommodate applicants
who are as yet unemployed or who are desirous of changing employers. The
alternate path contemplated is for the applicant to apply directly to EPA for
both written and practical examinations to be administered at the EPA Ann
Arbor facilities.
Figure 5-24 lists the major work elements involved with
examinations, record retention, and examiner scheduling. With regard to
preparation of written examinations, it is recommended (for a long-term
5-34
-------
CERTIFICATION CONTROL OVER A LABORATORY IS BASED ON INSPECTION VISITS,
INFORMATION TRANSFER, AND CROSS-CHECKS OF GAS ANALYSIS INSTRUMENTATION
INITIAL AND RENEWAL INSPECTION
(see flowsheet 201]
I I INSPECTION VISITS
PERIODIC INSPECTION
(see flowsheet 202)
RANDOM, UN-ANNOUNCED VISIT
(see flowsheet 203)
EVERY 2 YEARS
SEMI-ANNUAL, SCHEDULED VISIT
AVERAGE 2 PER YEAR
THESE ARE VERY DETAILED INSPECTIONS
WHICH WILL PROBABLY REQUIRE A 2-3 DAY
VISIT BY A 3 MEMBER INSPECTION TEAM
I
Oo
COVERS DETAILS OF PROCEDURES USED FOR
OPERATION, MAINTENANCE, AND CALIBRATION
OF ALL KEY INSTRUMENTS AND EQUIPMENT
IT IS SIMILAR TO THE FAA "SWAP" INSPECTION
IN ITS LEVEL OF DETAIL, BUT DIFFERS IN THAT
IT IS THE OFFICIAL INSPECTION WHICH DETERMINES
WHETHER OR NOT CERTIFICATION WILL BE
RENEWED FOR 2 YEARS
THE RENEWAL INSPECTION IS SIMILAR TO THAT
FOR INITIAL APPLICATION. THIS IS DONE TO FORCE
AN IN-DEPTH APPRAISAL OF EQUIPMENT,
PROCEDURAL, PERSONNEL, AND FACILITY CHANGES
THIS INSPECTION IS THE MAIN ASPECT OF ON-GOING
QUALITY CONTROL DURING THE 2 YEARS BETWEEN
RENEWAL INSPECTIONS. IT IS LESS DETAILED THAN
THE LATTER, AND WILL PROBABLY REQUIRE
A 2-3 DAY VISIT BY A 2 MAN INSPECTION TEAM
ITS FUNCTIONS ARE 4-FOLD:
(a) PERIODIC EXAMINATION OF RECORDS OF EQUIPMENT
CALIBRATION AND MAINTENANCE
(b) PERIODIC OVERVIEW OF LAB'S PROCEDURE DURING
A COMPLETE TEST OF TYPE FOR WHICH
CERTIFICATION IS HELD
(c) PERIODIC INSPECTION OF CALIBRATION
PROCEDURES FOR KEY EQUIPMENT
(d) ADVISE LAB WITH RESPECT TO PROBLEM AREAS
WHICH MIGHT ARISE CONCERNING ANALYSIS
DISCREPANCY, ETC.
THIS IS THE LEAST DETAILED INSPECTION,
PROBABLY REQUIRING 1 DAY FOR 1-2
INSPECTORS
ITS PURPOSE IS 3-FOLD:
(a) VERIFY THAT PROPER CALIBRATION AND
MAINTENANCE SCHEDULES ARE BEING
FOLLOWED FOR KEY EQUIPMENT
(b) OBSERVE GENERAL STATE OF EQUIPMENT AND
PERSONNEL READINESS, AND OVERALL STATUS
OF FACILITY
(c) INVESTIGATE A SPECIFIC CONDITION WHICH EPA
DECIDES SHOULD NOT BE LEFT UNTIL THE
NEXT PERIODIC INSPECTION
THESE VISITS SHOULD PREFERABLY BE INTEGRATED
WITH THE OTHER TWO TO PROVIDE, ON THE
AVERAGE, QUARTERLY CONTACT WITH LAB
EPA INSPECTION STAFF SHOULD BE OF A SIZE TO PERMIT ROTATION OF INSPECTION DUTIES.
PREFERABLY, NO INSPECTOR SHOULD PARTICIPATE IN TWO CONSECUTIVE VISITS TO A GIVEN
FACILITY. IT IS PARTICULARLY IMPORTANT THAT THE SAME TEAM SHOULD NOT GIVE THE
RENEWAL INSPECTION TWICE IN SUCCESSION TO A GIVEN LAB
INFORMATION TRANSFER
III GAS ANALYSIS CROSS-CHECKS
LAB MUST SUBMIT COMPLETE DATA (raw and reduced) FOR EACH CERTIFIED
TEST. MAIL WITHIN 2 BUSINESS DAYS OF COMPLETION OF TEST
A. ON QUARTERLY BASIS, EPA SENDS GAS CYLINDER STANDARDS ("unknowns")
TO LAB FOR MEASUREMENT ON ITS EQUIPMENT
B. LAB SENDS SOME OF ITS SPAN AND CALIBRATION GAS CYLINDERS TO EPA, FOR
NAMING ON LATTER'S EQUIPMENT. THIS IS NORMALLY DONE AT OPTION OF
LAB, BUT MAY BE REQUESTED BY EPA IN CASE OF ANALYSIS DISCREPANCY.
Figure 5-22. Summary of Certification Control Mechanisms
-------
Table 5-3. Operator Certification-Work Flow Sequence Analysis
FLOW SHEET NO.
FIRST LEVEL OF EXPANSION
/ OPERATOR CERTIFICATION BASIC WORK AREAS 101
SECOND LEVEL OF EXPANSION
/ PRINCIPAL WORK ELEMENTS IDENTIFIED FOR
BASIC WORK AREAS
- WRITTEN EXAMS 1011-1
- PRACTICAL TEST 1011-2
RECORD RETENTION 1011-2
EXAMINER SCHEDULING 1011-2
-------
FLOW SHEET 101
I EPA REGULATIONS
II BASIC EMISSIONS
MEASUREMENT
III FACILITY SPECIFIC
PROCEDURES
NOTIFY
APPLICANT:
a) FAILURE OF
ANY PART
b| CATEGORIZE
INCORRECT
ANSWERS AND
DEFICIENT
PROCEDURES
1ST RE-TEST
VALID 24
CALENDAR
MONTHS
NOTIFY
APPLICANT
2ND OR MORE
RE-TESTS
AN ALTERNATIVE PATH IS FOR THE APPLICANT
TO APPLY DIRECTLY TO EPA, FOR EXAMINATION
AT EPA ANN ARBOR FACILITIES-
IN THIS CASE, ALL BLOCKS OF THIS FLOW SHEET
WHICH REFER TO "EMPLOYER" ACTIONS, MUST
BE PERFORMED BY APPLICANT. ALL OTHER
PARTS OF FLOW SHEET ARE UNCHANGED.
APPLICANT IS RESPONSIBLE FOR PERSONAL COSTS.
Figure 5-23. EPA Operator Certification — Initial and Renewal
-------
TASK BLOCK 1011-1
UJ
oo
| WRITTEN "EXAM |
1
| PREPARATION |
|
REQUIREMENT:
1) APPLICANT TAKING RE-TEST
OF FAILED PORTION DOES NOT
GET SAME EXAM AGAIN
21 APPLICANT TAKING RENEWAL
TEST DOES NOT GET SAME
EXAM TAKEN 2 YEARS BEFORE
1
RECOMMENDED APPROACH
(LONG TERM)
[ ADMINISTERING EXAMSj
AT FACILITY OF APPLICANT'S
EMPLOYER
1
[ GRADING J
T
RECOMMEND FIXED PASS-
ING GRADE FOR ALL EXAMS
1
EXAMS SHOULD BE ADMINIS-
TERED IN SEPARATE ROOM
WHICH MINIMIZES DISTURB-
ANCE AND NOISE LEVEL.
PREFERABLY, NO ONE EX-
CEPT EXAMINEES AND EPA
EXAMINER SHOULD ENTER
ROOM WHILE EXAMINA-
TIONS ARE IN PROGRESS
1
1) EPA MAINTAIN BANK OF AP-
PROVED EXAM QUESTIONS,
NUMBERED AND CATALOGED
AS TO:
a) SUB-PART RATING OF
PART 85
b) TEST PORTION, i.e.:
1 EPA REGULATIONS
II BASIC EMISSION
MEASUREMENT
A. FUELS
B. VEHICLE PREP
C. GAS ANALYSIS
INSTRUMENTS
D. GAS SAMPLE
HANDLING
E. DYNAMOMETERS
III FACILITY SPECIFIC
EMISSION TESTING
1
2) EXAM NUMBERING AND IN-
DEXING SYSTEM WHICH
IDENTIFIES EACH QUESTION
USED IN EACH EXAM
1
FOR INITIAL 2 YEAR PERIOD,
CAN USE FIXED SET OF EXAMS.
THESE SHOULD INCLUDE SEP-
ARATE PARTS FOR POSSIBLE
RE-TESTS
EPA EXAMINER SHOULD
BE IN EXAM ROOM AT ALL
TIMES THAT EXAMINATIONS
ARE IN PROGRESS. THIS
SHOULD NOT BE DELEGATED
TO SECRETARY OR OTHER
EMPLOYEES OF THE LAB
RECOMMEND COMPART-
MENTED TEST (SECTIONS
1, II, III OF COLUMN 1)
WHICH ARE GRADED
SEPARATELY. APPLI-
CANT FAILING ANY PART
NEED RE-TAKE ONLY
THE FAILED PART.
1
CATEGORIZE INCORRECT
ANSWERS FOR EACH TEST,
TO INDICATE AREAS FOR
APPLICANT STUDY
1
NOTIFY APPLICANT BY
MAIL, AT HOME ADDRESS,
OF OVERALL SCORE, ANY
SECTIONS FAILED
1
ALL TEST RESULTS
HANDLED IN ONE MAILING
Figure 5-24. EPA Task Assignment for Operator Certification
-------
TASK BLOCK 1011-2
| PRACTICAL TEST ]
I
ADMINISTERED AT FACILITY
OF APPLICANT'S EMPLOYER
SPECIFY CONTENT OF EXAM
PREPARE CHECKLIST FOR-
MAT TO BE USED BY EPA
EXAMINER TO INDICATE
APPLICANT'S PERFORMANCE
EPA EXAMINER ADMINISTER
TEST TO ONLY 1 APPLICANT
AT A TIME
REVIEW BY EPA PANEL
OF TEST FOR EACH
APPLICANT
NOTIFY APPLICANT BY MAIL
IF TEST FAILED, STATING
PORTIONS FAILED
RECORD RETENTION
FOR EACH APPLICANT TESTED,
MAINTAIN A FILE CONSISTING OF:
SERIAL NO. OF EXAMS TAKEN,
GRADE ON EACH SECTION;
INDICATE AREAS DEFICIENT,
DATE OF EXAM
SCORE OR RATING ON PRACTICAL
TEST: INDICATE AREAS DEFICIENT,
DATE OF TEST
RATINGS ISSUED, DATE OF ISSUE
ABOVE INFORMATION RETAINED
UNTIL RATING RENEWED, OR FOR
3 YEARS. UPON RENEWAL. START
IDENTICAL NEW FILE. OLD FILE
MAY BE DESTROYED
RETAIN 10 YEAR FILE OF NAMES
OF CERTIFIED OPERATORS (BY
SOCIAL SECURITY NO.], RATINGS
HELD, DATES ISSUED OR RENEWED
EXAMINER SCHEDULING!
MAN-HOURS OF EPA EXAMINER
TIME AT APPLICANT'S FACILITY:
4 MAN-HOURS FOR ALL WRITTEN
TESTS (RE-TESTS MAY BE SHORTER)
4 MAN-HOURS FOR EACH APPLICANT
FOR PRACTICAL TEST (RE-TESTS
MAY BE SHORTER)
Figure 5-24. EPA Task Assignment for Operator Certification (Continued)
-------
approach) that EPA maintain a bank of numbered and catalogued examination
questions to avoid the situation where applicants would be given the same
test upon certification renewal (or re-testing after failing an examination).
This would entail the retention, in the applicant's records (as noted in Fig-
ure 5-Z4), of the serial number of examinations taken.
With regard to the man-hours estimates for written and practi-
cal examinations, the 4-hour estimates shown in Figure 5-24 were developed
by Olson Laboratories, Inc. , under separate contract to EPA/DECT.
5.4. Z On-Going Quality Control
As noted in Section 4. Z. Z, the on-going quality control of the
operator is accomplished in conjunction with laboratory quality control.
First, the operator is required to verify (by signature) that the certified test
data submitted to EPA by the laboratory has been performed under his sur-
veillance and control. This permits EPA to screen the submitted test data
for compliance with procedures. Second, the operator can be required to
participate in or perform any tests, calibrations, or other checks requested
by EPA inspectors at times of laboratory inspections (scheduled or unan-
nounced). This permits direct observation of the operator's performance
and techniques.
5-40
-------
-------
6. MANAGEMENT ORGANIZATIONAL STRUCTURE
6.1 INTRODUCTION
This section develops the elements of personnel staffing,
operational schedules, program costs, and management structure for the
basic laboratory and operator certification processes described in Sections 4
and 5. It thus completes the definition of the proposed certification program.
The processes and rationale used in this development are described, and the
impact of each item on the overall functioning of the certification program
is emphasized.
The topics are developed in sequence from the information
contained in the preceding sections. Personnel requirements are addressed
first. A baseline group of laboratories is established to which the analysis is
directed. The •work elements defined in Section 5 are then quantified in gen-
eral terms of man-units of effort. This information is processed into the
requisite number of EPA staff positions. This then permits an activity sched-
ule to be generated and the program operating costs to be determined.
Organization and management structure considerations are
then presented, followed by a discussion of some special topics and compari-
sons relevant to program implementation.
6.2 GENERALIZED PERSONNEL REQUIREMENTS
The basic EPA staff position which is required for the pro-
posed laboratory certification program is termed "Inspector" in this report.
This position involves participation in all aspects of certification activity —
application processing, office work, panel review sessions, operator
examination, and facility inspections. The job requirements of an inspector
fall into three main categories. The first requirement is complete familiar-
ity with both theory and practice of instrument and equipment operations —
including details of operation, calibration, and maintenance. There is no
alternative to prior "hands-on" experience in this case. If a person does not
have a recent background in this area, a job training program, probably
6-1
-------
conducted at the EPA Ann Arbor testing laboratory would be required. This
aspect is discussed more fully in Section 6. 5. 1.
The second requirement is that the inspector be intimately
familiar with all applicable provisions of 40 CFR 85, including all recent
EPA promulgations in the Federal Register, and their implementation.
The third requirement, which is nontechnical, is that the
inspector be capable of working well with people of widely different back-
grounds, and at all organizational levels of the certified laboratories. The
inspector position is an important one, and the inspector serves as an EPA
representative both in this country and abroad.
6.3 STAFFING REQUIREMENTS
6.3.1 Governing Factors
There are four principal considerations which govern the size
of staff required to implement the proposed laboratory certification program.
The first of these is the number, size, and geographical distribution of the
certified laboratories, and the number of certified operators. For purpose
of analysis, this factor was fixed (as described in the following section) at
conditions considered to be representative of the first few years of the certi-
fication program.
The second factor concerns the distribution among the staff
of the different categories of certification activities. It is necessary to have
a clear functional distinction between office and field responsibility, but it is
proposed that, at the operational level, each inspector participate in both
functional areas. The office work consists primarily of working on technical
phases of application processing and on-going quality control functions, and
participating in panel review sessions. Field work consists of participation
in each of the three types of facility inspections (initial/renewal, periodic,
and unannounced), plus administering written and practical tests to certified
operator applicants. However, within these basic functional areas, individual
inspectors may have categories of special knowledge and proficiency, such as
dynamometer equipment or gas analysis instruments, and their specific
capabilities and attributes may be emphasized within these functional areas.
6-2
-------
The third governing factor concerns travel schedule. The
nature of the inspector position entails a relatively large amount of travel
time. This must be kept within certain limits and structured in a specific
manner to achieve a satisfactory level of long-term job satisfaction for an
inspector.
The fourth consideration involves a satisfactory inspection
visit rotation schedule. To achieve optimum inspection efficiency and avoid
certain inherent (but usually undetected) personal bias factors, it is proposed
that the following restrictions on inspection visits by an individual inspector
should apply .
a. The same inspection team should not perform two successive
initial/renewal inspection visits to a given facility.
b. No inspector should participate in two successive inspection
visits (of any kind) to a given laboratory.
The impact of each of these four considerations on the quanti-
tative development of the required EPA staff is discussed in the following
sections,
6.3.2 Estimate of Laboratories to be Certified
To establish specific numerical estimates for personnel, sched-
ules, and costs, it was necessary to establish a baseline scenario of emission
test laboratories to which the program would be assumed to apply. This base-
line must include information concerning geographical location and extent of
emission test equipment at each facility. A review of this subject led to the
conclusion that about 17 independent laboratories could reasonably be expected
to be early applicants (within a year) to the proposed laboratory certification
program. This total was composed of 12 in the continental U.S., 4 in Europe,
and 1 in Japan. A longer term look indicated that about 26 laboratories might
be involved within a few years (consisting of 18 domestic laboratories, 6 in
Europe, and 2 in Japan).
All of the detailed program implementation analyses of this
report were applied to the near-term group of 17 laboratories. The subject
6-3
-------
of extrapolating these results to the longer term arrangement is discussed
in Section 6.5.4.
Eleven specific domestic facilities were assumed to be
involved, representing six different parent organizations. Information was
acquired from each concerning the scope of their emission test facilities.
Appendix C lists the organizations contacted. Similar information was avail-
able concerning two suitable candidate European laboratories.
This information indicated that the candidate laboratories
could be divided into four classifications based on equipment capabilities.
The four unassigned slots in the scenario of 17 •were also assigned a classi-
fication \vithin this system. This facility classification system is defined in
Table 6-1.
The geographical distribution of these domestic facilities is
nationwide. The foreign laboratories -were assumed to be located as follows;
one each in the vicinity of London, Paris, Rome, and Tokyo, plus one in an
unspecified location in northern Europe.
6.3.3 Laboratory Certification Program Implementation — Person-
nel Requirements, Schedules, and Costs
This section presents the results of a detailed examination of
the requirements for program plan implementation for the near-term
scenario of 17 certified laboratories. It describes the assumptions made and
calculational procedures used to determine each of the major factors and
presents the principal results. The principal requirements in the areas of
staffing, schedule, and travel costs are listed below:
a. Laboratory Certification Staff;
One Supervisor (-with no inspection travel workload)
Seven Inspectors (all participate equally in office and field
work)
b. Inspection Travel Schedule:
72 days per year travel time per inspector, 16 trips per year
3 weekend days of travel per year per inspector, in conjunc-
tion with a European inspection trip
6-4
-------
Table 6-1. Laboratory Facility Classification
Equipment and Locations
Emissions Test Capability
(For 1975 LDV Testing,
Subpart A)
Number of Dynamometers
Number of CVS Systems
Number of Complete Sets
of Gas Analysis Instruments
Number of Laboratories
Domestic
Europe
Japan
Total
Facility Classification
A
1
1
1
6
2
--
8
B
2
2
1
2
--
--
2
C
2
2
2
3
2
1
6
D
3
3
2
1
--
--
1
6. 3.3. 1
Inspection Travel Costs:
Approximately $61, 000 per year for the laboratory
certification staff
"Ideal" Man-Hour Estimates
Initial estimates were made of the man-hours required to
perform every operation specified in the work element flow sheet diagrams
presented in Section 5. This required identification of the individual work
elements for each subtask, and an assignment of a time estimate for the per-
formance of each such work elements. Thus, the identification and assess-
ment of each individual work element performed in the man-hour estimation
process represents an extension of the task block sheets of Section 5 into
succeeding levels of detail.
These man-hour estimates form the basis of subsequent staff,
costing, and schedule computations, and consequently represent an important
6-5
-------
part of the overall analysis. Therefore, the basic procedure of the man-hour
estimation process is described below.
A hypothetical minimum facility (Class A) laboratory was
followed through every step of the certification process, starting with the
receipt in the mail at EPA of the completed application form, and proceed-
ing through the various analysis and panel review phases, the inspection visit,
and the final review process prior to granting certification. This same hypo-
thetical facility was then subjected to a periodic and unannounced inspection,
in which all steps in the pre- and post-inspection office work were analyzed,
as -well as the inspection visit proper. In every phase of this process, a
degree of technical complication was structured into the analysis which was
considered to be representative of a real situation. These estimates are
referred to as "ideal", however, since they assume no interruptions or com-
peting -work assignments, and they further assume that all supporting equip-
ment and/or personnel which may be required are immediately available as
needed.
This analysis process provided a complete, quantitative pic-
ture of the total work burden for all aspects of the proposed certification
program for a specific size of facility (Class A). These results •were then
extended to the other facility sizes (Classes B, C, and D, as defined in
Section 6.3.2). This was accomplished by repeating every step in the analy-
ses performed for the Class A facility, and estimating for each applicable
category the additional man-hour requirement to cover the extra activities
resulting from the additional emissions test equipment involved. Table 6-2
presents the itemized results for application processing, three types of
inspections (initial/renewal, periodic, and unannounced) and operator
certification.
6.3.3.2 Personnel Requirements
Personnel requirements were developed based on the "ideal"
man-hour estimates presented in Section 6.3.3. 1. The development process
consisted of cataloging this information in terms of man-day requirements
6-6
-------
Table 6-2. Ideal Man-Hcmr Estimates for Laboratory Certification Activities
Class of Laboratory
Facility3- and Category
of Inspector Work
Activity
Facility A
Office
Field
Total
Facility B
Office
Field
Total
Facility C
Office
Field
Total
Facility D
Office
Field
Total
Types of Certification Activity and Personnel
Initial Applica-
tion Processing0
Inspec-
tor
170.0
23.6
193.6
210.0
29.4
239.4
275.0
35. 8
310.8
314.0
41.6
355.6
Super-
visor
19.3
—
19.3
24.7
--
24.7
30.8
__
30. 8
36.2
—
36.2
Periodic
Inspection
Inspec-
tor
28.0
15.2
43.2
34.2
19.4
53.6
41.4
24.4
65.8
47.6
28.6
76.2
Super-
visor
7.6
--
7.6
10.3
—
10.3
13.0
—
13.0
15.7
—
15.7
Unannounced
Inspection
Inspec-
tor
17.0
4. 8
21.8
22. 0
6.3
28.3
27.0
8.6
35.6
32.0
10. 1
42. 1
Super-
visor
4.6
--
4.6
6.0
—
6.0
7.4
—
7.4
8. 8
--
8.8
Operator
Certification0
Inspec-
tor
17.0
12.0
29.0
17.0
12.0
29.0
17. 0
12.0
29.0
17.0
12.0
29-0
Super-
visor
3.6
--
3.6
3.6
—
3.6
3.6
—
3.6
3.6
__
3.6
aSee Section 6.3.2 for definition of facility class
Includes inspection visit
CBased on two certified operators per laboratory
o
I
-J
-------
to perform each of the required functional tasks over the 24 month
certification cycle. A distinction was made between office and field (inspec-
tion) -work. Each of these two categories of activity was cataloged for each
of the four basic task functions of the certification group; namely, initial/
renewal application and inspection, periodic inspection, unannounced inspec-
tion, and operator testing.
The ideal man-hour estimates were converted into real-time
estimates by using parametric values of a "man-hour efficiency" factor.
The values selected for this factor were 1. 0, 1. 25, 1. 5, 1. 75, and 2. 0. The
ideal man-hour estimates are representative of the average time required to
perform each individual task, assuming a representative amount of technical
complication is involved. They are ideal only in the sense that they assume
no interruptions or competing job assignments, and that the supporting equip-
ment and/or personnel which may be required for any given task or work
elements are immediately available as needed. The "man-hour factor" is
applied to the ideal man-hours to account for those cases in -which the above
three assumptions are not met. As an example, consider the activity of the
inspector office burden associated with processing an initial application. The
ideal input data from Section 6.3.3. 1 and the results of applying various
"man-hour factors" are shown in Table 6-3 for the four different laboratory
classifications. The other office activities were treated in the same manner.
This resulted in the total inspector office burden shown in Table 6-4. This
office burden reflects the three periodic and four unannounced inspections at
each facility during the 24-month certification cycle, and two certified oper-
ators per laboratory are assumed. Table 6-4 shows, for example, that the
total office burden would require approximately four inspectors, if a man-
hour efficiency factor of 2. 0 was chosen. This latter computation is based
on 225 working days per year per person. This value (225 days) is used
throughout the staffing and schedule analysis. It is considered a conservative
estimate, and is based on 4 weeks per year vacation, 1 week sick leave, and
ten holidays.
6-8
-------
Table 6-3. Inspector Office Burden, Initial Application Processing
Facility
Clas sification
A
B
C
D
No. of
Facilities (N)
8
2
6
1
^->
Z-i Man-Days
(for 24-month cycle)
Ideal
Man-hours
(man -days)
[Man -days X N]
171
(22)
1176]
210
(27)
[54]
275
(35)
[210]
314
(40)
[40]
[480]
Man-hours Factor
1.25
214
(27)
[216]
262
(33)
[66]
344
(43)
[258]
392
(49)
[49]
[589]
1. 5
256
(32)
[256]
315
(40)
[80]
413
(52)
[312]
471
(59)
[59]
[707]
1.75
299
(38)
[304]
367
(46)
[92]
481
(61)
[366]
550
(69)
[691
[831]
2.0
342
(43)
[344]
420
(53)
[106]
550
(69)
[414]
628
(79)
[791
[943]
6-9
-------
Table 6-4. Total Inspector Office Burden
Type of Activity
Factor
Initial Inspection
Periodic Inspection
Unannounced Inspection
Operator Testing
y
/_- Man-days
Number of Inspectors3-
Inspector Office Burden, Man days
(2-year cycle)
Ideal
1.0
480
252
204
37
973
2.2
Man-hours Factor Results
1.25
589
306
252
46
1193
2.7
1. 5
707
357
304
55
1423
3.2
1.75
831
429
340
64
1664
3.7
2.0
943
456
388
73
1860
4.2
aBased on 225 work days per year per inspector
Similar analyses were performed for the on-site inspection
visit -work load for each type of inspection for each class of facility. From
this information, the inspection team numerical structures of Table 6-5 were
established. Next, the total man-day requirements for these inspection
visits, including travel time were computed. This man-day figure must
include the time required for certified operator testing. The latter item is
not included in Table 6-5. Accordingly, it was assumed that the two certi-
fied operator applicants would be tested concurrently with the facility initial/
renewal inspection visit, and would require a 2-day trip by an additional
inspector (4 hours to administer the written examination, plus 8 hours to
administer two practical tests). It was further assumed, for the initial cal-
culation, that every inspection visit is preceded and followed by a day of
travel, and that there is no weekend travel or stay time. The results of these
6-10
-------
Table 6-5. Inspection Team Numerical Structure
Facility
Classifi-
cation
A
B
C
D
Initial / R enewal
Inspection
No. of
Inspec-
tors
3
3
3
3
Days of
Visit
2
2
3
3
Periodic
Inspection
No. of
Inspec-
tors
2
2
2
2
Days of
Visit
2
2
3
3
Unannounced
Inspection
No. of
Inspec-
tors
1
2
2
2
Days of
Visit
1
1
1
2
calculations on inspection visit man-day requirements are shown in Table 6-6,
from which it is seen that the inspection work load is equivalent to approxi-
mately a 2-1/2 man-level staffing. Combining this with the results of
Table 6-4 for the office burden (for a man-hour factor of 2.0), gives a
requirement for a seven-man staff to handle both the office and field work
associated with the laboratory certification program associated with 17 inde-
pendent testing laboratories.
A similar analysis procedure was applied to estimate the work
load associated with the supervision of the activities of the inspection staff.
The results are shown in Table 6-7, and indicate that one supervisory position
is required.
6.3.3.3 Scheduling of Inspection Visits
This section describes the analysis activities concerned with
establishing the timing and schedule factors of the various inspections,
including travel time, to determine the work schedule for each inspector
position. The goal was to establish an efficient scheduling of inspection trips,
6-11
-------
Table 6-6. Inspection Visit Man-Day Requirements
(2-Year Certification Cycle)
Type of
Inspection
Initial /Renewal
(including operator
certification)
Periodic
Unarm ounc ed
£
Inspection
Time,
Man- days
157
246
112
515
Travel Total Man- Trips
Time, Time, No. of
Man- days Man- days Trips
136 293 17 68
204 450 51 102
208 320 68 104
548 1063 136 274
Assuming 225 working days per year per inspector;
No. of inspectors
r equir ed =
2
No. of inspectors required for
burden (Table 6-3)
1063 = 2.4
x 225
office = 4. 2
Total No. inspectors required
6. 6 = 7
-------
Table 6-7. Supervisory Workload
(2-Year Certification Cycle)
SUPERVISOR MAN- DAYS
Type of
Activity
Initial Application
Periodic Inspection
Unannounced Inspection
Operator Certification
Ideal
Man- day s
53
64
51
8
1.25
67
82
64
10
Man- hour
1.5
80
99
77
12
Factor
1.75
93
115
89
14
2.0
106
132
102
16
Man- day s
Fraction of full-time supervisor
(Defined as 450 man-days in
2 years)
176
0.39
223
0. 50
268
0. 60
311
0.69
356
0. 74
One Supervisory Position is Required
-------
consistent with two restrictions. The first restriction is that there be
minimum weekend travel or stay time. This is considered to be an
essential requirement for long-term job-acceptability, as the inspector po-
sitions require relatively extensive travel time. The second restriction is
that there be no compromise with the surprise element of the unannounced
inspections, such as would occur by combining them with other visits to the
area in a more time-efficient but predictable manner. The unannounced
inspection is an important and efficient aspect of on-going quality control,
but its value would be seriously degraded if the timing of the visit fell into
a pattern of established routine.
For the domestic schedule, two 1-day unannounced inspection
visits are combined into a 1 week trip, with a day of travel before and after
each inspection visit. No other inspection visits are combined, as this would
result in weekend travel or stay time. Table 6-8 shows the resulting travel
schedule for the domestic laboratories.
For the four European laboratories, it was assumed that the
certification schedules were adjusted to be staggered at 6-month intervals.
Thus, every 6 months an inspection tour is made of all four laboratories,
consisting of an initial/renewal inspection at one facility, and periodic inspec-
tions of the other three. Each unannounced inspection was assumed to occur
as a separate round trip from Ann Arbor to the one laboratory concerned.
The results of these computations are shown in Table 6-9. For the one
Japanese laboratory, each type of inspection visit was assumed to be a separ-
ate round trip from Ann Arbor. This produced the results shown in
Table 6-10. The summarized results for all inspection visits are given in
Table 6-11. All the figures for average inspector load per year shown in
these tables are based on a seven-man inspection staff.
The key results of this analysis are that each inspector must
make an average of 16 trips per year, spending an average of 72 days per
year on the road (counting travel time) which includes an average of 3 week-
end days per year travel time (in conjunction with a European inspection
trip).
6-14
-------
Table 6-8. Inspector Travel Schedule — Domestic Laboratories
(24-Month Certification Cycle)
Type of Inspection
Initial /Renewal /Operator
Periodic
Unanno unc e d
Man-days
204
312
196
Number of Trips
12
36
28
Man -Trips
48
72
44
712
76
164
Ul
Average Inspector Load Per Year;
712
Travel time = „ ~
7x2
Individual trip duration = 1 >.
164
Trips per year
7x2
Time between start of successive trips
Weekend travel
= 50. 9 days
4. 3 days
= 11. 7
= 1. 02 month
0
-------
Table 6-9. Inspector Travel Schedule — European Laboratories
(24-Month Certification Cycle)
Type of Inspection
Combined Initial/Renewal/
Operator and Periodic
Unannounced
Man-days
146
Number of
Trips
4
Man-Trips
16
Weekend
Man-days
40
72
16
24
Average Inspector Load Per Year:
Travel time (work days)
Individual trip durations
Trips per year
Time between start of successive trips
Weekend travel
C ombined initia 1 /r enewa 1 /
operator and periodic inspections
10. 4 days
9. 1 days
1.1
10. 5 months
2. 9 days
Unannounced
Inspections
5. 1 days
3. 0 days
1.7
7. 0 months
0
-------
Table 6-10. Inspector Travel Schedule— Japanese Laboratory
(24-Month Certification Cycle)
Type of Inspection
Initial /Renewal /Operator
Periodic
Unannounced
Man-days
19
30
24
Number of Trips
1
3
4
Man-Trips
4
6
8
73
18
Average Inspector Load Per Year:
Travel time
Individual trip duration
Trips per year
Time between start of successive trips
Weekend travel
5. 2 days
4. 0 days
1.3
9. 4 months
0 (except as may result from time change)
-------
Table 6-11. Inspector Travel Schedule— Overall
(24-Month Certification Cycle)
Type of Trip
Domestic
Europe - Initial/Renewal/Operator
-Unannounced
Japan
S
Man-days
712
146
72
73
1,003
Number of Trips
76
4
16
8
104
Man-trips
164
16
24
18
222
I
I—I
00
Average Inspector Load Per Year:
Travel time (workdays)
Individual trip duration
Trips per year
Time between start of successive trips
Weekend travel time
71. 7 days
4. 5 days
15.9
16. 4 work days
2. 9 days (plus that which may result solely
from time change on foreign trips)
-------
This is a rather high travel load, and is probably near the
upper range of a practicable schedule. This subject is discussed further in
Section 6.5.3, but a few comments may be abstracted here. First, these
calculations were intentionally made for conservative, general conditions.
A travel time reduction down to about 68 to 69 days per inspector should be
readily achievable in practice by using specific features of the distribution
of the applicant laboratories. Some other slight reductions appear possible
but are not assumed herein. If a larger reduction in travel load is consid-
ered necessary, this can only be accomplished (without voiding the basic
features of the proposed certification process) by increasing the size of the
inspection staff. Thus, an eight-man staff would reduce the travel time to
about 60 days per year per inspector.
6.3.3.4 Travel Expenses
Based on the inspection visit schedule derived in the preced-
ing section, travel expenses for each inspection trip were computed in
accordance with the following basic procedure. Each trip was assumed to be
a round trip from Ann Arbor, with some trips including one or more inter-
mediate sites. Airline fare was taken as the coach rate in effect on the date
the calculations were performed. Per diem (lodging plus meals) was
assumed to be $34 per 24-hour day per inspector for domestic trips, and
$50 for foreign trips. Ground transportation estimates were included for all
applicable stages. The summarized results are given in Table 6-12, which
shows a total inspection visit travel expense of approximately $61, 000 per
year.
With a staff of seven inspectors plus one supervisor at a bur-
den rate of $50,000 per position per year, the cost of the laboratory cer-
tification program would be approximately $400, 000 staff burden plus
$61, 000 travel expenses, for a total annual cost of approximately $461, 000.
It should be noted that the travel allowances and costs per
position as used above are made on a different basis than used by EPA for
its own economic projections. The EPA uses a different accounting structure
6-19
-------
Table 6-12. Travel Expenses for Inspection Visits
(2-Year Certification Cycle)
Geographical
Category and
Number of
Laboratories
Domestic (12)
European (4)
Japan (1)
Overall Subtotals
Domestic
Europe
Japan
Z
Type of
Inspection
initial/ renewal0
periodic
unannounced
Z
initial/ renewal"
and periodic
unannounced
Z
initial/ renewal0
periodic
unannounc ed
Z
Travel
Costs3-
$
7, 870
11,790
9,700
29,360
14,430
18, 700
33, 130
5, 140
7,720
10, 290
23, 150
29,360
33,130
23, 150
85, 640
On- site
Costsb
$
5, 690
9,510
5,460
20, 660
9,750
2,980
12,730
860
1,430
990
3, 280
20, 660
12,730
3, 280
36,670
Total
Travel
Costs
$
13, 560
21, 300
15, 160
50,020
24, 180
21, 680
45, 860
6,000
9, 150
11, 280
26,430
50, 020
45, 860
26,430
122,310
Percent
of
Total
27.1
42.6
30.3
100.0
52.7
47.3
100.0
22.7
34.6
42.7
100.0
40.9
37.5
21.6
100.0
aRound trip cost from Ann Arbor to airport of desination
Per diem and ground transportation from airport of destination
to return
Includes operator certification
Initial /renewal, operator certification, and periodic inspections
combined in inspection tour
6-20
-------
for personnel costing, full details of which were neither available nor
directly pertinent to the present analysis. The purpose of the present esti-
mate is to indicate the approximate total magnitude of the charges which
should be attributed to the proposed laboratory certification program,
regardless of the details as to how these costs would be distributed internally
by the EPA.
6.3.4 Organization of the Laboratory Certification Group
6.3.4.1 General Personnel Requirements
Table 6-13 summarizes the basic technical work areas as
delineated in the work sequence analysis (Section 5) and as utilized in the
staffing, schedule, and cost estimates of Section 6.3.3. Although there is a
clear functional distinction between the office and field responsibilities, it is
recommended and assumed in all analyses in Section 6.3.3 that each inspec-
tor on the laboratory certification staff participates, on a rotating or as
needed basis, in both office and field work areas.
In addition to the inspectors, per se, the laboratory certifica-
tion group would require an administrative head, with line management
responsibility, and some form of clerical assistance. In time, the clerical
burden should increase due to the need to process, file, and retain such
items and records as:
a. Application forms
b. Communications between laboratory certification group,
laboratories, and operators
c. Certificate issuance records
d. Facility inspection reports
e. Results of operator written and practical tests
f. Measurements of EPA gas cylinder "unknowns"
transmitted to EPA
g. Results of "naming" laboratory calibration gases
6-21
-------
Table 6-13. Technical Work Areas
IN OFFICE
/ DEFINITION OF GENERAL AND SPECIFIC CERTIFICATION PROGRAM
REQUIREMENTS
/ ESTABLISH APPLICATION FO'RM REQUIREMENTS
/ PREPARE APPLICATION FORMS
/ PROCESS AND RATE APPLICATIONS
/ PREPARE WRITTEN EXAMINATIONS
/ GRADE WRITTEN EXAMINATIONS
/ PREPARE PRACTICAL TESTING PROCEDURES
/ PROCESS CERTIFICATIONS
N • IN FIELD
/ GIVE WRITTEN EXAMINATIONS
/ GIVE PRACTICAL TESTS
/ GRADE PRACTICAL TESTS
• REVIEWED BY OFFICE STAFF
/ MAKE FACILITY INSPECTIONS
-------
6. 3. 4. 2 Initial Organizational Structure
SLnce the initial laboratory certification program manpower
requirements consist principally of seven or eight inspectors plus one super-
visor, it would appear more utilitarian and effective to initially organize the
group as a section or branch within an existing branch or division of the
Office of Mobile Source Air Pollution Control (OMSAPC). This would enable
the neophyte laboratory certification group to utilize existing lines of man-
agement control and clerical services. At the same time, it would permit
the total energies of the group members to be centered on their task efforts
and not divert their time to nonproductive activities which often are associ-
ated with the formation of a totally new organizational structure. As and if
the manpower requirements of the group increase (e. g. , as new or additional
laboratories and operators request certification), then consideration should
be given to a more formal and structured organizational form, as described
below.
6. 3. 4. 3 Longer-Term Organizational Structure
In the longer-term, the basic functional task requirements of
the laboratory certification group should be similar to that of the near term
(above); however, it is expected that there will be an increase in the number
of personnel assigned to the group in accordance with an increased number
of certified laboratories covered by the program.
There is an additional operational difference which concerns
the development of written and practical tests for operators. In the near-
term structure (first 2 years or so), this task has been assumed to be per-
formed for EPA by an outside contractor. After this period, EPA will have
an option in this regard. One is for EPA to assume this task. This is the
procedure used by the FA A (e. g. , aviation mechanic written examinations)
and the AEC (nuclear power plant operator written and practical tests).
Exercise of this option would probably require additional EPA personnel.
6-23
-------
An alternative approach would be for EPA to continue to contract for this
task. This is the method used by the California Department of Public Health
for written examination preparation for clinical laboratory technologists. In
either event, it would be a responsibility of the laboratory certification group
to ensure that requirements associated with operator retesting (both for
failed tests and for certification renewal) are met. These requirements,
described in Figure 5-24 of Section 5. 3, deal with examination upgrading,
record retention, and avoidance of excessive repeat questions to the same
operator on successive tests.
Because of the factors of (a) increased number of staff mem-
bers, (b) increased clerical work load, and (c) examination development
requirements, it may be advisable in the longer term to provide a more
formal organizational structure for the laboratory certification group. One
such option is delineated in Figure 6-1. Here, the "laboratory certification
group" is pictured as a branch of an OMSAPC division in Ann Arbor. Three
sections are included in accordance with the three principal functional task
areas: office technical work, field work, and clerical work. The Certifica-
tion Processing Section is charged with responsibility for assuring that all
in-office certification activities are accomplished in a timely and effective
manner. In this regard, then, the principal function of this section is coor-
dination of application processing. Corollary functions would include (a) the
development of examinations for operators, and (b) changes and updating of
the regulations pertaining to laboratory and operator certification, as well as
any necessary changes in the application forms. When the inspectors were
not on laboratory field inspections, then, their in-office efforts would be
available to this section for completion of the necessary work.
The Operations Section would be charged with responsibility
of conducting all field activities, including the scheduling of the inspectors
for each trip and the coordination required between the laboratory and the
laboratory certification group with regard to inspections and other on-going
6-24
-------
LABORATORY
AND OPERATOR
CERTIFICATION
GROUP
DIVISION OR
BRANCH
STAFF
• SPECIAL
COORDINATOR
CLERICAL
OFFICE
SECTION
CERTIFICATION
PROCESSING
SECTION
OPERATIONS
SECTION
IN)
CLERICAL
PROCESSING
FILINGS
STORAGE
REGULATIONS
AND APPLICATIONS
EXAMINATION
DEVELOPMENT
APPLICATION
PROCESSING
COORDINATION
TEST OPERATIONS
AND OP ERA TOR
EXAMS
FACILITY AND
EQUIPMENT
ANALYSIS AND
INSTRUMENTATION
Figure 6-1.
Organization of Laboratory Certification Group —
A Long-Term Option
-------
quality control activities. As noted in Figure 6-1, if the number of inspec-
tors on the staff were large enough, it might be advisable to further segregate
the inspection staff into areas of special expertise or proficiency, as
indicated.
The third section, Clerical, would be charged with all paper-
work processing, filing, and information storage functions. In the long term,
if a sufficiently large number of laboratories and operators apply for certifi-
cation, a separate Clerical Office Section may be essential for efficient
operation of the laboratory certification group. This is particularly true
because the individual inspectors are assumed to be engaged in field work
for a high percentage of the time.
6.4 MANAGEMENT PLAN OPTIONS
The current organizational structure of the Office of Mobile
Source Air Pollution Control is depicted schematically in Figure 6-2. By
inspection, there are four obvious, potential ways of incorporating the
laboratory and operator certification group into this structure. Each such
approach is discussed below in terms of advantages and disadvantages.
6. 4. 1 Option A
Figure 6-3 depicts the laboratory and operator certification
group as having divisional status within OMSAPC. The advantages of such
an arrangement include:
a. Provides a single direct line of responsibility to OMSAPC
b. Provides direct management control over the assigned
responsibility (the division director's time is not diluted by
other functions)
c. Provides a single and direct focal point of contact with inde-
pendent testing laboratories and operators
d. Provides the opportunity to organize the required division
personnel in the most efficient manner to accomplish the
required tasks, as there would be no existing branches to
avoid overlap with
6-26
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OMSAPC
E.G. STORK
EMISSION
TESTING
LABORATORY (0PM)
• ANN ARBOR, MICHIGAN
STAFF
• TECHNOLOGY
• REGULATIONS
I
IN)
DIVISION OF
ALTERNATIVE
AUTOMOTIVE
POWER SYSTEMS
(AAPS)
DIVISION OF
EMISSION
CONTROL
TECHNOLOGY
(DECT)
DIVISION OF
CERTIFICATION
AND
SURVEILLANCE
ENGINES
BRANCH
ELECTRIC AND
FUELS BRANCH
REGULATION
DEVELOPMENT
BRANCH
TEST AND
EVALUATION
BRANCH
CERTIFICATION
BRANCH
SURVEILLANCE
BRANCH
CHARACTER-
IZATION AND
CONTROL
BRANCH
Figure 6-2. Current Organizational Structure
-------
QMS A PC
EMISSION
TESTING
LABORATORY (0PM)
• ANN ARBOR, MICHIGAN
oo
STAFF
AAPS
DIVISION
DECT
CERT. & SURV.
DIVISION
DIVISION OF
LABORATORY
AND OPERA TOR
CERTIFICATION
Figure 6-3. Option A Organizational Structure
-------
On the other hand, this arrangement has several disadvantages, including:
a. It may not enable efficient use of manpower if the number of
certified laboratories and operators is small.
b. It requires a complete staffing of a new division.
c. It requires extensive interfacing with other OMSAPC
activities, including:
1. Certification branch of Certification and Surveillance
Division -- for review of certified test data sent in by
the laboratory
2. Emission Testing Laboratory (OPM) -- for coordination
of facility, equipment, and operational procedures
3. Division of Emission Control Technology (DECT) --
for coordination of test and evaluation procedures
6. 4. 2 Option B
Figure 6-4 shows the laboratory certification group as a
branch of the Ann Arbor Emission Testing Laboratory (OPM). The possible
advantages of such an arrangement include:
a. It places the inspectors of the laboratory certification group
in close working contact with facility, equipment, and opera-
tional requirements
b. It may be possible to draw on laboratory personnel who are
experienced with regard to facility inspection requirements,
as well as operator written and practical test requirements.
Disadvantages of this organizational approach include:
a. It may conflict with the principal mission of the laboratory
(i. e. , it would no longer be a "pure" testing facility).
b. It would drain the laboratory of experienced personnel if
they were used to initially staff the laboratory certification
branch.
c. Interfacing with other OMSAPC activities would still be
required:
1. Certification Branch of Certification and Surveillance
Division -- for review of certified test data sent in by
the laboratory
6-29
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QMS A PC
EMISSION
TESTING
LABORATORY (0PM)
• ANN ARBOR, MICHIGAN
i
oo
o
LABORATORY
AND OPERATOR
CERTIFICATION
BRANCH
STAFF
AAPS
DIVISION
DECT
CERT. & SURV.
DIVISION
Figure 6-4. Option B Organizational Structure
-------
2. DECT -- for coordination of test and evaluation
procedures, especially for after-market or retrofit
tests
d. It adds to the management responsibilities of the OPM
director.
6. 4. 3 Option C
Figure 6-5 depicts the laboratory and operator certification
group as a branch within the Certification and Surveillance Division. The
possible advantages of this arrangement include:
a. It places all "certification" functions (vehicles, laboratories,
operators) in the same division.
b. Personnel familiar with the quality control aspects of certi-
fication testing may be available to initially staff the new
branch.
Disadvantages of this approach include:
a. It may be in conflict with a principal mission of this division
(i. e. , the certification of emission test vehicles in conjunction
with the emission test laboratory).
b. It would require replacement of any personnel used for initial
staffing of the new branch.
c. Interfacing with other OMSAPC activities would still be
required:
1. Emission Testing Laboratory (OPM) -- for coordination
of facility, equipment and operational requirements
2, DECT -- coordination of test and evaluation procedures,
especially for after-market or retrofit tests
d. It adds to the management responsibilities of the division
director.
6. 4. 4 Option D
Figure 6-6 shows the laboratory certification group as a branch
of DECT. The possible advantages of this arrangement include:
a. It places the laboratory certification group personnel (i. e. ,
inspectors) in close working contact with: regulations develop-
ment personnel, test and evaluation personnel, and after-market
or retrofit device personnel.
6-31
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I
00
QMS A PC
EMISSION
TESTING
LABORATORY (0PM)
ANN ARBOR, MICHIGAN
AAPS
DIVISION
DECT
STAFF
CERT. & SURV.
DIVISION
CERTIFICATION
BRANCH
SURVEILLANCE
BRANCH
LABORATORY
AND OPERATOR
CERTIFICATION
BRANCH
Figure 6-5. Option C Organizational Structure
-------
EMISSION
TESTING
LABORATORY (0PM)
• ANN ARBOR, MICHIGAN
J.
AAPS
DIVISION
CT-
U>
00
OMSAPC
STAFF
DECT
1
CERTIFICATION
AND
SURVEILLANCE
DIVISION
REGULATION
DEVELOPMENT
BRANCH
TEST AND
EVALUATION
BRANCH
CHARACTER-
IZATION
AND CONTROL
BRANCH
LABORATORY
AND OPERATOR
CERTIFICATION
BRANCH
Figure 6-6. Option D Organizational Structure
-------
b. The personnel involved in formulating the laboratory and
operator certification program are located in this division
and may be available to help staff the new branch.
Disadvantages include:
a. It may conflict with the principal mission of this division of
regulations development.
b. It would require the replacement of any personnel diverted
to staff the new branch.
c. It would require interfacing with other OMSAPC activities:
1. Emission Testing Laboratory (OPM) -- for coordination
of facility, equipment, and operational requirements
2. Certification and Surveillance Division -- for review
of test data sent in by the laboratory
d. It adds to the management responsibilities of the DECT
director.
6. 4. 5 Overview Comments
As the preceding sections have noted, each of the four options
has certain desirable features and certain undesirable features from an overall
management organization viewpoint. Chief among these are:
a. All options require either initiation or continuation of
interfacing with existing OMSAPC activities.
b. All options except A increase the responsibilities of a division
director.
c. All options require drawing on at least some experienced
EPA personnel to initially staff the new laboratory and operator
certification group, whether it has branch or divisional status.
d. Option A provides the clearest line responsibility for the new
function; it could draw on all existing divisions for initial
staffing and thus spread the restaffing load over a broader
base.
e. Option A would appear to require a certain minimum level
of certification activity to justify divisional status.
6-34
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f. Options B, C, and D all have a logical basis for effectively
carrying out the laboratory certification program. The
group could be advanced to divisional status at a later date
if the work load warranted.
g. Options B, C, and D may present conflicts with the primary
assigned functions of the division concerned.
It would seem premature to exercise option A initially, since
the anticipated work load during the early stages may not justify divisional
status. Therefore, the choice should be between options B, C, and D. The
selection of the appropriate option should consider the possible functional
conflicts noted in g above, as well as the possibility of best matching avail-
able talents in the various OMSAPC divisions with the personnel requirements
of the laboratory certification group. At present there is no clear-cut prefer-
ence for any of these alternatives.
This analysis is intended to outline some of the obvious merits
and problems with various organizational concepts. The selection of the
actual organizational form may consider other factors not addressed in this
discussion.
6. 5 SPECIAL PROBLEMS
This section considers in more detail certain problem areas
that were mentioned in earlier sections but were not discussed fully at the
time since they were corollary to the principal analysis activity.
6. 5. 1 Inspector Training
It was emphasized in Section 6. 2 that recent "hands-on"
experience with emissions test equipment should be a prerequisite for assign-
ment to the position of inspector. It is unlikely that a sufficient number of
personnel will be available initially who meet this requirement and who also
satisfy the other requirements for appointment as an inspector. Accordingly,
a training program would have to be instituted prior to full-scale implementa-
tion of the certification program.
6-35
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This training program should most likely operate in the
following manner. It would be applicable only to personnel whose background
indicates that they would be suitable for assignment as an inspector. The
program would consist of working in the EPA Testing Laboratory (OPM) at
Ann Arbor, under the direction of normal laboratory line supervision. The
work should entail basic instrument and equipment operation, calibration,
maintenance, and trouble-shooting. For a person with no prior experience
in these specific areas, but who possesses the proper technical background
and good motivation, it is estimated that about 3 months full-time work under
these conditions would be required to establish the necessary knowledge and
skills. It would be good practice to require each trainee to successfully take
the regular written and practical operator's exams at the end of this program.
In addition to this formal initial training program, it would
appear very desirable to have every inspector receive an annual briefing or
check out given by personnel from the Ann Arbor Testing Laboratory. This
would cover latest developments in technique, equipment, and instrumentation,
and would include such hands-on work by each inspector as may be required to
familiarize him with these new procedures.
6. 5. 2 Program Start-Up
The subjects of concern here are the possible conflicts that
might arise on program start-up, due to initial overloading of the capabilities
of the laboratory certification group. For example, consider the worst case
occurrence and assume that all 17 laboratories of the near-term scenario were
to apply immediately upon announcement by EPA of implementation of the
certification program. The questions to be investigated then become: (a) how
long would it take to complete the initial application processing and inspection
of all 17 facilities, and (b) how can the resulting asymetrical renewal schedule
(24-month cycle) be adjusted to distribute the certification work load uniformly
over each calendar year.
The information generated in Section 6. 3. 3. 2 was used to
construct bar charts representing the calendar time required to perform each
6-36
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phase of initial application processing and inspection. An analysis was
performed for the most conservative case (man-hour factor of 2. 0 in all
office work phases) with two three-man teams working on the processing
of the application. Each team was assumed to work on two applications con-
currently. The analysis resulted in an estimate of 11. 6 months required to
complete the processing of all 17 initial applications. This time allotment
accounts for all unannounced and periodic inspections which come due during
the 11.6 months for those laboratories that receive early certification. For
the purpose of this analysis, unannounced inspections at each facility were
assumed to be spaced at 6-month intervals, starting about 3 months after
award of certification. The seventh man on the inspection staff was assumed
to be required to maintain a continuous complement of two three-man teams,
and to administer the operator tests during the inspection visit.
Similar analyses were performed with man-hour factors for the
office work phases of 1. 5 and 1. 0, respectively. The computed time periods
to complete the certification of 17 laboratories were 9. 1 and 6. 8 months,
respectively.
The situation may arise in which it is desirable to temporarily
augment the inspection staff during the start-up period by borrowing person-
nel from other branches or divisions of OMSAPC. This case was investigated
by assuming that enough additional personnel were available to permit con-
tinuous activity by three three-man teams. An average case man-hour factor
of 1. 5 was assumed, resulting in a time requirement of 5. 7 months to com-
plete the processing of all 17 applications.
In summary, under the assumed worst-case condition of
simultaneous application of 17 laboratories, the initial certification process
can be completed in between 6 months to 1 year, the exact value depending
on the degree of technical complication encountered in application processing,
and on the availability of temporary support personnel for the laboratory
certification staff. This does not appear to be an unreasonable schedule, and
6-37
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it gives a good indication that in actual practice the start-up process should
not present any major roadblocks to efficient program implementation.
It is seen, however, that a likely result of the initial certifi-
cation schedule would be to produce an undesirable, asymetrical certification
cycle. That is, there would be a preponderance of renewal applications and
inspections coming due within a period of a few months to a year. This can
be avoided if EPA retains the discretionary option of extending the certifica-
tion period of selected facilities. This device can be used to smooth out the
certification cycle and produce a more uniform work load for the laboratory
certification group. An approach of this sort would in any event be neces-
sary to achieve the proposed certification schedule for the European labora-
tories described in Section 6. 3. 3. 3. During any such period of certification
extension, all other control activities (periodic and unannounced inspections,
and quarterly measurement of EPA "unknown" gas cylinders) would continue
at the normal, or perhaps even an accelerated schedule.
6. 5. 3 Inspection Travel Schedule
In Section 6. 3. 3. 3 the computed inspection travel time was
shown to be 72 days per year per inspector (with possible reduction to 68 to
69 days in actual implementation). This corresponds to 30 to 32 percent of
total time spent in travel. This is a high number; accordingly, it is of
interest to compare this with the travel schedule of other certifying agencies,
and also to investigate what options are available to decrease this figure,
should it prove to be unsatisfactory.
The only valid comparison is that with the AEC Office responsible
for licensing of operators for nuclear power plants. This activity has a single
national office, with scheduled visits to nationwide facilities. It has nearly
the same central staff as that computed for the EPA Laboratory Certification
Program. The staffing of this AEC office is: one supervisor, three group
leaders (these are senior examiners, and they participate in field work to
the same extent as examiners), five examiners, and two clerical. Plus
21 consultants nationwide who participate in administering exams. Their
average work load is about 1/5 that of the examiner position.
6-38
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Based on an effective examiner staff of 8 + ~ = 12, the
field load (defined as the total on-site inspection/test time per field level
staff position) of the AEC office is estimated to be closely comparable to that
for the proposed EPA staff. Each of the eight examiners from the AEC
national office makes an average of one trip per month. Each trip normally
lasts 1 week, for an average of 60 days on the road per year per examiner,
which amounts to about 27 percent of total time spent in travel. Consider-
ing the comparable field loads of the two activities, it is seen that the lower
AEC travel burden is attributable to the use of the 21 consultants to reduce
the number of trips required of the central staff. Taking this into account,
the travel time for the EPA staff is in line with its field load.
Notwithstanding the above conclusion, it is of interest to
examine what alternatives may exist to reduce this total travel time per
inspector. At one extreme is the FAA structure described in Section 2. 2. 2,
with its management chain of command extending from a single national office
to 12 regional offices, with each of the latter having jurisdiction over a num-
ber of district offices of relatively small geographical coverage. All actual
certification activity is executed at the district office level, thereby eliminat-
ing inspector travel time as a significant consideration. This is an example of
a mature certification program which has a very widespread base of applica-
tion. It is clear that such a structure is beyond the scope of EPA laboratory
certification activities.
The AEC office represents an intermediate case, in which the
consultants perform a somewhat analogous function as that of the FAA district
office. This is an example of a less mature (but well established) certifica-
tion activity, applied to a much smaller base than that of the FAA, but one
which is still considerably larger than that of the proposed EPA activity (in
terms of number of facilities concerned). This approach is not considered
practicable for EPA needs, for the following reasons.
6-39
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First, there may not be an external group of qualified persons
to act as consultants or part-time staff. There may, in certain cases, be
EPA regional offices in the vicinity of a certified laboratory, but it is unlikely
that qualified personnel would be available here. It is likely that the certi-
fied laboratory program would have to be in operation for more than a few
years before this approach could be implemented. Finally, even if the
approach could be implemented immediately, it would not appear desirable
to do so for some years, at least. During the formative stage of a new
activity such as this, it is essential that all the staff be under central direc-
tion, and there should be no communication barriers among the various staff
members. The day-to-day operational procedure must evolve as a result
of feedback at both the office and field levels concerning the daily aspects of
program implementation.
A reduction in the number of inspections could be attained at
the expense of certification control, however, this is considered to be unaccept-
able. Accordingly, the only feasible way to reduce inspector travel load would
be to increase the size of the inspection staff. Adding an eighth inspector would
reduce the annual travel time to about 60 days per inspector; that is, identical
to that of the AEG office. This may well be a desirable step to take, although
it should be noted that, in all other respects (including the inspector rotation
requirements discussed in Section 6. 3. 1) an inspector staff of seven appears
adequate to meet all program requirements for the near-term scenario of
17 certified laboratories.
6. 5. 4 Extension of Analysis Results to Longer-Term
Implementation
As mentioned in Section 6. 3. 2, it is considered likely that
some 26 independent laboratories could be involved in this program after a
few years. It is therefore of interest to estimate the adjustments in the
laboratory certification group required to handle this increased work load.
A review of the analysis details used to obtain the results for the near-term
6-40
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scenario of 17 laboratories leads to the conclusion that, to a good approximation,
both personnel staffing and travel expenses would be increased in direct pro-
portion to this increase in the number of certified laboratories. That is, a
factor of about 1. 5 should be applied, giving a staff requirement of 11 to 13
inspectors, which would probably require a total of two or three supervisory
or administrative positions. Annual travel expenses (at present rates) would
be approximately $94, 000.
6. 6 COMPARISON WITH COST OF EPA-OPERATED
CERTIFICATION TEST FACILITIES IN EUROPE
AND JAPAN
An alternative to certification of independent foreign testing
laboratories would be for EPA to own and operate an emission testing
laboratory in Europe and in Japan, to perform certification testing in those
areas. A cost estimate was performed for such an arrangement, for com-
parison with the proposed laboratory certification program for foreign
laboratories and also for comparison with existing certification costs at the
EPA Ann Arbor Testing Laboratory. The estimate was performed for one
laboratory in Europe and one in Japan, to handle near-term vehicle testing
rates of 360 and 210 certification tests per year, respectively. The cost
estimate for these foreign facilities was structured to the same format as
that used by EPA to determine cost of certification testing at Ann Arbor.
These cost estimates do not represent official EPA figures, however. They
are estimates prepared during this study based on general guidance from
EPA.
The workload and staffing estimates for these laboratories are
shown in Table 6-14. The organization structure upon which these numbers
are based is described below.
It would appear to be essential that there be one full-time,
professional level EPA employee responsible for each dynamometer test
cell. It is the responsibility of this person to ensure that all quality control
6-41
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Table 6-14. EPA Laboratory in Europe and Japan; Workload
and Staffing Estimates
Test, Facilities, and Staff
Number of Certification
Tests per Year
Number of Dynamometer
Test Cells
Staff
Supervisor
Emission Test Specialist
Manufacturer Liaison
Subtotal, EPA Staff
o
Operators
Total Personnel
Europe
360
2
1
2
3
6
7
13
Japan
210
1
1
1
2
4
4
8
Combined
570
3
2
3
5
10
11
21
Possibly local nationals, provided on contract basis
Exclusive of clerical
aspects of the test cell are properly followed. This includes equipment and
instrumentation operation, calibration, maintenance, and record keeping.
This person must monitor all these activities, and be able to verify at all
times that everything in the test cell is ready for a certification test, or if
not, what must be done to put it in that condition. This position is denoted
in Table 6-14 as "Emission Test Specialist. "
The "manufacturer liaison" classification is somewhat self-explanatory,
in that these personnel must coordinate certification testing with the manu-
facturers' schedules, and work on other details concerned with certification
6-42
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paperwork. One of these persons must witness each certification test and
sign it off as being a valid and properly- conducted test. These people are
also U. S. citizens and EPA staff employees.
The test operators may also be U.S. citizen EPA employees,
but would most probably be local nationals working under the supervision of
the EPA staff, and could be supplied on a contract basis from a local organiza-
tion or agency. These same comments apply to the clerical workers.
The cost estimates for this laboratory structure are shown in
Table 6-15. A brief description of the basis on which each type of charge
was computed is given in the following discussion.
Table 6-15. Cost Estimates for EPA Laboratories
in Europe and Japan
Cost Category
Staff Burden
Computer Charge
Facility Rent
Program - Support Fund
Equipment Depreciation
Total
Cost per Certification
Test
Cost Estimate, in dollars
Europe
280, 000
36, 000
200, 000
24, 000
20, 000
560, 000
1560
Japan
172, 000
21, 000
140, 000
14, 000
10, 000
357, 000
1700
Combined
452, 000
57, 000
340, 000
38, 000
30, 000
917, 000
1610
6-43
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The staff burden was based on a fixed dollar rate salary for
each position (exclusive of clerical). The salary rate used was chosen to
be 10 percent higher than the comparable figure used in conjunction with the
EPA Ann Arbor testing laboratory. Computer-related costs were assumed
to be fixed at $100 per test. In practice, data reduction procedures and costs
may vary considerably for a small laboratory at a foreign location. The
fixed rate assumed here is intended to reflect one reasonable alternative.
The estimate for facility rental was arrived at on the basis of a comparable
dollar figure per test cell, as that allocated at the Ann Arbor facility. The
program support fund is an overhead related item, and it was based on an
equivalent rate as that allocated to the Ann Arbor testing function. The
equipment depreciation value applies primarily to emissions test equipment
and instrumentation, and was again selected on a comparable basis to that
attributed to the EPA Ann Arbor testing laboratory.
It is seen that, by this method of accounting, the total cost to
perform 570 certification tests in these two foreign laboratories is approxi-
mately $917, 000,or $1610 per certification test. The equivalent figure for
EPA Ann Arbor testing (using a similar accounting system) is approximately
$1000 per test to perform about 3100 certification tests annually. The
higher cost per test of the foreign laboratories is a result of the inherently
lower personnel and equipment utilization efficiency in a small facility com-
pared to that of a much larger one. The analysis performed herein indicates
that not until the volume of testing can justify at least three or four test
cells per test laboratory that costs per test could become significantly closer
to the Ann Arbor level.
The cost of the laboratory certification program for 17 inde-
pendent laboratories (including four in Europe and one in Japan) may be
estimated for a staff of seven inspectors plus one supervisor at an annual
burden rate of $50, 000, plus travel costs of approximately $61, 000 per year,
to yield a total annual cost of approximately $461, 000.
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The cost of certifying just the four European and one Japanese
independent laboratories as part of the overall laboratory certification pro-
gram is estimated to be approximately $156, 000 per year. Thus, the pro-
portionate share of staff burden attributable just to the foreign laboratories
is approximately 30 percent, or an annual burden of approximately $120, 000.
The travel cost allocable to the foreign laboratories is approximately $36, 000
per year.
6-45
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APPENDIX A
SIGNIFICANT MEETINGS AND COMMUNICATIONS
(Telecons except as noted. Many follow-ups with
information by mail, not separately recorded. )
Part 1 - Federal Aviation Agency
Date
Office and Function
Personnel
Contacted
4 April
and
9 April
1974
National Office, Flight Standards Division
Management Branch
Leo Clark
David Custiss
March -
May 1974
Western Regional Office,
Flight Standards Division
Los Angeles, California
Meeting on 4 April plus several telecons
John Winder
Joe Hornsby
Ben Wells
March -
May 1974
Santa Monica General Aviation
District Office
Santa Monica, California
Visit of 12 March plus several telecons
W. L. Hawk
C. C. Sargent
Helen Jacobs
6 March
and
2 April
1974
Long Beach General Aviation
District Office
Long Beach, California
E. V. Curry
W. Spooner
March -
April 1974
Records and Testing Branch,
General Aviation Section
Oklahoma City, Oklahoma
Separate offices contacted for:
written exam preparation, flight ratings,
exam grading, exam printing
Mr- Phipps
Stewart Robinson
Robert O'Neil
W. P. Duer
John Freeman
9 April
and
1 5 April
1974
National Office for Training of
Aviation Technicians
Oklahoma City, Oklahoma
Telecon plus meeting at Los Angeles
Keith Teas ley
9 April
and
10 April
1974
Northrop Institute of Technology
Aviation Technician School
Telecon plus visit
Anthony Vai
A-l
-------
APPENDIX A, Part 1 (Continued)
Date
Office and Function
Personnel
Contacted
12 April Los Angeles Trade-Technical College
1974 (Part of L. A. Community College System)
Training of aviation maintenance
technicians
Office Staff
18 April Attended annual meeting of ATEC
1974 (Aviation Technician Educational
Council) at Los Angeles
Presentation by
Dr. David Allen,
U.C.L.A., re survey
for FAA on occupational
status of aviation
technicians
Part 2 - Other Agency Contacts
19 April Atomic Energy Commission
29 April Office for Licensing of Operators for
31 July Nuclear Power Plants
1974 Bethesda, Maryland
Paul Collings, Chief
March - California Bureau of Automotive Repair
May 1974 Sacramento, California
A. Winston, Manager
Mary Jeters
Howard Posner
5 March California Department of Public Health
and Laboratory Field Service
March - Licensing of clinical laboratories and
May 1974 clinical laboratory technologists
Los Angeles Office and
Berkeley (main) Office
Charles Lange
Barbara Ralston
Jean Puffer
Rodney Hamblin
1 April Pennsylvania State Police Headquarters
1974 Harrisburg, Pennsylvania
Enforcement of Vehicle Safety
Inspection Program
Capt. Robert Dunham
April - Pennsylvania Department of Transportation
May 1974 Bureau of Traffic Safety
Harrisburg, Pennsylvania
Administration of Vehicle Safety
Inspection Program
Mrs. Z. Luft,
Assistant Chief
A-2
-------
APPENDIX A, Part 2 (Continued)
Date
Office and Function
Personnel
Contacted
22 March New Jersey Department of Education
14 June Trenton, New Jersey
1974 Handling vocational instruction of auto
mechanics for New Jersey Department of
Environmental Protection
Tom McKenna
4 March California Air Resources Board
1974 El Monte, California
Contact was in relation to former
GARB laboratory certification activity.
Gerhard Haas
A-3
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APPENDIX B
APPLICATION FOR INITIAL LABORATORY CERTIFICATION
Sub-Part Rating: A (light duty vehicle, gasoline fueled)
Test Procedure: 1975 Model Year Vehicle
There are many requirements which a certified laboratory must
meet, specified in Part 85 of Title 40, Code of Federal Regulations (40
CFR 85), eub-parts A and N. These requirements are all incorporated by
reference in this application. It is the responsibility of the applicant to be
familiar with the current promulgations of each sub-part. Certification,
if granted, is based on the postulate that the laboratory follows these pro-
cedures of 40 CFR 85 exactly, except as may be described otherwise in
this application.
Accordingly, it is imperative that the applicant laboratory describe
any such procedural differences in the application. If there is no part of the
application form which covers a particular variance, the applicant should
describe the variance on a separate sheet and attach to the completed
application. Failure to comply with this requirement may result in denial
or suspension of certification.
B-l
-------
A. General Laboratory Operation
i. a. Name of laboratory (exactly as desired on certificate)
b. Address
2. Ownership
a. Type (corporation, institute, association, governmental
entity, etc.)
b. Exact name of corporation, institute, association, etc. ,
owning or controlling laboratory
c. Name and title of person(s) authorized to represent laboratory
in all transactions with the Administrator.
d. List name6 of all members of board of directors, or other
controlling group
3. Business Activity
a. Brief history of lab. This should be one,or at most a few
paragraphs, delineating the main steps in the origin of the
laboratory and its major evolutionary changes (if any) to its
present state
b. Enclose financial statement, or other information, showing
basic financial status of laboratory. This may consist of
information normally distributed for this purpose to directors
or shareholders
c. Describe approximate level of emissions measurement
activity for
(i) facility for which this application is made
(ii) all laboratory operations of parent organization (if
applicable)
B-2
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4. General Facility
a. Brief description of physical plant, and its location
b. Provide approximate overall inventory of emission test
equipment, such as number of dyno test cells suitable
for certification testing of the sub-part rating applied for
c. Approximate number of personnel at the facility for which
this application is made
d. Does local law, or laboratory policy, or any other condition,
forbid or render impractical, the right of entry of EPA in-
spectors as described in 85,l306(b)?
Yes O
No O
If answer is yes, describe the nature of the law or other
hindrance to this right of entry
B. Certified Personnel
List all operators certified by the Administrator for certification
testing of the sub-part rating for which this application is made
Name Certificate Date of Certification
Number Expiration
B-3
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In the following equipment sections of the application, each
item applies to all of the equipment of that type to be used in certification
tests. Thus, the section on CVS pump calibration must cover all the
CVS pumps which the applicant proposes for use in certification testing.
The applicant must utilize some form of in-house identification numbering
(I. D. ) system in each case. The purpose of this I. D. system is to provide
a simple unambiguous designator for each key equipment item as requested
in the application form. This I. D. number is to be used in all further
correspondence between the laboratory and the Administrator, and forms
part of the certification conditions. The I. D. number must be traceable,
in laboratory records, to manufacturer, model number, and serial number,
or any other designation required to completely define a specific piece of
equipment. This in-house numbering system may, for example, be keyed
to each separate dynamometer test cell.
B-4
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C. Exhaust Emissions Measuring Equipment
1. Exhaust Gas Handling System
a) Provide schematic drawings patterned after Figures A 75-1 and
A 75-2 of 40CFR85. for each test cell, if applicable. Show
and label all of the following component* used:
valves (schematic must indicate type of valve, i.e., flow
control, flow selector, check, relief, etc. )
filters
pumps
blowers
flow meters
pressure gages and manometers
temperature probes
sampling probes
quick disconnect fittings
Two schematics are required:
i) Exhaust Gas Sampling System, which must show all components
from vehicle tailpipe, to exhaust of CVS pump to atmosphere,
including dilution air inlet and bag'samples.
ii) Exhaust Gas Analysis System, which must show all components
from the sample bag to the sample vent to atmosphere from each
analyzer. It must also show valving arrangement for admitting
zero, span, and calibration gases to each analyzer.
If either or both schematics of (i ) and (ii) are identical in every
respect to those of figure A 75-land A 75-2, respectively, this
may be 60 stated, and that schematic deleted. In this case,
all components of the deleted schematic must be numbered in
accordance with Figure A 75-1 or A 75-2.
B-5
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b) Itemized Component List
List each item of paragraph a), showing
part number on schematic
type of component (i.e., valve, needle; pump, bellows; etc. )
manufacturer
model number, including in-hou*e L D. fop CVS pump
materials of construction for all parts which contact the
sample stream prior to analysis, including "o" rings, valve
seats, filter material, etc.
specify materials used for all tubing, hoses, and ducting
c) CVS Pump Calibration
i) Is procedure of Appendix III, Part 85, Sub-part A followed
exactly ? Yes Q
No Q
If answer is no, describe method used, giving schematics,
equipment list, and detailed procedure
ii) Enclose most recent calibration curve, including a tabulation
of the coordinates of each calibration point.
d) CVS System Verification
i) Procedure used
(1) propane injection Q
(2) CO injection Q
(3) Critical flow device Q
(4) Other Q
If blocks (3) or (4) checked, describe detailed procedure
used, including schematics and equipment list.
ii) Enclose results of most recent verification
B-6
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2. Gas Analysis Instruments
a) instrument Inventory
i) List each instrument to be used in certification tests, giving
1. type of gas analyzed
2. manufacturer
3. model number
4. in-house I. D.
5. any significant in-houee modifications of sample train or
electronics
ii) Refer to Reference A, which is a listing, by manufacturer
and model number, of all analyzers approved by EPA for
certification use. Only instruments listed in Reference A may
be used in certification tests
iii) Enclose most recent calibration curve(s) for each analyzer listed
in sub-paragraph 2. a) (i). This must include a tabulation of the
coordinates of each calibration point.
3. Calibration and epan gas inventory
a) List each gas used in conjunction with any analyzer which is to be
utilized in certification tests
This listing should show analysis gas, diluent, manufacturer, manu-
facturer's reported analysis and tolerance, concentration measured by
EPA (if applicable), cylinder size, and in-house I. D.
Indicate those cylinders which are primary NBS reference materials,
or traceable to within 1% of NBS reference materials
b) Procedure used for naming gases
Appendix Vin, Subpart N D
Other (describe on separate sheet
B-7
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4. Data Link
a) Identify manner in which the analyzer response (calibration,
zero and span, and sample measurement) is recorded in a
permanent form
recorder j |
digital printer I t
computer printout | )
other (specify) l"~|
Provide manufacture and model number of equipment used
b) If a computer printout is used '.
i) provide functional block diagram of signal path from analyzer
to computer printout. This should be in sufficient detail to define
the number and kind of signal processing steps involved, i.e. ,
A/D conversion, digital data transmission, multiplexing, etc.
A brief written description should accompany the diagram, to
prevent ambiguity in following the signal processing.
ii) describe procedures for calibrating and/or verifying proper
functioning of the data link, and the frequency at which these
procedures are performed
B-8
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D. Dynamometers
1. Inventory
List each dynamometer to be used in certification tests. This
should include
a) manufacturer and model no. and in-house I. D.
b) basic design or performance parameters
i) roll and frame
roll diameter
roll axial spacing
maximum vehicle axle weight
ii) power absorption unit
type (water brake, etc)
power absorption range - preferably include curves
of maximum and minimum absorbed power vs dyno
speed
iii) inertia simulation unit
type (flywheel, etc. )
range of vehicle inertia simulation list incremental
inertia selection values, if applicable
c) describe any significant in-house modifications
2. Calibrations in each case, give calibration schedule; describe detailed
procedures including schematics, plots, and equipment list, as
appropriate
a) torque readout
b) roll speed
B-9
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c) dyno friction
If procedure of Appendix II, Pa.it 85, sub-part A is followed
exactly, this may be so stated with no additional description
required
E. Evaporative Emissions Measurement
1. Canister. Provide dimensioned schematic drawings of the activated
carbon traps in use. If the canister is identical to that of
85-075-21, this may be so stated and the drawing deleted
2. Balance (for weighing activated carbon trap)
manufacturer
model no.
calibration procedure and schedule
F. Vehicle Preparation
1. Driving Schedule (for 1 hour pre-test drive) show route, mileage,
typical speeds, proximity to lab
2. Temperature controlled soak rooms
Give free floor space, available for test vehicle soaking, which
is temperature controlled as specified in 85.075-12 and -13.
G. Fuels Handling
1. Storage
a) specify the delivery unit in which fuel is received from the
supplier, i.e. , 55 gallon drum, tanker truck transfer to holding
tank, etc. If more than one delivery unit is used, specify for
each type the approximate percentage of total annual fuel received
B-10
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b) specify the storage unit from which fuel is routinely drawn
for lab use, if this is different from the delivery unit defined
above
2. Temperature and Venting Control of Storage Vessels ;
Specify for each type of storage listed in G 1. a) and b), for each
of the following conditions
a) long term storage between withdrawals
b) short term, prior to and during withdrawal
3. Provide a detailed schematic of fuel plumbing from delivery unit
to dispensing point in lab
4. Describe procedures used to clean and/or purge fuel supply system
in the case of a change in fuel type
B-ll
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APPENDIX C. INDEPENDENT TEST LABORATORIES DATA
O
i
Table C-l. Emission Test Capability of Independent Laboratories
Part 1 - Information acquired from domestic independent laboratories
Date
18 July
1974
18 July
1974
18 July
1974
19 July
1974
18 July
1974
Organization
Automotive En-
vironmental
Systems, Inc.
Automotive
Research
Associates
Automotive
Testing
Laboratories
General Envi-
ronments Corp.
(formerly Gen-
eral Testing
Laboratories)
Olson Labora-
tories, Inc.
Personnel
Contacted
Jim Sachtschale
Larry Smith
Douglass
Liljedahl
John Kochis
Jerry Coker
Location of
Laboratory
7300 Bolsa Ave.
Westminster, Calif.
92683
10723 Indianhead Blvd.
St. Louis, Mo. 631 32
5404 Bandera Road
San Antonio, Texas
78238
19900 E. Colfax
Denver, Colorado
6840 Industrial Road
Springfield, Virginia
22151
Harrwood, Virginia
421 E. Cerritos Blvd.
Anaheim, Calif.
11665 Levan Road
Livonia, Mich. 48150
216 - 14th Street, NW
Atlanta, Georgia
1601 A Harmer
Levittown, Penna.
Emission Test Capability
1 dyno, 1 CVS, 1 gas
analysis
1 dyno, 1 CVS, 1 gas
analysis
2 dyno, 2 CVS, 1 gas
analysis (used in common to
both test cells)
2 dyno, 2 CVS, 2 gas
analysis
2 dyno, 1 CVS, 1-3/4 gas
analysis
1 dyno, 1 CVS, 1 gas
analysis
3 dyno, 3 CVS, 1 mass gas
analysis (used in common to
all test cells) plus 1 volu-
metric gas analysis
2 dyno, 2 CVS, 2 gas
analysis
1 dyno, 1 CVS, 1 gas
analysis
1 dyno, 1 CVS, 1 gas
Facility
Classifi-
cation '2)
A
A
B
C
C
A
D
C
A
A
-------
Part 2 - Laboratories not contacted during this program; information on
emission test capability obtained from other sources
O
i
IN)
Organization
South-west Research Institute
MIRA (Motor Industry Research
Association)
UTAC (Technical Union of
Automobile, Motorcycle, and
Cycle Industries)
Location of
Laboratory
8500 Culebra Road
San Antonio, Texas
78284
Nuneaton, England
(80 air miles NW of
center of London)
Montlhery, France
(18 miles S. of Paris)
Emission Test Capability
1 dyno, 1 CVS, 1 gas
analysis
2 dyno, 1 CVS, 2 gas
analysis
1 dyno, 1 CVS, 1 gas
analysis
Notes to Parts 1 and 2
(1)
Facility
Classi-
fication
(2)
(2)
Emission test capability applies only to LDV testing. The equipment referred to is
that suitable for 1975 FTP, sub-part A; either presently in use or attainable from
equipment and instrumentation on hand.
Many of these laboratories have extensive supporting and auxiliary equipments which
are not listed here.
These are standardized facility classifications used in determining EPA certification
workload. See Table 6-1 for definitions.
C
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
EPA-460/3-74-019
2.
3. RECIPIENT'S ACCESSIOONO.
4. TITLE AND SUBTITLE
LABORATORY CERTIFICATION PROGRAM
IMPLEMENTATION ANALYSIS
5. REPORT DATE
October 1974
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S) ~~~
M. G. Hinton, W. B. Lee, T. lura, and J. Meltzer
8. PERFORMING ORGANIZATION REPORT NO.
ATR-74(7329)-!
9. PERFORMING ORGANIZATION NAME AND ADDRESS
The Environmental Programs Group
Environment and Urban Division
The Aerospace Corporation
El Segundo, California 90245
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-0417
12. SPONSORING AGENCY NAME AND ADDRESS
EPA, Office of Air and Water Programs
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
Ann Arbor, Michigan 48105
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
An analysis was made of the work task activities that would be required of an EPA
group in the process of implementing a program whereby independent testing
laboratories (and their test operators) would be certified as to their capability to
perform vehicle exhaust emission tests. The results indicate that a laboratory
certification group consisting of seven inspectors and one supervisor is adequate
to perform the certification activities for 17 laboratories and 34 operators (two
operators at each laboratory) which were assumed to be early applicants to the
proposed certification program. These laboratories were composed of 12 in
the continental U.S. , 4 in Europe, and 1 in Japan. The work task activities
examined included all functional tasks required for initial and renewal certifica-
tions as well as on-going quality control of both laboratories and operator.s.
The total annual cost of such a laboratory certification program was estimated
to be approximately $460,000 (including travel costs).
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATI Field/Group
Air Pollution
Test Laboratories
Test Operators
Certification
Costs
Air Pollution Control
Emission Testing
Certification Functions
Staffing Requirements
Management Organization
05 A
13 B
14 B
3. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
3F PAC
230
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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