STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JAN I 9 1993
OFFICE OF
SOLIDWASTE AND EMERGENCY RESPONSE
OSWER Directive 9240.0-25
MEMORANDUM
SUBJECT: Reassignment of CLP Transportation Functions
FROM: Henry L. Longest II, Director
Office of Emergency and RemedieJH^Spbnse
TO: Director, Waste Management Division
Regions I, IV, V, VII
Director, Emergency and Remedial Response Division
Region II
Director,- Hazardous Waste Management Division
Regions III, VI, VIII, IX
Director, Hazardous Waste Division
Region X
Director, Environmental Services Division
Regions I-IV, VI-VIII, X
Director, Environmental Sciences Division
Region V
Deputy Director, Office of Policy and Management
Region IX
Purpose
The purpose of this Directive is to inform you that, as of
June 1, 1993, the Office of Emergency and Remedial Response
(OERR) is reassigning the responsibility of providing
transportation of Contract Laboratory Program (CLP) sample
coolers to the Regions and the.-.r support contractors. This
Directive incorporates Regional comments received in response to
our July 2, 1992 draft, in which we requested your cooperation to
work together to reassign this function.
Background
The transportation of CLP coolers has been available to the
Regions through a national transportation contract. This
contract, which is managed by the Analytical Operations Branch
(AOB), provides a mechanism for shipping empty sample coolers
from CLP laboratories back to the originating sampling office.
-------
We believe that this function is more appropriately managed by
the contractors directly responsible for collectir.g samples
rather than by a Headquarters office. Superfund support
contractors, such as ARCS, TAT, TES, and ERGS, are already
responsible for the transportation of samples for CLP activities
and samples and coolers for non-CLP activities. In addition, the
transportation contract is used to ship Contract Compliance
Screening (CCS) reports to the Regions from the Sample Management
Office (SMO) .
On July 2, 1992, the Hazardous Site Evaluation Division
notified you of our intent, to reassign this function, and
requested comments so that any unanticipated issues could be
addressed in the Directive. We appreciate your constructive
comments and suggestions, and have addressed them to the extent
possible. The majority of Regions which responded agreed with
the Directive, and several Regions provided suggestions for
inclusion in the Directive as guidelines in implementing it.
Objective?
Transferring the transportation of CLP coolers to the
Regions will assign responsibility for program operations to the
Regions and guidance and oversight functions to Headquarters.
This shift of responsibilities is consistent with OSWER policy on
delegation of operational functions to the Regions and ensuring
that Regional personnel most aware of the quality of services
rendered are overseeing them. Regions and support contractors
will be better able to respond to local variability regarding
demand, supply, vendor availability, proximity, and price. With
regard to the shipment of CCS reports, we intend to modify the
SMO contract to enable SMO to effectively manage this function.
Implementation
We are discontinuing the national program which has provided
transportation of coolers from CLP laboratories on a centralized
j.o r*e»jr ^ a. , ±y*j. »•<=
believe the May 31, 1993 date should provide sufficient time to
enable the support contractors to establish a mechanism for
transporting CLP coolers and for your Region to address any other
related issues that may arise. We suggest that the Regional
process for oversight of non-CLP sample transportation functions
be used, or that the project officer or task monitor for the
support contract be responsible for monitoring the CLP cooler
transportation operations. From the amount required by each
Region in FY 92 to transport CLP coolers, the projected
extramural funding will be allocated to the Regions by the
Program Development and Budget staff.
-------
The Regions and their support contractors should establish
their own programs for obtaining CLP cooler transportation
services prior to May 31, 1993. The specific approach to be used
for acquiring transportation services is up to the Region;
however, guidelines on implementing this Directive are addressed
in the Appendix. Based on Regional comments, we have also added
language to CLP contracts th?>t indicates that the Regions will
assume this responsibility as of June 1, 199., including language
that describes laboratory responsibilities for managing the
coolers.
We are committed to working with you in the transfer of
responsibilities. We believe that the authorization to allow the
respective field support contractor to perform this duty can be
easily accomplished by the initiation of a taskinq document or
work assignment. In the July 2, 1992 memorandum, a copy of the
transportation contract statement of work was attached to enable
you to begin preparing for the transfer. If you have any
questions or comments, please have your staff contact Hans Crump
of the Analytical Operations Branch on (703) 603-8821.
Attachment
cc: Jerry Clifford, HSCD
Deborah Dietrich, ERD
Larry Reed, HSED
Janet Simmons, CMD
-------
APPENDIX - OSWER DIRECTIVE 9240.0-25
This appendix contains suggestions for implementing this
Directive. First, we believe that the responsibility for this
service rests with the party that collects samples - in most
cases this party is the field support contractor. Second, we do
n -. believe it wo Id be prudent to have one or more support
contractors or subcontractors in the Region responsible for
providing transportation services to all other contractors. This
could create a potential conflict-of-interest situation, whereby
some contractors would be dependent upon a competitor for their
performance. We encourage Regions to consider an approach which
fully delegates the responsibility for providing transportation
services for CLP activities to the individual responsible support
contractors, as is already the case for CLP samples and most non-
CLP transportation activities. As mentioned previously, Federal
oversight should be integrated into the Region's existing
contractor oversight program.
To avoid the possibility of developing significantly
differing procedures between contractors within each Region and
among Regions, the procedures outlined in the document Sampler's
Guide to the Contract Laboratory Program should be followed.
Additional suggestions are outlined below.
• Sampling contractors should include a completed shipping
label in the cooler which can have any coded information for
tracking purposes.
• The label should consist of multi-copies so the laboratory
and the sampling contractors can each retain one for their
records .
• The label should be designed so that the laboratory can
simply place the already-completed label on the cooler for
shipment purposes. The process should be as easy as
Litcs
The label should include third party billing information so
that the transportation carrier ir. able to invoice the
correct sampling contractor. The laboratory should be
informed of the identity of the carrier.
To avoid confusion, each Region should attempt to use only a
minimum number of different carriers.
Sufficient information should be included on the label to
enable the sampling contractor to track use of the billing
number .
------- |