ENVIRONMENTAL LABORATORY ADVISORY BOARD (ELAB)
Face-to-Face Meeting/Teleconference: 866-299-3188/9195415544#
Hyatt Regency Albuquerque, Albuquerque, NM
January 22, 2018; 1:00 - 3:00 p.m. MST
MEETING SUMMARY
The U.S. Environmental Protection Agency's (EPA) Environmental Laboratory Advisory Board
(ELAB or Board) face-to-face meeting was held on January 22, 2018, as a session at
the 2018 Forum on Environmental Accreditation in Albuquerque, New Mexico. The agenda for
this meeting is provided as Attachment A, a list of meeting participants is provided as
Attachment B, and action items are included as Attachment C. The official certification of the
minutes by the Chair or Vice-Chair is included as Attachment D.
OPENING REMARKS, ROLL CALL, MISSION STATEMENT AND OVERVIEW OF
BOARD GOALS
Dr. Henry Leibovitz, Chair of ELAB, welcomed the members and guests to the meeting. He took
roll of the members present and attending by teleconference. Ms. Lara Phelps, Designated
Federal Official (DFO) for the Board, participated via teleconference.
Dr. Leibovitz explained that the Board operates under the Federal Advisory Committee Act.
ELAB's mission is to provide consensus advice, information and recommendations on issues
related to enhancing EPA's measurement programs and facilitating the operation and expansion
of a national environmental accreditation program. ELAB provides this advice, information
and/or recommendations to the EPA Administrator, EPA Science Advisor and/or Forum on
Environmental Measurements (FEM).
APPROVAL OF DECEMBER MINUTES
Dr. Leibovitz asked whether any members had comments about the Board's December 2017
minutes; none were offered. Ms. Deb Waller moved to accept the minutes; Ms. Patty Carvajal
seconded the motion. The Board unanimously approved the December minutes. Dr. Leibovitz
explained that all past Board minutes are published on ELAB's website.
UPDATES FROM THE DFO
Ms. Phelps reported that she has accepted a new position in the Agency as the Deputy Division
Director of the Air and Energy Management Division within the National Risk Management
Research Laboratory (NRMRL). She is working with Mr. Thomas O'Farrell, ELAB's new DFO,
to ensure that the transition is as smooth as possible. Work to publish all of ELAB's past
products and any relevant EPA responses on the Board's website will continue.
This is a membership drive year for the Board; a Federal Register notice will be published in the
near future to announce the call for members. Those Board members who have not served their
maximum allowed terms and are interested in serving again will need to inform EPA in writing
of their continued interest. ELAB members also are encouraged to make suggestions regarding
those who may be interested in serving on the Board.
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EPA has updated its meeting system; the new call-in number and passcode will take effect for
the Board's February meeting. Although it is not standard protocol, to help ensure that interested
parties can find the information, the new call-in credentials will be published to ELAB's website.
Ms. Phelps' phone number and email address remain the same.
Dr. Leibovitz thanked Ms. Phelps for her 14 years of service to ELAB and read the letter of
appreciation for her service that the Board drafted to send to the Principal Deputy Assistant
Administrator for Science for the Office of Research and Development at EPA. Dr. Dallas Wait
moved to accept the letter and send it to EPA; Mr. Brad Meadows seconded the motion, which
was approved unanimously. Ms. Phelps noted that it has been an honor and a pleasure to work
with ELAB through the years.
ACTIVITIES SINCE AUGUST 2017
Since ELAB's last face-to-face meeting in August, the Board and its Task Groups have
completed the following:
• Met with EPA staff and The NELAC Institute (TNI) Whole Effluent Toxicity (WET)
Testing Expert Committee members to discuss TNI recommendations (August 2017).
• Followed up with the participant who introduced the issue of microwave extraction of
polychlorinated biphenyls at the August face-to-face meeting, explaining that this is
covered in Method 8082A (September 2017).
• Provided recommendations to the Agency on how to increase access to the Drinking
Water Certification Officer's Training Course (October 2017).
• The Cyanide Methodology Task Group met with Mr. Dan Hautman and other Office of
Water (OW) staff to discuss EPA's response to ELAB's cyanide methodology
recommendations and developed a response to the Agency (November 2017).
• Established two new Task Groups on (1) user-generated library acceptance criteria and
(2) addressing emerging contaminants (November 2017).
• Received and is considering EPA's response to the April 2017 letter on selected ion
monitoring (SIM; December 2017).
CURRENT TASK GROUP UPDATES
The Board possesses broad expertise and works on a variety of topics identified by ELAB
members, the Agency or the environmental laboratory community. The Board addresses these
topics through temporary Task Groups. The Task Group leaders or their representatives provided
a report of current topics/activities.
The following Task Groups are on hiatus or awaiting input: Drinking Water Certification
Officer's Course (awaiting feedback from an October 2017 letter), In-Line and On-Line
Monitoring (asked to provide future input on revised Method 334), and Interagency Data Quality
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Task Force/Data Quality Objective Process (awaiting the scheduling of a future task force
meeting).
WET Testing
Dr. Leibovitz explained that the Board had been approached in early 2016 by the TNI WET
Expert Committee, which had asked ELAB to critique a white paper concerning the quality
assurance aspects of WET proficiency testing (PT) and possibly provide a letter of support for
TNI's recommendation. ELAB generally agreed with the theme of the white paper, as expressed
in its May 2017 letter to EPA. Staff from EPA's OW and Office of Enforcement and Compliance
Assurance are exploring options regarding PT parameter consistency and reporting requirements;
the Agency would like to continue to engage with TNI and/or ELAB on this issue. The TNI
WET Expert Committee is holding a session at the forum the following morning.
Cyanide Methodology
In the absence of Dr. Mike Delaney, Ms. Waller explained that EPA's response to ELAB's letter
on this topic was received in July 2017 and shared at the Board's August 2017 face-to-face
meeting. The Board appreciates the discussions its members have had with Mr. Hautman. EPA's
letter was referred back to the Task Group, which met and drafted a response to the Agency.
That letter was discussed by the full Board and approved for submission to EPA in early January
2018, after Dr. Michael Shapiro's (EPA) successor has been announced.
ELAB noted EPA's agreement that some approved drinking water cyanide methods and required
preservation can lead to false positives for some samples in which cyanide forms in the sample
or during testing. This is a significant problem because detected results must be reported in the
public water supply's (PWS) Consumer Confidence Report (CCR). ELAB appreciates that EPA
should not overstep state regulations that may be more stringent than the corresponding federal
regulations; however, the Board believes that this issue should be addressed by EPA sooner than
the next Six-Year Review of Drinking Water Standards. Although ELAB appreciates EPA's
desire to avoid regulation by guidance, the Agency already has issued CCR guidance documents
to states and PWSs, and these could be updated to address the issue.
To be proactive, EPA could prepare a "Frequently Asked Questions" (FAQ) webpage or update
Cyanide Clarification of Free and Total Cyanide Analysis for Safe Drinking Water Act (SDWA)
Compliance. This guidance also should inform laboratory certification officers, PWSs and their
laboratories of the flexibility afforded by section 4.5 in Method 335.4: "Other compatible
procedures for the removal or suppression of interferences may be employed provided they do
not adversely affect the overall performance of the method." EPA guidance and the FAQ
webpage also should note the flexibility allowed in the Standard Methods and other approved
methods.
ELAB also requests that EPA confirm that the "at or above" language in 40 CFR 141.151(d)
("For the purpose of this subpart, detected means: at or above the levels prescribed by
§141.23(a)(4) for inorganic contaminants'') means that unless a state has adopted a stricter
required minimum reporting limit, states and EPA should accept laboratory results with reporting
limits at or above the "detection limits" stated in 40 CFR 141.23. Laboratory certification
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officers, PWSs and their laboratories would benefit significantly from this information, as it
would preclude the need to report results less than EPA's stated practical quantitation limit for
cyanide of 100 micrograms per liter. This is the approved practice in California.
The Board appreciates the opportunity to continue this discussion with EPA, and ELAB asks the
Agency to let the Board know if additional information or clarification is needed.
SIM
In Dr. Delaney's absence, Dr. Leibovitz summarized that the Board's goal for this effort had
been to help to define minimum criteria for SIM methods. Initially, the Board requested a
dialogue with EPA through the FEM that would allow the Board to provide input on potential
issues that had been identified and to support the objective of producing data of known and
documented quality. The FEM provided a favorable response, and a Task Group was established
to address the issue. The Task Group met several times with external SIM experts to focus on the
Board's approved motion to develop reasonable criteria for the control of SIM and work with
EPA to collaboratively develop criteria for SIM analysis that can be incorporated into commonly
used methods or standards. ELAB approved the minimum criteria developed by the Task Group
and sent them to EPA in April 2017. The Agency recently responded with detailed comments
and suggestions for the minimum criteria.
EPA's letter contained 8 pages of comments and clarifications plus a reprint of EPA research on
SIM gas chromatography (GC)/mass spectrometry (MS) for air toxics analysis (Pleil et al. 1990.
Journal of the Air & Waste Management Association 41(3):287-293.) EPA discussed the
minimum criteria at a FEM meeting and solicited comments from subject-matter experts. Staff
from EPA's Office of Air and Radiation, Office of Land and Emergency Management, Office of
Resource and Conservation Recovery, OW's Office of Science and Technology, National
Exposure Research Laboratory, NRMRL, and Region 7 provided input. Generally, EPA was
"very supportive of having some minimum criteria for SIM methods" but noted that its programs
have differing needs. The Agency asked ELAB to "provide a revision to the minimum criteria."
In its feedback, EPA provided a number of editorial suggestions, as well as 7 pages of technical
suggestions about background/definitions, personnel, method flexibility, type of MS, MS tuning
criteria, number of scans per peak and scan descriptors, SIM acquisition parameters, sensitivity,
retention time windows, identification and identification verification criteria, automated peak
detection, and other criteria that have not been mentioned.
The Board agreed that the letter and minimum criteria should be sent back to the Task Group to
address EPA's comments.
Mr. Jerry Parr (TNI) commented that the initial demonstration of capability (IDC) under the
personnel suggestion is a trivial point because IDC is something that is done before samples are
run, but there are no samples yet. Mr. David Speis (Retired) agreed, adding that this was an
unusual set of criteria from the Agency. He suggested that the Task Group meet with EPA staff
to discuss and prioritize the criteria because if the Board attempts to address all of them, it will
be an arduous task that will not be overly helpful to the environmental laboratory community.
Mr. Parr agreed.
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Dr. Richard Burrows (TestAmerica Laboratories, Inc.) noted that a thesis on SIM analysis is not
needed; rather, three to four bullets or one short paragraph should be developed that provides
guidance for methods that do not mention SIM. Dr. Leibovitz explained that this was the Board's
original intent. EPA's comments were specific, and Dr. Leibovitz agreed that key criteria are
important. Data validators do not have clear guidance to determine the quality of the data
generated by SIM; laboratories need clear criteria they must meet when asked to perform SIM so
that the quality of the data is known. Dr. Burrows agreed, reiterating that the goal is not to
bypass current methods but to provide guidance for methods that do not have any SIM guidance
whatsoever. Dr. Leibovitz noted that the Task Group would examine the criteria, determine
which criteria meet all program needs, and focus on those. Dr. Burrows was unsure why program
specificity is an issue. Dr. Leibovitz could not speak for the programs, but he noted that they
have different data uses that may prompt different requirements.
User-Generated Library Acceptance Criteria
Dr. Brian Buckley explained that the Task Group still is in the exploratory phase and had met via
teleconference to discuss whether users could develop their own libraries for quality evaluation
of data and whether quality analysis could be separated from quantitative analysis, recognizing
that the breadth of the National Institute of Standards and Technology (NIST) library can never
be duplicated. The Task Group members thought that the effort is possible if EPA is willing to
suspend current tuning criteria, ELAB can present a compelling case for evaluation criteria to
ensure quality without sacrificing the existing methodology, and a standard approach to
determining the criteria and demonstrating why the chosen criteria were selected can be
established (i.e., if EPA specifies how laboratories set their criteria vs. the Agency specifying the
criteria).
Quantitative analysis is amenable to the development of user-generated libraries, although
qualitative analysis is not because of the breadth of the NIST library. Each laboratory has the
potential to create a rigorous set of criteria that EPA would examine and approve. Perhaps NIST
criteria can be used to determine how to make user-generated libraries compatible in terms of
cross-validation or cross-comparison of compounds.
The Task Group discussed whether to focus on any type of MS or focus on GC only and
determined that, to keep the task manageable, the initial focus would be on GC. Other
applications—and their different ionization sources—can be considered after the efficacy of the
GC criteria have been proven.
In determining whether this effort is worthwhile, the Task Group noted that the community will
benefit from being able to use the full capacity of laboratory instrumentation and from not being
required to meet tuning criteria that do not allow instruments to be run optimally. The focus of
the effort should be on general day-to-day analyses that do not involve unknown identification. It
is appropriate for ELAB to explore this issue because any comments would be focused on
current, recognized MS methods and demonstrating the limits created by the current tuning
requirements rather than on developing new methods.
The Task Group will determine whether EPA is willing to suspend the current tuning criteria and
would be amenable to this effort. Dr. Buckley asked the participants for their input.
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Mr. Parr commented that he had personally generated approximately 500 spectra in the NIST
library using the DFTPP tuning criteria. Cholesterol was used for the quality control (QC) check
(i.e., very soft loss of water to show the source is clean). In his experience, the cholesterol check
is a good criterion for ensuring that the spectrometer is working correctly, which is necessary.
Dr. Buckley thought that cholesterol would be an ideal QC requirement for certain classes of
compounds and agreed that evaluation criteria must be included to demonstrate instrument
performance.
Addressing Emerging Contaminants
On behalf of Ms. Sharon Mertens, who leads this Task Group, Dr. Leibovitz explained that this
Task Group recently was established to explore potential interim actions that EPA can take to
address emerging contaminants and compounds of concern that do not have specific analytical
methodology for regulation prior to the rule-making process. This issue is important because not
only are new contaminants emerging, but also because new technologies allow the identification
of the presence of contaminants in amounts that could not be detected previously. He cited the
recent example of per- and polyfluoroalkyl substances, commonly known as PFAS.
OPEN DISCUSSION/NEW ITEMS
ELAB also is working on the following issues and may establish Task Groups as necessary:
• Encouraging the drinking water program to adopt the most recent approved methods
similar to the wastewater program and NELAP laboratory requirements.
• Clean Water Act Analytical Methods: Method 624.1, Section 9.7—Acrolein, which was
introduced to the Board by Mr. Scott Siders (Illinois EPA) and Dr. Burrows, who had
concerns regarding the preservation requirement in the field.
• Revisions to Appendix B—Method Detection Limit (MDL) Procedure as Applied to
Drinking Water, which was brought to ELAB's attention through a request from TNI via
a memorandum.
In regard to the MDL issue, Mr. Parr explained that although the two technical issues described
in the TNI memorandum are concerns, the greatest concern is the use of the word "should,"
which could cause all 10 EPA regions and 50 states to have different interpretations. One
consistent approach is needed.
Mr. Michael Flournoy and Dr. Leibovitz explained that EPA has asked the American Council of
Independent Laboratories (ACIL) to help coordinate and perform a method validation study for
the proposed new draft of EPA Method 3050C (an update to Method 3050B for the Acid
Digestion of Sediments, Sludges and Soils). The objective is to validate the proposed revisions to
3050C via simultaneous direct comparison to the performance of 3050B for a number of
analytes. A minimum of 10 volunteer laboratories that routinely use Method 3050B will be
prequalified to participate in the study through the review of their certifications of accreditation.
Laboratories interested in participating may contact Dr. Agustin Pierri (Week Laboratories, Inc.)
at agustin.pierri@wecklabs.com no later than March 1, 2018.
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Mr. Bob Wyeth (Independent Consultant) noted that numerous issues exist with methods and
wondered whether user-generated libraries and SIM criteria were the most important issues for
ELAB to consider. He requested that the environmental laboratory community bring forward
more practical topics that can be addressed relatively quickly and help to improve commercial
laboratory data quality. Most commercial laboratories do not use SIM or user-generated libraries,
which tend to be used in more research-oriented efforts.
Dr. Burrows noted that EPA has improved Methods 608.3, 624.1 and 625.1, but additional issues
exist and improvements still are needed. He requested that the Board consider establishing a
Task Group to develop a proposal that EPA further revise and improve these methods during the
next Method Update Rule (MUR).
Mr. Parr explained that an effort had been underway since the release of the previous MUR.
EPA's response to questions about why the Agency had not made certain requested QC criteria
changes to methods was that EPA did not have the interlaboratory performance data to support
the changes. To address this, TNI contacted the Association of Public Health Laboratories
(APHL), Water Environment Federation (WEF) and ACIL. TNI, APHL, WEF and ACIL have
finalized a letter proposing that the Agency work with the four associations, which will provide
EPA with any data that it requests at no charge so that the Agency can update QC criteria. In
working on Dr. Burrows' request, ELAB can note that industry is offering the data that EPA
needs to improve these methods.
Dr. Leibovitz explained that EPA is looking for matrices to conduct a validation study for an
improved method for polychlorinated biphenyl congeners in wastewater. He also explained that
Dr. Shapiro has retired from the Agency and no longer acts as the FEM Coordinator. Many of
the Board's letters have been addressed to Dr. Shapiro, and ELAB is waiting to determine who
will take his place to ensure that future letters are guided to the appropriate recipients.
As this is most likely Ms. Kristen LeBaron's (The Scientific Consulting Group, Inc.) last face-to-
face meeting with ELAB, Dr. Leibovitz recognized her for her service to the Board over the
years. The Board members and Ms. Phelps added their appreciation.
REVIEW ACTION ITEMS/CLOSING REMARKS/ADJOURNMENT
Ms. LeBaron reviewed the action items identified during the meeting, which can be found in
Attachment C.
Citing no additional comments or issues, Dr. Leibovitz asked for a motion to adjourn. Mr. Jeff
Loewe made the motion, which Mr. Meadows seconded. The Board unanimously approved the
motion, and the meeting was adjourned at 2:33 p.m.
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Attachment A
ENVIRONMENTAL LABORATORY ADVISORY BOARD (ELAB)
Face-to-Face Meeting/Teleconference: 866-299-3188/9195415544#
Hyatt Regency Albuquerque, Albuquerque, NM
January 22, 2018; 1:00 - 3:00 p.m. MST
AGENDA
1:00 - 3:00 p.m. Opening Remarks, Roll Call, Mission Statement and Overview of Board
Goals
Discussion/Approval of December 2017 Minutes
Updates From the Designated Federal Official
Activities Since August 2017
Current Task Group Updates
Open Discussion/New Items
Review Action Items/Closing Remarks/Adjournment
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Attachment B
PARTICIPANTS LIST
Board Members
Attendance
(Y/N)
Name
Affiliation
Rhode Island State Health Laboratories
Y
Dr. Henry Leibovitz (Chair)
Representing: Association of Public Health
Laboratories
N
Dr. Michael (Mike) Delaney
(Vice-Chair)
Massachusetts Water Resources Authority (MWRA)
Representing: MWRA
Y (via
teleconference)
Ms. Lara Phelps (Outgoing
DFO)
U.S. Environmental Protection Agency
Representing: EPA
Y (via
Mr. Thomas O'Farrell (Incoming
U.S. Environmental Protection Agency
teleconference)
DFO)
Representing: EPA
Y (via
teleconference)
Dr. Kim Anderson
Oregon State University
Representing: Academia—Oregon State University
Y (via
teleconference)
Dr. Brian Buckley
Rutgers Environmental and Occupational Health
Sciences Institute
Representing: Academia and Laboratory—Rutgers
Y
Ms. Patricia (Patty) Carvajal
San Antonio River Authority
Representing: Watershed/Restoration
Y (via
teleconference)
Eurofins Environment Testing USA
Mr. Michael Flournoy
Representing: American Council of Independent
Laboratories
N
Dr. Keri Hornbuckle
The University of Iowa
Representing: Academia—The University of Iowa
Y (via
teleconference)
Dr. Deyuan (Kitty) Kong
Chevron Energy Technology Company
Representing: Chevron
Y (via
teleconference)
Mr. Jeff Loewe
NiSource, Inc.
Representing: Industry—NiSource, Inc.
Babcock Laboratories, Inc.
Y
Mr. Brad Meadows
Representing: Commercial Laboratory— Babcock
Laboratories, Inc.
Y (via
teleconference)
Ms. Sharon Mertens
Milwaukee Metropolitan Sewerage District
Representing: The NELAC Institute
Y (via
teleconference)
Dr. Mahesh Pujari
City of Los Angeles
Representing: National Association of Clean Water
Agencies
Y (via
teleconference)
Mr. Elan Rieser
Con Edison
Representing: Utility Water Act Group
Y (via
teleconference)
Dr. A. Dallas Wait (Chair)
Gradient
Representing: Consumer Products Industry
Y
Ms. Debra (Deb) Waller
New Jersey Department of Environmental Protection
(NJDEP)
Representing: State Government—NJDEP
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PARTICIPANTS LIST (CONT)
Contractors and Guests
Attendance
(Y/N)
Name
Affiliation
Y
Ms. Kristen LeBaron (Contractor)
The Scientific Consulting Group, Inc. (SCG)
Y (via Adobe
Connect)
Mr. Travis Bartholomew (Guest)
Texas Commission on Environmental Quality
Y (via Adobe
Connect)
Ms. Mary Boden (Guest)
Nebraska Public Health Laboratory
Y
Dr. Richard Burrows (Guest)
TestAmerica Laboratories, Inc.
Y (via Adobe
Connect)
Ms. Nasreen DeRubeis (Guest)
Unknown
Y
Ms. Judy Morgan (Guest)
Pace Analytical Services
Y
Mr. Jerry Parr (Guest)
The NELAC Institute
Y
Mr. David (Dave) Speis (Guest)
Retired
Y (via Adobe
Connect)
Ms. Jennifer Thoreson (Guest)
Minnesota Pollution Control Agency
Y
Mr. Bob Wyeth (Guest)
Independent Consultant
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Attachment C
ACTION ITEMS
1. Ms. LeBaron will finalize the December meeting minutes and send them to Ms. Phelps via
email.
2. Ms. LeBaron will finalize the letter of appreciation for Ms. Phelps' service so that it can be
sent to EPA.
3. The Board will consider Dr. Burrows' suggestion regarding the 600-series methods.
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Attachment D
I hereby certify that this is the final version of minutes for the Environmental Laboratory
Advisory Board Meeting held on January 22, 2018.
Signature, Chair
Dr. Henry Leibovitz
Print Name, Chair
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