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 The 14th Annual Waste Testing and Quality Assurance Symposium, sponsored by the USEPA's Office of Solid Waste and Emergency Response and the American Chemical Society, was held July 13-16, 1998. Several short courses were scheduled during the symposium, including: "Analytical Strategy for the RCRA Program," "Clean Chemistry for Trace Elemental Analysis," "Quality Systems, PBMS and NELAC: Putting It All Together," and "Intro to Practical Ethics for Environmental Labs." Most of these short courses were well-attended, and several had more participants than planned. However, it was announced that only eight (8) people had signed up for the Lab Ethics workshop, and the workshop was cancelled!

This failure to draw more people was even more glaring when Joseph F. Solsky, a chemist with the US Army Corps of Engineers in Omaha, Nebraska, presented a paper in the Tuesday morning Organics I Session entitled "Questionable Practices in the Laboratory." He stated most people in the industry know about practices that "clearly involve the deliberate direct manipulation and/or alteration of data, often to achieve or meet method QC criteria." These include "dry-labbing," "peak-shaving, "peak-enhancing," and "time-traveling." Dr. Solsky focused on questionable practices such as:

• Lab Standard Operating Procedures or Quality Control Plans that contain incorrect (false, misleading) statements
  
• Initial 5-point calibration curves constructed by "picking and choosing" the best from 8 or more different responses
  
• Averaging the % Difference across all target analytes. even when several exceed the Continuing Calibration Verification criteria
  
• Narrow acceptance ranges for Laboratory Control Samples and wide ranges for Matrix Spike samples are reported, but the actual laboratory control charts show significantly different ranges
  
• Detection limit studies analyzed eight or more samples, then discarded points to achieve a lower MDL with the best seven.

The practices noted in Dr. Solsky's presentation, and others contributed by attendees (picking the cleanest of multiple method blanks to report, for example) combined with the cancellation of the Lab Ethics short course, were some of the hottest "hallway" topics during the symposium. Why are these questionable practices, as well as the obviously fraudulent activities, performed at labs? What can be done about it? The following comments may stimulate your response:

Dr. Solsky said there may be several reasons why labs use questionable practices:

• An entire generation of analysts is familiar with "prescriptive" methods and contract specifications, but not necessarily the science behind them
  
• The labs face market pressures such as commodity pricing, industry over-capacity, and difficult client expectations
  
• Labs using "low-ball" prices to "get a foot in the door" don't cover real analytical and reporting costs, and may cut corners on quality

Were there only eight signups for the short course because everyone else already knew of the problems, and addressed them? Or did they not want to know? Or were they afraid if they signed up for the course, they would be perceived as "having a problem" and be shunned? Did everyone read and heed the Inspector General's report "Laboratory Data Quality at Federal Facility Superfund Sites?" An excerpt follows: "Federal facilities have experienced serious problems with the quality of laboratory analyses used to make cleanup decisions. There is evidence these problems are widespread." To illustrate:

Extensive laboratory fraud was found at one laboratory, which was used by 28 DOD installations in three EPA regions, resulting in about $5 million dollars of lost data, resampling costs, and associated expenses. EPA suspended another laboratory for improper analyses. This laboratory did work at five DOD sites in two EPA regions. One of these sites was Hunters Point Naval Shipyard, where $2.5 million of data from this laboratory and another laboratory was deemed unusable and the cleanup was delayed 2 years. DOE had problems with laboratory analyses at its Hanford and Fernald Superfund sites. Fraudulent laboratory analyses were alleged at Hanford, one of the nation's largest environmental cleanup sites. Further, approximately $240,000 of laboratory analyses were rejected at its Fernald site. Additional laboratory analyses, costing about $3.2 million could not be used for their intended purpose at Rocky Mountain Arsenal, Luke Air Force Base, Travis Air Force Base, and Sacramento Army Depot because of laboratory quality issues. Moreover, the cleanup of one operable unit at Travis Air Force Base was delayed more than 2 years.

What horror stories, questionable practices, even fraudulent activities can you describe? What happened, what was the impact on the people and the data quality? Most important, what can be done to detect, correct, and prevent abuses? Should there be mandatory lab employee ethics training as part of EPA analytical contracts? Should there be industry workgroups who address these problems? Should laboratories who self-report such abuses and practices be penalized as harshly as those caught covering them up? How should an employee be treated from such a lab, one who didn't know about these practices, or believed they were acceptable?

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