Procedural Manual For The Environmental Laboratory Accreditation Program
Procedural Manual For The Environmental Laboratory Accreditation Program
Procedural Manual For The Environmental Laboratory Accreditation Program
Environmental Laboratory
Accreditation Program
September 2010
Publication No. 10-03-048
Publication Information
This manual is available on the Department of Ecology’s website at
https://fortress.wa.gov/ecy/publications/SummaryPages/1003048.html
This document replaces the 2002 version of this manual, Publication No. 02-03-055.
Contact Information
Lab Accreditation Unit
Washington State Department of Ecology
PO Box 488
Manchester, WA 98353-0488
Phone: (360) 871-8840
Web site: https://ecology.wa.gov/Regulations-Permits/Permits-certifications/Laboratory-
Accreditation
Communications Consultant
Washington State Department of Ecology
Olympia, WA 98504-7600
Phone: (360) 407-6764
Any use of product or firm names in this publication is for descriptive purposes only
and does not imply endorsement by the author or the Department of Ecology.
If you need this document in a format for the visually impaired, call 360-407-6764.
People with hearing loss can call 711 for Washington Relay Service.
People with a speech disability can call 877-833-6341.
Procedural Manual
for the
Environmental Laboratory
Accreditation Program
by
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Denying, Suspending, or Revoking Accreditation ............................................................37
Denying Accreditation .................................................................................................37
Suspending or Revoking Accreditation .......................................................................37
Recognition of Accreditation by Third Party.....................................................................39
Appeals ..............................................................................................................................40
Enforcement .......................................................................................................................41
Ecology Assistance to Labs ...............................................................................................42
Special Requirements for Drinking Water Certification Officers ....................................43
Appendices .........................................................................................................................44
Appendix A. Glossary and Acronyms ........................................................................46
Appendix B. Summary of Requirements to Use Accredited Laboratories .................52
Appendix C. Contacts at the Washington State Department of Ecology ...................54
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Purpose of This Manual
This manual explains procedures for implementing the Washington State Environmental
Laboratory Accreditation Program, administered by the Washington State Department of
Ecology. The manual provides guidance to laboratories participating in the program and
to users of data from these laboratories.
• Increase fees to meet the actual costs of conducting business. Our new fee structure
aligns fees with the level of services required to accredit different types of labs.
• Clarify the grounds for revoking or suspending accreditation so that our rules
expressly state that suspension or revocation can occur for failure to pay mandatory
fees and for failure to maintain third-party accreditation.
• Eliminate reciprocity agreements with other states and the exemption provisions for
certain wastewater discharge laboratories.
A revised rule addressing the above issues became effective on September 9, 2010. This
version of the Procedural Manual for the Environmental Laboratory Accreditation
Program recognizes those revisions.
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This page is purposely left blank
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Introduction
This manual explains procedures for implementing the Washington State Environmental
Laboratory Accreditation Program. The program was established under provisions of
RCW 43.21A.230 and satisfies the intent of RCW 43.20.020.
All enforcement actions are based on Chapter 173-50 WAC or on rules requiring the use
of accredited laboratories. Chapter 173-50 WAC does not require labs to be accredited.
This requirement is in other state, federal, or regulatory agency rules. Other documents
such as permits, grants, or contracts also may stipulate that analytical data come from
accredited labs. Requirements for use of accredited labs are summarized in Appendix B
of this manual.
• The lab's quality system, staff, facilities and equipment, test methods, records, and
reports have been evaluated.
• The evaluation indicates the lab has the capability to provide accurate, defensible
data.
Accreditation does not authorize use of a specific method for any specific program or
project. It is the responsibility of the laboratory to ensure that methods used to analyze
client samples meet the requirements of the program or project for which the data are
intended.
Accreditation does not mean that any specific report or set of data originating in an
accredited lab is accurate or defensible. To ensure data quality, data users must require
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labs to provide sufficient evidence, usually in the form of results of quality control (QC)
tests, with each set of data.
• Process for developing a quality assurance (QA) program of the type expected in an
accredited lab and suggestions for preparing an effective QA manual.
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Requirements for Participating in the
Laboratory Accreditation Program
Initial Accreditation
To become accredited, a lab must:
Continuing Accreditation
To retain accreditation, a participating lab must:
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How to Apply for Accreditation
and Pay Fees
A lab obtains an application by contacting the Lab Accreditation Unit (see Appendix C)
or from the Lab Accreditation web site: https://ecology.wa.gov/Regulations-
Permits/Permits-certifications/Laboratory-Accreditation
For out-of-state labs that require an on-site audit for initial accreditation, the Lab
Accreditation Unit will send the lab an estimate of travel costs for the on-site audit. The
out-of-state lab must sign and return the estimate prior to scheduling the on-site audit.
After completion of the visit, Ecology will send an invoice to the lab for the actual travel
costs.
Completed applications and the associated fee should be sent to the Ecology Cashiering
Unit (see Appendix C). Payment may be made by check, money order, or purchase
order.
A list of parameters with associated analyte and method codes and a fee calculator are
available on our web site.
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Quality Assurance Manual
When a lab submits an initial application and pays the fee to the Ecology Cashiering
Unit, the lab must submit their QA manual to the Lab Accreditation Unit. The detail and
scope of the QA manual should be commensurate with the size and mission of the lab.
For example, a multi-discipline commercial lab may have a QA manual consisting of
several volumes, while a small wastewater treatment plant lab or health district water lab
may have a manual of only a few pages.
The QA manual documents how the lab ensures the quality of results reported by the lab.
QA is important during sampling and transport of samples to the lab, while samples are
being analyzed, and when data are reported. Because this is a lab accreditation program,
the emphasis in reviewing the QA manual is on the analysis of samples and reporting of
results, but documentation regarding sample management and data management is also
addressed.
The QA manual is primarily intended for use by lab personnel to ensure reliability of
results, and the manual must be readily available to analysts. Secondarily, it is used by
personnel outside the lab to gain insight and confidence in the overall QA measures used
by the lab.
Formatting a QA Manual
A standard format is not required for QA manuals to meet the requirements of Ecology’s
Laboratory Accreditation Program. The only requirement is that the manual describes
adequately the QA procedures followed by the lab.
The U.S. Environmental Protection Agency (EPA) has not specified a format for a QA
manual, but has specified requirements and content for a QA plan. Some labs have
prepared QA program plans and/or QA facility plans according to EPA guidelines. These
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plans often include standard operating procedures (SOPs), each of which instructs
someone how to perform a specific task. A QA plan can fulfill the requirements of a QA
manual, as long as it includes information on each of the elements described below.
2. Glossary
Because some QA/QC terms are not universally accepted, a list of frequently used
QA/QC terms is a necessary part of a QA manual. Appendix A is a glossary of terms as
used by Ecology’s Laboratory Accreditation Program. The Model QA Manual available
from our web site also includes an abbreviated glossary.
Large labs should include an organization chart. If organization and responsibilities are
already identified in a QA facility plan or other document, they need not be replicated in
the QA manual, but the supplemental document should be submitted for review.
5. Sample Management
This section (1) describes those aspects of sampling which relate to or are the
responsibility of the lab, (2) specifies procedures for requesting sample analyses (needed
by users of the lab) and receipt, logging, storage, and handling of samples, (3) includes
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procedures for chain-of-custody (if not in a separate SOP or appendix to the QA manual),
and (4) includes criteria for acceptance or rejection of samples submitted to the lab.
For compliance monitoring under the Safe Drinking Water Act or the Clean Water Act,
required containers, preservation techniques, and holding times are specified in the
Federal Register or Code of Federal Regulations (CFR).
6. Methods
This section lists all analytical methods used in the lab with references to published
methods. For compliance monitoring under the Safe Drinking Water or the Clean Water
Act, required methods are specified in the Federal Register or CFR.
8. Control Charts
SOPs should be written to describe the construction and use of control charts, especially
for routine analyses of check standards. An Excel program that facilitates preparation of
control charts, including instructions on its use, is available from our web site.
9. Corrective Actions
Describe the corrective actions to be taken by the analyst when QC results do not meet
criteria in the method or SOP, or when the results exceed the warning or action limits of
the control chart.
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10. Data Management
The QA manual must address:
• Data recording procedures. How are data recorded – on bench sheets, bound
notebooks, directly to computer software?
• Data reduction. How are computations done – by analyst, supervisor, computer?
• Data validation. How are data checked to ensure they are valid – by peer,
supervisor?
• Data entry. How are final data entered into the system that will generate the final
report?
For small labs, data might be copied directly to the report after validation. Most
wastewater treatment plant labs would, for example, transfer data directly from log
books or bench sheets to the discharge monitoring report (DMR) after being validated
by a supervisor.
• Data reporting. How is the final report generated – by analyst, supervisor, clerical
staff?
10. Audits
This section specifies procedures for, and frequency of, system audits and proficiency
testing. Other types of audits, such as management systems and data quality, may also be
needed for large labs. As a minimum, the audits and PT required for participation in the
Laboratory Accreditation Program should be addressed in this section.
11. Reports
This section describes the requirements for, and frequency of, reports on QA/QC to
management. For labs to be accredited for drinking water, they must adhere to the report
retention requirements found in the EPA Manual for the Certification of Laboratories
Analyzing Drinking Water.
Drinking water labs are required to address sampling in their QA manuals, if lab staff are
involved in sampling.
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Proficiency Testing
Important: To receive credit for satisfactory PT results, labs must report method and
analyte codes to the PT provider with each result. A list of parameters with associated
analyte and method codes are available on our web site.
• For accreditation in the Drinking Water category, the PT studies must be designated
by the vendors as water supply (WS) studies.
• For accreditation in the Non-Potable Water category, the PT studies will normally be
water pollution (WP) studies. However, if a lab is requesting accreditation for the
same parameter (analyte and method) in both drinking water and non-potable water, a
result from a WS study will satisfy the PT requirement for both matrices. If a vendor
does not include all analytes in a WS study that would be of interest to a lab seeking
accreditation for non-potable water, the lab might need to supplement the WS study
by ordering specific WP analytes.
• For accreditation in the Solids and Chemical Materials category, the PT samples must
be solids (e.g., Soil, Underground Storage Tank, and Resource Conservation and
Recovery Act /Hazardous Waste studies).
• For accreditation in the Air and Emissions category, the PT studies must be
designated for air samples.
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For continuing accreditation
The lab must participate in two PT studies for each applicable parameter each
accreditation year, except for microbiology and bioassay parameters where one study per
year is required. The Lab Accreditation Unit decides the availability of PTs for specific
parameters. The lab must ensure required PT samples are analyzed and that the results
are reported to the Lab Accreditation Unit.
For chemistry parameters, after an accredited lab submits two satisfactory PT sample
results and no unsatisfactory results in an accreditation year, the laboratory is required to
submit only one satisfactory PT sample result in subsequent accreditation years. This
applies as long as there are no intervening unsatisfactory PT sample results.
If the lab requests updates or changes to its Scope of Accreditation between renewals,
processing will include review of all PT results available at that time.
• Quarterly National Council of the Paper Industry for Air and Stream Improvement
(NCASI) studies.
Labs should not wait until contacted by the Lab Accreditation Unit, or until they must
apply for accreditation, to request participation in PT studies. Early participation in PT
studies will avoid delays in meeting the PT requirement for the Laboratory Accreditation
Program. Furthermore, participation in PT studies is a good idea, even for labs that are
not participating in the Laboratory Accreditation Program.
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Can water supply studies be used for accreditation of non-potable
water?
For accreditation in the non-potable water category, PT samples from WP studies should
be analyzed. For accreditation in the drinking water category, PT samples from WS
studies must be analyzed. However, if a lab is accredited for the same parameter (analyte
and method) in both drinking water and non-potable water, a result from a WS study will
satisfy the PT requirement for non-potable water as well.
Must the PT study report sent to Ecology come from the PT vendor?
No. The Lab Accreditation Unit accepts copies of PT study evaluation reports from the
lab. However, most PT vendors will send evaluation reports to the Lab Accreditation
Unit as well as to the lab.
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Should PT samples be analyzed just like routine samples?
Special procedures (i.e., procedures other than those used for routine sample analyses)
must not be used when analyzing PT samples. For example, no special calibration should
be done, and results should be calculated from a single analysis, not as the mean of
replicate analyses. Records for PT sample analyses, including raw data, are examined
during on-site audits.
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On-Site Audit
The final requirement in the accreditation process is the on-site audit by the Lab
Accreditation Unit. Unit staff may be assisted by auditors from other programs or
agencies when special expertise is required.
No on-site audit by the Lab Accreditation Unit is required when accreditation is granted
through recognition of a third-party accrediting authority such as one of the National
Environmental Laboratory Accreditation Program (NELAP) states or the American
Association for Laboratory Accreditation (A2LA).
The Lab Accreditation Unit makes advance arrangements with the lab for the on-site
audit. Routine on-site audits are scheduled for dates and times that are mutually
agreeable with the lab. The lab should be prepared to receive the auditor, or audit team
for large labs, at the arranged date and time. The audit team attempts to minimize
disruption to the normal working routine in the lab. On-site audits of a large commercial
lab may involve three (and seldom more) auditors over a period of one or two days.
Assessment of a small wastewater treatment plant lab may involve only one auditor for a
portion of a day.
Emphasis in the audit is on documentation and other evidence demonstrating the lab is
producing accurate and defensible data. Auditors examine documents to verify that all
information provided in the application and QA manual is correct. Specifically, they
verify:
• Personnel training and experience status.
• Facility features.
• Sample handling procedures.
• QA/QC procedures.
• Analytical procedures.
• Data management procedures.
Normally, the analysis of PT samples is not done as part of the on-site audit. However, if
analysis of PT samples has been identified as a problem prior to the on-site audit, the lab
may be required to analyze a PT sample during the assessment as part of the corrective
action to identify and eliminate the cause(s) of the problem.
Auditors use checklists in either printed or electronic format to document lab procedures.
These checklists aid the auditor in assuring complete and uniform evaluation of the labs.
Checklists may be sent to the lab before the on-site visit, with a request that the lab
complete the checklists and return them to the Lab Accreditation Unit. Auditors may
also request to review electronic data before the audit. If completed before the audit,
checklists are reviewed by Unit staff and used as a basis for further discussion and
clarification as necessary during the audit. This helps to minimize disruption of lab
activities during the on-site visit and saves time for all concerned.
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Typical Agenda
The agenda for a typical on-site audit is as follows:
1. The auditor(s) conduct(s) an entry briefing with the lab manager to discuss the
purpose and schedule for the audit. The lab’s QA officer should attend the briefing.
If the lab manager chooses, additional lab personnel may attend the briefing.
2. The auditor carries out the audit accompanied by appropriate lab personnel. The lab
manager or any other personnel are not expected to accompany auditor during the
visit, but may if they wish. The auditor requires access to all parts of the lab and to
all staff members having anything to do with the analytical procedures for which
accreditation is sought.
3. The auditor reviews lab records, which should be provided as requested. Records
requested may include those corresponding to:
• Samples including PT samples (e.g., records pertaining to identification,
chain-of-custody, preservation, storage, holding times, tracking).
• Analyses (e.g., methods, calibration, calculations).
• QC (e.g., blanks, check standards, duplicates, spikes, certified reference materials,
control charts).
• Data management (reduction, validation, reporting, entry, assessment).
The auditor evaluates the entire process of documentation from the time the samples
are received by the lab until the results are reported. Sampling procedures are
evaluated only if lab personnel are responsible for sampling.
4. The auditor physically examines lab equipment and facilities to determine if they are
adequate to perform the analyses requested in the application.
5. Lab personnel may be observed performing analyses. They are expected to be able to
explain what they are doing and why, as well as answer other pertinent questions.
6. If time permits and the lab so requests prior to the assessment, the auditor may
provide a training session on a QA/QC or analytical topic of interest to the lab. This
training should be arranged with the Lab Accreditation Unit when the on-site audit is
first scheduled.
7. An exit briefing is held with the lab manager and selected staff to discuss the
observations and preliminary findings of the audit. Preliminary recommendations for
resolution of problems are discussed as appropriate. For large labs, a tentative time
for the exit briefing is scheduled during the entry briefing to allow maximum
flexibility in scheduling attendance by appropriate lab personnel. The scheduled time
for the exit briefing is adjusted as necessary as the audit proceeds.
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8. After the audit, a formal report of the findings is sent to the lab. Problems are
identified, and formal recommendations for resolution made. Actions that must be
completed before accreditation can be granted are identified. If appropriate, the lab is
required to report corrective actions within a reasonable period following receipt of
the assessment report.
9. Under certain circumstances where the Lab Accreditation Unit has sufficient evidence
of a lab’s capability, accreditation may be granted before an on-site assessment is
completed. (See the Interim Accreditation section of this manual.)
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Critical Elements for Accreditation
Certain laboratory operations are critical elements for consistent generation of accurate
and defensible data. These elements are the subject of intense scrutiny throughout the
accreditation process. Deficiencies in critical elements can be the basis for denial,
suspension, or revocation of accreditation status.
For labs to be accredited for drinking water, they must adhere to the critical elements
found in the latest edition of the EPA Manual for the Certification of Laboratories
Analyzing Drinking Water. Some of those elements have been included in this manual
for the convenience of lab personnel.
Analytical Methods
An analytical method is a set of written instructions completely describing the procedure
to be followed by the analyst to obtain the required analytical result. It is essential that
the analytical method be available to, and used by, analysts at the bench level. The lab’s
capability to accurately and defensibly carry out the written method is the basis for
accreditation.
• When the lab follows a published method exactly, the method must be present in the
lab and referenced in the QA manual. If a published method is modified or
augmented in any significant way, the changes must be documented, either in an SOP
or in an appendix to the QA manual. The modifications can be recorded in a lab
notebook if the modifications were made for analysis of a specific set of samples as
opposed to being used for all analyses.
Clean Water Act methods may be modified if the chemistry of the method or the
determinative technique is not changed, but Drinking Water methods cannot be
modified. A lab must apply to EPA directly for approval of an alternate test
procedure to modify Drinking Water methods.
• SOPs are required for methods that have been developed in the lab or adapted from
sources other than those described above, such as articles appearing in the literature.
While the Laboratory Accreditation Program does not establish requirements for the use
of specific methods, auditors insist that certain methods are used when those methods are
required by state or federal regulations. The Federal Register and 40 CFR Part 136 lists
test procedures that are approved for monitoring effluents under the NPDES permit
system. The Federal Register and 40 CFR Part 141 list test procedures approved for
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monitoring under the Safe Drinking Water Act. EPA's SW-846, Test Methods for
Evaluating Solid Waste Physical/Chemical Methods, suggests methods to be used for
solids and hazardous waste. Approved Biosolids methods are listed in 40 CFR Part 503
and WAC 173-308. Accreditation for a given method does not imply that the method has
been approved for use in any specific regulatory program.
A list of parameters with associated analyte and method codes are available on our web
site.
Reports of analytical results must reference the method used for analyses. For standard
methods, the reference must be clearly stated so that the client can find and read the
method if necessary.
Modifications to standard methods must be clearly identified and explained in the report.
Copies of the SOP or lab notebook detailing the modifications should be made available
to the client on request. When in-house methods have been used, copies of SOPs
describing these methods and any modifications documented in notebooks should be
provided to the client if requested.
Following are the basic types of QC tests and an explanation of how results of the tests
are used by Ecology in making an accreditation decision. See the Glossary in
Appendix A for a definition of each of the QC tests.
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Blanks
A method blank should be analyzed in every batch of samples for most analyses. For
some analyses (e.g., pH), there is no blank. The blank is usually considered to be a test
for contamination, but it can also be used to determine that all aspects of the test have
been done properly. In the total suspended solids test, for example, failure to completely
dry the filter may lead to a positive blank which was not caused by contamination.
Consistent failure of blank analyses can be grounds for a decision to withhold
accreditation for a given test.
Check standards
A check standard should be analyzed in each batch of samples. When a check standard
from a different source than the calibration standards is analyzed and the result agrees
with the known value, the analytical system is “in control” and the analyst may proceed
with confidence to analyze other samples.
When that check standard is analyzed repeatedly, either in a single batch, or over a period
of weeks or months in several batches, the average result compared to the true value is a
good indicator of data quality. The difference between the average and true value is an
indication of bias. By calculating the standard deviation of those repeated analyses, the
analyst can get an estimate of precision. Because it can give an indication of both bias
and precision, the two components of accuracy, the check standard is arguably the most
important QC test in an environmental laboratory.
Excessive bias and/or imprecision as indicated by the average and standard deviation of
repeated analyses of a check standard can, and normally would be, grounds for a decision
to withhold accreditation for a given test.
Standard reference materials (SRMs) and certified reference materials (CRMs) are useful
in checking the entire analytical process including digestion of the sample.
Duplicates
Duplicates aliquots of samples (analytical duplicates) are analyzed to check the within-
batch variability (precision) of the analytical system in the matrix of the samples.
Analytical duplicates should be run in each batch of samples.
If duplicate samples are collected under essentially identical conditions (field duplicates),
they can be used to estimate the total variability affecting the determination.
If the precision of the check standard results indicates that the analytical system is in
control but the variability in the results for the analytical duplicates is too large, the
sample matrix may be affecting the precision of the analysis. Because the lab has little
influence over the matrix, it would be unlikely that a negative accreditation decision
would be made because of the errant duplicate results in such a case.
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Matrix spikes
Spiked samples should be analyzed to check for bias due to interference by the matrix. If
check standard results indicate that the analytical system is in control, but the matrix
spike results indicate significant bias, the matrix may be interfering with the
determination. Accreditation decisions would normally not be made based on matrix
spike results. This does not relieve the lab from attempting to find a process for
overcoming the matrix interference (such as using a different method or different
extraction technique). If a duplicate and a spiked sample are to be run in the same batch,
it is best to duplicate the spiked sample if the sample does not contain quantifiable
concentrations of the analyte. This would be done to assure the availability of two results
as a check on precision.
Sample Management
Sample management is a key element in QA and must be documented in the
QA manual. The lab is responsible for those elements of sample management over which
it has direct control. The process that results in evidence that the integrity of samples has
been maintained from the time of sampling until the analyses are completed must be
documented in the QA manual or elsewhere. The documentation must include sample
preservation and storage and complete chain-of-custody,
Data Management
Because a lab's only product is a report, and that report is generated from data that are
based on observations made in the lab, it is essential that the data be managed properly.
Without an effective data management program, a lab's data (and therefore its reports) are
not defensible, either scientifically or legally.
The following guidelines will assist labs in ensuring the defensibility of data.
• The following criteria apply for all lab records. Failure to comply with these criteria,
because the defensibility of data is at risk, may be grounds for denial, suspension, or
revocation of accreditation.
o All logbooks must be paginated before use. This may be done by hand or with a
stamping device, or by purchasing paginated logbooks.
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o A permanent record of all analysts' names, initials, and signatures must be
maintained. It may be maintained as a permanent file separate from logbooks or
on a dedicated page in each logbook. Even after an analyst leaves the lab, the
record of initial/signature must be maintained for at least as long as the lab is
required by regulation to maintain data (e.g., three years for NPDES reporting).
o All entries must be dated and initialed.
o Entries must be made in indelible ink. Pencils are unacceptable because the data
would not be legally defensible. (It is wise to remove all pencils from labs to
discourage their use.) Felt tip and "roller-ball" pens are not advisable because
entries may be obliterated by water or other solvents.
o All deletions and corrections must be crossed-out with a single line, accompanied
with the date and initials of the person making the deletion or correction. No
information can be written over or scratched out other than with a single line.
"White-out," correction tapes, and other means of correction are not acceptable.
o All logbooks must have the dates of use clearly documented on the front of the
log. When a logbook is completed, the ending date of the old log must be the
starting date of the new replacement log to eliminate any gaps in the data record.
o Records of standards preparation must be maintained. All stock standard
solutions, intermediate standard solutions, and working standard solutions must
be documented. Requirements for the recorded information are:
All pertinent compound information must be recorded. This includes all
compounds or elements in the solution, vendor and the vendor lot number,
purity, concentration (if made from a solution), amount used, and date opened.
Equations showing how calculations were made should be included. Results
must be checked for accuracy by a peer who initials and dates each section
checked. A supervisor or designated QA officer must check authenticity of
data on a regular basis.
All solution information – such as the final volume, solvent, and final
concentration – must be recorded. Include the brand, lot number, and grade of
solvents. An expiration date for the standard must be recorded when
applicable. Additional items that may be recorded are the lot number and
vendor of the solvent. When the last of a stock standard is used, the date
should be entered in the standards log.
If a standard certificate of analysis is provided by the vendor, it must be
maintained as part of the standard's permanent record.
The date the solution (working standard) is prepared and the initials of the
person preparing the standard must be recorded.
o Records of sample receipt must be maintained for all samples, including PT
samples. Requirements for sample information are:
Pertinent sample information available to the lab must be recorded in the
sample logbook. The lab must record the sampling date, type of sample
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(i.e., grab or composite), matrix, and the requested analyses. A lab sample
identification number must be assigned to the sample and, if applicable,
recorded with the client identification number.
The date and time of sample receipt must be recorded with the name or initials
of the persons receiving and relinquishing the samples. For samples delivered
by common carrier (e.g., UPS, FedEx), a copy of the bill-of-lading (shipping
bill) should be maintained by the lab. If a bill-of-lading is not provided by the
carrier (as it is not by UPS and other carriers who use an electronic record of
delivery), the lab should ask the delivery person to sign a form stating that a
given number of sample packages was delivered at a specified time.
The temperature of the samples also must be recorded, or a record made that
wet ice was still present in the cooler, to provide a defensible record that
samples received were within or outside of a required temperature range. The
condition of the sample containers (e.g., for commercial labs receiving
samples in coolers) must be noted in the sample log.
These requirements are absolute for labs supporting NPDES compliance
monitoring. If samples which require chain-of-custody management are
received from a remote location, the presence or lack of intact custody seals
must be noted.
• Equipment (hardware and software) should include a backup and recovery system to
ensure data availability in the event of a system failure.
• The LIMS must provide for archival of records for at least the period required by the
regulatory program under which data were gathered (e.g., three years for NPDES
monitoring).
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o Interpretation of LIMS error codes, if used, and corresponding corrective actions.
o Procedure for making authorized changes to correct errors in data entry.
o Maintenance of system hardware.
o Electronic reporting of data.
Only the lab can identify CBI. When doing so, the lab must mark the document or
section of a document such that there is no question concerning whether or not it is
claimed to be CBI.
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Recommended Practices
Some elements of lab operations affect efficiency, safety, and other administrative
functions but would not normally adversely affect accuracy or defensibility of analytical
data. Deficiencies in those non-critical areas are brought to the attention of lab
management under the heading of recommended practices and, individually, are not the
basis for denial of accreditation status.
Personnel
The accreditation process seeks to determine if managerial, supervisory, and analytical
personnel have adequate training and experience to allow satisfactory completion of
analytical procedures and compilation of reliable, defensible, accurate data. Personnel
requirements take into account both the size of the lab and the skill necessary to perform
the tests.
A position or job description should be available for each lab employee. The job
description is a detailed statement of the requirements of the position and should include
the following information as a minimum:
• Title and grade.
• Organizational unit and/or location of position.
• Detailed description of position duties.
• Supervision and guidance received.
Recommended training and experience for lab personnel are addressed below. They are
provided as an aid to labs in establishing criteria for hiring and training of personnel.
Special personnel requirements for staff at accredited drinking water labs are given at the
end of this section. Accredited labs must report significant changes in personnel status
(e.g., loss of a key supervisor) to the Lab Accreditation Unit within 30 days of the
changes.
Lab Director
There should be either a person in this position or a person available for consultation who
meets the requirements described below. This requirement may not be necessary for
small labs (e.g., a lab supporting a small wastewater treatment plant).
• Academic Training: Minimum of a bachelor's degree in chemistry or a biological
science. Or, if the bachelor's degree is in a field other than chemistry or a biology
science, the individual should have college-level credit hours sufficient to qualify for
a minor in chemistry or biology.
• Experience: Minimum of two years experience in an environmental lab.
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Supervisors
Minimum recommended requirements for supervisor positions are listed below. If the
supervisor is also an instrument operator, the requirements for Instrument Operators
(below) should also be met.
• Academic Training: Bachelor's degree in science that included the number of credit
hours in chemistry or biology courses required for a major in one of those disciplines.
• Experience: Minimum of one year experience in an environmental lab.
Instrument operators
Personnel operating atomic absorption (AA) spectrometers, ion chromatographs (IC),
gas chromatographs (GC), liquid chromatographs (LC), inductively coupled plasma
(ICP) spectrometers, automated or robotic analyzers, or other instruments of comparable
complexity should meet the following requirements:
• Academic Training: Bachelor's degree in chemistry or related field. This may not be
necessary if the immediate supervisor has a bachelor's degree in chemistry or related
field or if the analyst has the number of credit hours in chemistry courses required for
a major in chemistry.
• Specialized Training: Satisfactory completion of a short course offered by the
equipment manufacturer, a professional organization, university, or other qualified
training facility.
• Experience: Minimum of six months experience in operation of the instrument (see
Trainees below).
• Initial Qualification: After appropriate training, the analyst should demonstrate the
ability to produce acceptable results in the analysis of an applicable QC or PT sample.
Other analysts
Other analysts (e.g., chemistry, biology, or microbiology technicians) should meet the
following minimum requirements:
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Wastewater treatment plant operators
For wastewater treatment plants which do not have full-time analysts and where analyses
are performed by plant operators, the operators must meet the requirements of Chapter
173-230 WAC, Certification of Operators of Wastewater Treatment Plants.
Trainees
Data produced by analysts and instrument operators while in the process of obtaining
training or experience are acceptable when reviewed and validated by a fully qualified
analyst or the lab supervisor.
Facilities
Information provided on the application and obtained from the on-site audit is used to
determine if lab facilities support efficient generation of accurate, defensible data. Lab
facilities should be clean, have temperature and humidity adequately controlled in the
instrument areas, and have adequate lighting at the bench top. The lab should have
provisions for the proper storage and disposal of chemical wastes. Exhaust hoods with a
verified airflow of 75-125 cubic feet per minute should be available for procedures that
produce dangerous or offensive fumes.
For chemistry determinations, a minimum of 150 square feet of lab space and at least
15 linear feet of usable bench space per analyst is recommended. Workbench space
should be convenient to sink, water, gas, vacuum, and electrical sources. Electrical
sources should be free of surges and unanticipated outages. Inorganic and organic
facilities should be in separate rooms. Facilities used for analysis of volatile organics
should be at an overpressure relative to other lab areas. The analytical and sample
storage area should be isolated from all potential sources of contamination. Standards
requiring refrigeration (e.g., volatile organics) should be stored separately from samples.
For microbiology determinations, a minimum of 150 square feet of lab space and five
linear feet of usable bench space per analyst is recommended. Lab facilities should
include sufficient bench-top area for processing samples; storage space for media,
glassware, and portable equipment; floor space for stationary equipment (e.g., incubators,
water baths, refrigerators); and associated areas for cleaning glassware and sterilizing
materials.
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For bioassay determinations, facility requirements depend primarily on the type and
number of tests to be performed. In general, space requirements are relatively large.
Safety
Generally, safety procedures are not critical elements of the on-site audit. This does not
imply a lack of concern for safety but rather recognition that other regulatory agencies
have primary responsibility in this area. Serious safety deficiencies observed during the
on-site assessment are referred to the appropriate state or federal regulatory agencies for
follow-up.
All labs should have fire extinguishers. Fume hoods should be available if dangerous
fumes are likely to be present during lab operations. Safety glasses should be worn by
analysts and readily available for visitors. Eye washes and overhead showers should be
readily available if dangerous (e.g., caustic, acidic, otherwise corrosive) materials are
used. Lab areas likely to be wet should have ground fault protection for electrical
circuits. Material Safety Data Sheets (MSDS) should be readily available for all
chemicals used in the lab.
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Evaluation and Issuance of Certificate
Following completion of the initial on-site audit, the Lab Accreditation Unit prepares a
report describing the results of the accreditation process: application, QA manual, PT,
and on-site audit. The Unit maintains a copy of the report. The report lists findings and
describes actions required in response, and, as appropriate, makes recommendations
about resolution of problems.
• If results indicate accreditation of the lab is justified, the Lab Accreditation Unit
issues a certificate authorizing the lab to submit data to Ecology, the Washington
State Department of Health (DOH), or another data user, for those parameters
included in the accompanying Scope of Accreditation.
• If results indicate the lab should not be accredited (see the Denying, Suspending, or
Revoking Accreditation Status section of this manual), the lab is advised of:
o The specific reasons for the decision and actions required of the lab to correct the
deficiencies, or
o Other specific action required as a basis for a subsequent accreditation decision.
If the accreditation is for a lab that reports drinking water data, the DOH Drinking Water
Program is notified of accreditation actions.
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Interim and Provisional Accreditation
Interim Accreditation
When the Lab Accreditation Unit initially is not able to complete the accreditation
process for an applying lab in a timely manner, interim accreditation may be granted
based on review of the application, QA manual, SOPs, and successful completion of PT
studies where appropriate. The on-site audit is completed as soon as practical after which
a decision on full accreditation would be made.
When the on-site audit does not include complete evaluation for a specific analyte and
method (e.g., because the capability did not exist at the time of the on-site audit), the lab
may be requested to submit to the Lab Accreditation Unit a technical data package for
use in making an accreditation decision. Based on review of the data package and PT
sample analysis results, if appropriate, a decision may be made to grant interim
accreditation pending completion of the on-site audit.
The content of such data packages will vary depending on the type of data reported but
generally will contain, as applicable, complete information on the following:
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• Reports: Final report forms (e.g., data summary with reporting limits, blank
summary, matrix spike summary, surrogate summary, and QC sample summary).
Provisional Accreditation
A lab having deficiencies indicating an analytical problem, but not a complete inability to
provide reliable, accurate, and defensible data, may be given a provisional accreditation
pending resolution of those deficiencies. Under some circumstances, the Lab
Accreditation Unit will specify a date by which deficiencies must be corrected. Upon
determining that the deficiencies have been corrected, the Lab Accreditation Unit takes
action to award full accreditation. If a lab fails to correct the deficiencies within the time
period allowed, accreditation may be revoked for the affected parameters. Refer to the
Denying or Revoking Accreditation Status section of this manual.
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Accreditation Categories
Ecology’s Laboratory Accreditation Program accredits by matrix, analyte, and analytical
method.
The four matrices above are those for which the NELAP accredits labs. NELAP
accredits for a fifth matrix, tissue, which in Ecology’s program is included in the Solids
and Chemical Materials matrix.
For each matrix, environmental labs are accredited within broad technology categories.
Not all of the following technology categories apply to each of the four matrices.
• General chemistry.
• Trace metals.
• Organics I: GC, high pressure liquid chromatography methods without a mass
spectrometer.
• Organics II: mass spectrometry methods.
• Radiochemistry.
• Microbiology.
• Bioassay.
• Immunoassay.
• Physical.
Within those categories, labs are specifically accredited to analyze samples within well-
defined parameters. For example, a lab may be accredited to analyze purgeable
halocarbons using EPA Method 601 and phenols using EPA 604 under Organics I, and
dioxin using EPA Method 613 under Organics II.
Accreditation for some methods can be requested in only one of the matrix groups. For
example, all 500-series methods for organics can be requested only in Drinking Water,
and SW-846 methods can be requested only in Solids and Chemical Materials, even
though the lab may be using those methods exclusively for testing aqueous samples.
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Requirements for Maintaining Accreditation
Accreditation is granted for a one-year period (the accreditation year) and expires one
year after the effective date on the certificate. Approximately 60 days before the
expiration date, accredited labs are sent information necessary to renew their
accreditation. The laboratory should apply for renewal at least two weeks prior to the
expiration of the current accreditation.
On-site audits of drinking water labs are required every three years to maintain
accreditation. For laboratories not accredited for drinking water parameters, the schedule
of on-site audits will be determined in part by the workload in the Lab Accreditation
Unit. We will attempt to conduct on-site audits every three to four years. In some cases,
we may decide to review documentation of lab practices and capabilities in lieu of an on-
site visit.
The purpose of these audits is to determine if the lab’s capability has been adequately
maintained and to evaluate any capabilities added since the last audit. These audits
usually involve a more focused evaluation of selected analytical capabilities, based on
review of the lab's performance since the last audit.
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Denying, Suspending, or Revoking
Accreditation
Denying Accreditation
A lab may be denied accreditation (WAC 173-50-140) if any of the following apply to
the lab:
• Fails to comply with standards for critical elements of the on-site audit.
• Misrepresents itself to the department (Ecology).
• Fails to disclose pertinent information in the application.
• Falsifies reports of analysis including PT results.
• Engages in unethical or fraudulent practices concerning generation of analytical data.
• Is deficient in its ability to provide accurate and defensible analytical data.
• Fails to render applicable fees.
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Revocation of accreditation is the withdrawal of a previously granted accreditation.
Revocation may involve the entire laboratory or one or more individual parameters.
Revocation is a permanent status requiring the lab to apply, pay a fee, and go through
pertinent steps of the accreditation process including, if necessary, an on-site audit.
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Recognition of Accreditation by Third Party
Ecology may recognize accreditation by another accrediting authority of an
environmental laboratory located in Washington or out-of-state.
Labs considering applying for recognition of accreditation by a third party should contact
Ecology’s Lab Accreditation Unit before submitting an application to ascertain whether
the third party is or could be recognized by Ecology.
Labs applying for recognition of a third party’s accreditation must provide copies of the
following to the Lab Accreditation Unit:
• The Certificate and Scope of Accreditation issued by the third-party accrediting
authority.
• The accrediting agency's most recent on-site audit report.
• The lab’s corrective action report associated with that audit.
• Recent, satisfactory PT sample results.
• The lab’s QA manual.
Laboratories granted third-party accreditation must notify the Lab Accreditation Unit
immediately of changes in the status of their third-party accreditation.
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Appeals
Managers of environmental labs may appeal final accreditation actions (awards, denials,
suspensions, revocations) within 30 days of notification of that final action, in accordance
with Chapter 43.21B RCW. The Water Pollution Control Board hears and makes
decisions on such appeals. If an appeal does not result in action favorable to the
laboratory, a laboratory having had its accreditation denied or revoked may reapply for
accreditation to include payment of appropriate fees. A lab should reapply only after
correcting any deficiencies.
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Enforcement
For the purpose of conducting on-site audits or inspections to ensure compliance with the
accreditation requirements, Ecology staff may enter business premises in which
analytical data pertaining to accreditation are generated or stored. Ecology would take
this action only during the lab’s regular business hours.
Refusal to permit entry for such purposes may result in denial or revocation of
accreditation.
Organizations or persons who submit analytical data originating from a lab that is not
accredited for the procedures used to generate that data may be subject to penalty under
provisions of Ecology or DOH regulations, permits, contractual agreements, or other
regulatory instruments which require use of an accredited lab.
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Ecology Assistance to Labs
Laboratories scheduled to undergo an on-site audit may request that Ecology conduct a
training session for lab staff in conjunction with that audit. Accredited laboratories may
also request on-site assistance at times other than the on-site audit. Whether requested as
part of the on-site audit or otherwise, Ecology will provide such assistance to the extent
allowed by staff resources available at the time.
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Special Requirements for
Drinking Water Certification Officers
Lab Accreditation Unit staff acting as auditors of drinking water labs must attend EPA’s
Drinking Water Certification Officer training course. Refresher training is required every
five years. Additionally, auditors must maintain proficiency in major technologies for
which they assess labs by actually performing analyses with those technologies each
year.
The Unit will furnish an annual report to EPA Region 10 covering actions completed
regarding drinking water labs in the past year, as well as actions planned for the coming
year.
Selected Unit staff acting as drinking water lab auditors will attend an annual meeting of
certification officers (auditors) sponsored by EPA.
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Appendices
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Appendix A. Glossary and Acronyms
Glossary
Accreditation year: The one-year period as stated on the certificate of accreditation.
Accuracy: The difference between a measured value and the true value. Accuracy is
affected by both random error (imprecision) and systematic error (bias). (See Bias and
Precision.)
Action Limit: The limit on a control chart, which, if exceeded, requires corrective action
to be taken. Action limits are usually placed at ±3 standard deviations from the expected
or mean value.
Batch: A set of samples analyzed together without interruption. Results are usually
calculated from the same calibration curve or factor.
Bias: The difference between the population mean and the true value. Bias usually
describes a systematic difference reproducible over time, and is characteristic of both the
measurement system, and the analyte(s) being measured. (See Systematic Errors.)
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Blank: A synthetic sample, free of the analyte(s) of interest. For example, in water
analysis, pure water is used for the blank. In chemical analysis, a blank is used to
estimate the analytical response to all factors other than the analyte in the sample.
Field blanks are used to obtain information on contamination introduced during sample
collection, transport, or storage. Method blanks are used to reveal contamination
introduced by laboratory.
Check Standard: A solution of known concentration used to indicate bias and the
precision of an analytical system. When used in conjunction with a control chart, it
becomes a control standard. Check standards are prepared from different sources than
standards used for calibration.
Control Limits: Statistical warning and action limits calculated for control charts, used
to make decisions on acceptability of QC results. Warning limits are usually established
at two standard deviations above and below the mean of repeated analyses of a standard.
Action limits are established at three standard deviations.
Ecology Accrediting Authority: The supervisor of the Lab Accreditation Unit in the
Washington State Department of Ecology.
Holding Time: The allowed time from when a sample was taken or extracted until it
must be analyzed. For composited samples, the holding time starts when the last
composite aliquot is collected.
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Initial Demonstration of Capability: Demonstration by a lab or an analyst of the ability
to meet acceptable precision and bias objectives, and meet desired method detection
limits.
Lab Accreditation Unit: The unit in the Environmental Assessment Program of the
Washington State Department of Ecology that administers the Washington State
Environmental Laboratory Accreditation Program.
Matrix: The substance from which a sample is collected, such as groundwater, ambient
water, wastewater, air, solid, semisolid (such as tissue), or chemical compounds (such as
oil).
Quality Assurance (QA): A set of activities designed to establish and document the
reliability and usability of measurement data.
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Reference Material: A material or substance usually taken from a natural source
(such as a sediment), one or more properties of which are sufficiently well established to
be used as a check standard. Often called standard reference materials or certified
reference materials when produced by NIST.
Spike: A known amount of analyte added to a sample to reveal bias due to interference
present in the sample. The magnitude of bias is estimated as percent recovery. If the
spike is added to an environmental sample, the sample is called a matrix spike.
Surrogate Standard: A type of spike added to each sample for certain types of analyses
(e.g., trace organics), in a known amount, and at the start of the analytical process. A
surrogate compound is similar to one or more of the target analytes in the method but is
not expected to be present in environmental samples.
Warning Limit: A type of control limit specified by a value on a control chart, usually
±2 standard deviations from the mean. When a measurement result falls outside the
warning limits, there is a high probability that the analytical system is out of control and
the analyst should investigate the reason for the errant result.
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Acronyms
A2LA American Association for Laboratory Accreditation
CFR Code of Federal Regulations
DMR Discharge Monitoring Report
DOH Washington State Department of Health
Ecology Washington State Department of Ecology
EPA U.S. Environmental Protection Agency
GC/MS Gas Chromatography - Mass Spectrometry
ICP/MS Inductively Coupled Plasma/Mass Spectrometry
NELAP National Environmental Laboratory Accreditation Program
NIST National Institute of Science and Technology
NPDES National Pollutant Discharge Elimination System
QA Quality Assurance
QC Quality Control
RCW Revised Code of Washington
SOP Standard Operating Procedure
WAC Washington Administrative Code
WP Water Pollution
WS Water Supply
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Appendix B. Summary of Requirements to Use
Accredited Laboratories
Requirements for use of accredited labs are found in several documents. The oldest is
Ecology Executive Policy 1-22 which requires use of accredited labs for all water matrix
analyses other than those submitted in accordance with a wastewater discharge permit.
All monitoring data submitted to Ecology must come from accredited labs, with specific
exceptions. Tests which need not be conducted by an accredited lab are:
• Those done for process control only.
• Flow, temperature, and settleable solids.
• Conductivity and pH, if a lab operated by a discharger is not required to be accredited
for any other test.
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Stormwater Permits
All monitoring data, except for flow, temperature, pH, total residual chlorine, and other
exceptions approved by Ecology, must come from an accredited lab.
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Appendix C. Contacts at the Washington State
Department of Ecology
Mailing Address
Department of Ecology
Lab Accreditation Unit
PO Box 488
Manchester, WA 98353-0488
Physical Address
Department of Ecology
Lab Accreditation Unit
7411 Beach Drive East
Port Orchard, WA
Cashiering Unit
Mailing Address
Department of Ecology
Cashiering Unit
PO Box 47611
Olympia, WA 98504-7611
Physical Address
Department of Ecology
Cashiering Unit
300 Desmond Drive
Lacey, WA 98503-5128
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