Laboratory audits are not only a best practice but are typically mandated by consent decrees. The BWON program enhancements section of refinery consent decrees requires the auditing of laboratories that perform analyses of Benzene Waste Operations NESHAPs (BWON) samples to ensure that proper analytical and quality assurance/quality control procedures are followed. Most consent decrees require that the laboratory be audited every two years for the life of the consent decree and that audits be performed by an independent party other than the laboratory or the client who requests the analysis. Sage has audited numerous clients’ laboratories that are used to perform benzene analysis on BWON samples, in accordance with clients’ consent decrees.
Sage has developed audit protocols (in the form of checklists) for BWON laboratory audits based on National Environmental Laboratory Accreditation Conference (NELAC) principles. Our specialists ensure that appropriate aspects of quality of performance for analysis of benzene in wastewater and organic samples are reviewed and are suitable for the stated purpose. On a client’s request, we will add provisions for evaluation of specific gravity by ASTM Method D1429-03. We also can audit analytical methods for parameters other than benzene on request if such methods are within the experience and proficiency of our auditors.
We begin the laboratory audits by reviewing the laboratory Quality Assurance Manual, procedures, records, and files relevant to benzene analyses for BWON prior to the on-site auditing. Once on-site, we conduct interviews of the laboratory president, the QA/QC officer, and key employees. Next, we conduct a field verification to visually inspect the facility, including all rooms that are used in any part of the BWON sample trail (i.e., from sample receipt through storage, analysis, retention, disposal, reporting, and archiving). If requested, we evaluate the capability for specific gravity analysis for organic liquids and sludges. We complete a rigorous audit checklist based on responses to the questions asked. At the conclusion of the on-site visit, we conduct an exit interview with the laboratory.
Following each audit, Sage will present the client with a draft report and a completed audit checklist presenting any findings. All findings that are potentially noncompliant with a federal or state regulation will be provided in a simple table format that defines the deficiency and references the appropriate citation. Any recommendations for improvement based on best management practices that are not related to compliance issues are also included in a separate table and can be issued in a separate report on request. We incorporate client comments into the final report that is issued to the client for the record.
Our lead auditor for BWON laboratory audits is Mr. David Monfore, QEP, P.E. Mr. Monfore has more than 38 years of work experience and has conducted many laboratory audits. He has a bachelor of science degree in chemistry and a master of science degree in environmental science and has had numerous contacts with analytical laboratories related to samples of wastewater and groundwater.