Intersection of Environmental, Public Health, and Consumer Markets
The Guadalupe-Blanco River Authority (GBRA) is a quasi-government organization covering all things water-related in a 10-county Texas district. In addition to testing, the authority’s activities include engineering, hydroelectric power generation, and educational outreach. The authority’s water testing laboratory, directed by Josephine Longoria, analyzes drinking water, wastewater, and industrial water taken from and released to standing water and rivers, as well as water from underground sources.
As part of the national Clean Rivers Program, the lab also helps maintain water quality and health for the Guadalupe and Blanco rivers. GBRA’s customers include local water agencies and distributors, industrial companies, and individuals seeking advice on well water quality.
Longoria’s lab is accredited by The NELAC Institute (TNI), which provides certification via the National Environmental Laboratory Accreditation Program. The regulatory tangles water labs encounter arise from the alphabet soup of authorities and regulations under which they work. For GBRA these include, but are not limited to, the Clean Water Act; the Resource Conservation and Recovery Act; the Safe Drinking Water Act; and the Comprehensive Environmental Response, Compensation, and Liability Act. Texas laboratories must also deal with the Texas Commission on Environmental Quality (TCEQ), the Texas Railroads Commission, and the Texas Clean Water Act.
“Achieving TNI accreditation is expensive and time-consuming,” Longoria says. Her lab is audited every two years for quality practices. Only labs that test for customers outside their geographic domain require this qualification. “But labs should consider this level of accreditation so that test results are more trustworthy; the data is more defensible.”
Longoria practices what she preaches: When workloads or analytes fall outside GBRA’s capabilities, the samples are outsourced, but only to TNI-accredited facilities.
Testing and Sampling
Most water laboratories run what are referred to as conventional tests. For wastewater, these include biological oxygen demand, carbonaceous biological oxygen demand, total suspended solids, and others. Drinking water assays focus on microbiology; for example, total coliform analysis, fecal coliform, and E. coli. Nutrients are quantified in rivers and other potential drinking water sources. The most common are nitrates, ammonia, total phosphorus, and total organic carbon. Chlorinated water undergoes evaluation for chlorinated hydrocarbons, including tetrahalomethanes, as well as pH and residual chlorine. Pre- and post-industrial water undergo a variety of tests based on previous use or future intended use. GBRA also determines that industrial users have the proper disposal permits.
Water is as diverse as any other substance. Test goals, customers, analytes, and matrices differ widely among samples from lakes and rivers meant for drinking or recreation, water treated at municipal drinking water plants, or samples arising from municipal waste or industrial processes. Matrices can differ based on geography or proximity to industries. Hydraulic fracking, for example, has raised numerous water quality issues that were unknown a decade ago. Analytes and matrix dictate instrumentation and testing protocols. Adding a layer of regulation compounds the complexity. “You can get into the legal world very quickly,” Longoria says.
Many problems in water labs originate at the sampling site. “If you don’t sample correctly, it doesn’t matter what the lab does,” Longoria says. “Sometimes we have to train our customers on proper sampling by providing guidance, cheat sheets, and instructions on obtaining samples that best represent the site of interest.”
Some samples require preparation to remove interferences or to prolong hold times. Analyzing beyond hold-time windows automatically flags data as “qualified” or “inadmissible.”
“Hold time is huge, especially when your instrumentation decides not to work that day,” Longoria says. She advises lab managers to always have a “Plan B” in place in the event of instrument or system failure, unwieldy workflows, hold-time deadlines, or the absence of certain instrument operators.
Related advice applies to instrumentation. Outside of LC-MS, water labs do not use many exotic analyzers. Ion and nutrient analyzers tend to be robust, but they have their limits in terms of stretching maintenance schedules. “You know your analyzers have been running hard for four months straight and probably need to be shut down for preventive maintenance,” Longoria says. “Don’t wait for them to break down. Assign regular maintenance times throughout the year. Otherwise your instrument will go down at the worst time, when you’ve just received a big load of samples.”
Automating Sample Handling
Longoria strives to keep her staff of 12 abreast of the many regulatory agencies they deal with, each with a unique preferred reporting format. “A Clean Rivers Program sample must follow the quality assurance project plan for that entity. If you’re working on samples for a nearby city, we must follow the TCEQ rules and the EPA’s 40 CFR Part 136,” Longoria says.
She could not keep up with all these demands without a LIMS, she adds. GBRA has recently upgraded its LIMS. As of January 1, 2015, the lab’s information management system will be based on a product from ATL.
Customers, particularly states and municipalities, often change their report forms, but a lab’s LIMS may lack the ability to generate custom forms. Form generation is a feature lab managers need to think about when purchasing a LIMS for a water lab. Falling back on paper forms erases a good deal of the benefit of automated lab information systems.
As interviews with this month’s two laboratory managers show, a LIMS is invaluable even in small labs. “One of a LIMS’ main benefits is avoidance of human error,” says Ken Rosnack, business development manager for food and environmental at Waters (Milford, MA). “If you have to read an instrument value, copy it to a piece of paper, transcribe it to a paper notebook, and then transfer it into a data system, opportunities for transposing numbers abound.” Data volume also contributes entry points for erroneous readings and transcriptions.
Water testing laboratories rely on many individual tests that change over time through regulatory decree or with customers’ evolving needs. New instruments replace old, technicians and scientists come and go, SOPs undergo revision, and established methods fall by the wayside.
For example, many labs now test for pharmaceuticals in drinking water. “Methods and instrumentation from 20 years ago would never pick up those compounds,” Rosnack says, “but they nevertheless are known to pose long-term health risks.” A lab seeking to expand into organics/pharmaceutical testing would need to implement those protocols rapidly, store them as methods, and guide sample processing through a LIMS or its close cousin, a laboratory execution system.
“Anywhere a LIMS takes a reading–from a balance or pH meter all the way up to a mass spectrometer–any time it stores information securely, that’s a benefit,” Rosnack says. He also suggests that data be stored on an offsite server for security reasons, in case of a lab disaster.
A LIMS provides value beyond the testing laboratory. Many government labs now instruct remote technicians on proper sampling techniques. If these individuals had remote access to the laboratory’s LIMS, they could log and barcode samples as they collect them, Rosnack notes. Samples would arrive at the lab fully documented and ready for testing. “The closer to the starting point a LIMS is accessed, the better.”
A LIMS also tracks changes to existing methods and newly approved or mandated analyses, who made the change, and why. Tracking those changes and the rationale behind them is critical to regulatory compliance and meeting individual customer requirements.
Human Resource Challenges
The City of Everett Water Lab (CoEWL) (Everett, WA) began as a wastewater testing laboratory, then expanded into analysis of drinking water and solid waste samples. Water quality analyst and manager Chris Merwede’s group tests for nutrients, metals, microbes, biological oxygen demand, and total suspended solids, and utilizes other wet chemistry methods.
Merwede’s main hurdles relate to his lab’s size–five analysts including himself. Workflow bandwidth issues cause the lab to outsource organics testing and to jockey test schedules to accommodate on-hand expertise.
Short-hold tests challenge all analytical labs, but with some staff working four 10-hour shifts and others a more traditional schedule, CoEWL is forced to consider not just analytic capabilities, but coordinating sample arrival with the appropriate expertise. For example, one analyst specializes in metals, another in nutrients, while a third conducts microbiology tests.
Since bacteria may multiply or die in a very short time, the lab runs microbial tests within six hours of receiving them. Nitrites have an outside hold time of 48 hours. Dissolved metals fall somewhere in between. Samples tested for metals must be filtered on arrival to prevent metals leaching from suspended particles. After that, samples are stable.
“If someone is working four 10-hour shifts and they’re off on a day when a bacteria test sample comes in, what do you do?” Merwede asks. Regular customers usually call ahead to ensure that the correct analyst will be on the job when they deliver samples.
CoEWL maintains a vigorous cross-training program that stretches its available skill set at any particular time, but its coverage is imperfect. “You need experience with an instrument to understand its capabilities and the quirks associated with particular samples,” Merwede says. “If no one is available to test a sample, we’re forced to subcontract it out.”
CoEWL is accredited with Washington for drinking water and wastewater through the state’s Department of Ecology and Health, which luckily for the lab consists of two separate entities that have merged. Before the agencies joined forces, both audited CoEWL. Now the lab undergoes just one combined audit every two years.
With little leeway in terms of human resources, and with its manager wearing several hats, the lab relies on PerkinElmer’s LABWORKS LIMS to keep track of samples and tests. The package includes a general data report form covering what most customers need. Those requiring a specific format benefit from SAP’s Crystal Reports, which is incorporated into CoEWL’s LIMS.
Even with a LIMS, the paperwork, regulatory, and operational burdens on small water laboratories are daunting. “The many roles I must play as manager is my greatest challenge,” Merwede tells Lab Manager. “A lab of our size can’t afford to hire someone just to complete the reams of paperwork.”
While automating sample flow and assays through its LIMS certainly helps CoEWL, particularly with reporting and compliance, many assays still run in manual mode. Safety checks and occupational health-related compliance still require surveying the lab, notebook in hand, on foot. Similarly, preparing for state audits does not lend itself to automation.
Workflows do not slow when the microbiology expert is filing validation documents or the metals specialist is dealing with a troublesome customer. Managers of small labs must juggle several occupations, approaching the expert level in some instances.
Merwede is CoEWL’s de facto safety officer. As a trained chemist he is familiar with safe operation of fume hoods, but balancing the air demands of hoods plus the lab’s HVAC system required him to dig deeply into facility and engineering lore–a task he would not have to worry about at a much larger organization.
“It’s the things you don’t know about lab safety that can get you, the unknown unknowns,” he says. “Suddenly I have to be an HVAC person. ‘Jack-of-all-trades, master of none’ doesn’t apply here. In a small lab, the manager must be a jack-of-alltrades and master of many.”
Like this article? Click here to subscribe to free newsletters from Lab Manager