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Home My WebLink About#481-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 481 Laboratory Name: SGS North America, Inc. Inspection Type: Commercial Maintenance Inspector Name(s): Todd Crawford, Dana Satterwhite, Gary Francies Jeff Adams, David Livingston, Tonja Springer Chet Whiting Inspection Date: July 19, 2011 Date Report Completed: August 17, 2011 Date Forwarded to Reviewer: August 17, 2011 Reviewed by: David Livingston Date Review Completed: August 19, 2011 Cover Letter to use: ___ Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: August 19, 2011 Date Forwarded to Alberta: August 25, 2011 Date Mailed: August 25, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: SGS North America, Inc. ADDRESS: 5500 Business Drive Wilmington, NC 28405 CERTIFICATE #: 481 DATE OF INSPECTION: July 19, 2011 TYPE OF INSPECTION: Commercial Maintenance AUDITOR(S): Todd Crawford, Dana Satterwhite, Gary Francies, Jeff Adams, David Livingston, Tonja Springer and Chet Whiting LOCAL PERSON(S) CONTACTED: Jeanie Milholland I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. The system for traceability of standard and reagent preparation is effective, thorough and easy to follow. Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload and holding times. Finding E is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: Add space to the Chain of Custody (COC) to document the applicable regulatory program (e.g., NC Aquifer Protection Section). Comment: While reviewing data for SW -846 Method 8151, it was observed that only one out of six data review sheets had been completed by the reviewing analyst. A. Finding: The form on which dry weights are calculated for VPH analysis does not contain units of measure. Requirement: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. The date and time BOD and Coliform samples are removed from the incubator must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H). B. Finding: Units of measure are not documented on the Thermometer Calibration Record (form M125.0310082), the Temperature Tracking sheet or Balance Tracking sheet. The units of measure are considered pertinent information. Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a) (7) (A). Page 2 #481 SGS North America, Inc. General Quality Control C. Finding: No policy is in place that requires the North Carolina Wastewater/Groundwater Laboratory Certification group to be notified when samples which do not meet sample collection, holding time, or preservation requirements are received and analyzed. Requirement: At any time a laboratory receives samples which do not meet sample collection, holding time, or preservation requirements, the laboratory must notify the sample collector or client and secure another sample if possible. If another sample cannot be secured, the original sample may be analyzed but the results reported must be qualified with the nature of the infraction(s) and the laboratory must notify the State Laboratory about the infraction(s). The notification must include a statement indicating corrective actions taken to prevent the problem for future samples. Ref: 15A NCAC 2H .0805 (a) (7) (N). D. Finding: Standard Operating Procedures (SOPs) are not being reviewed and/or updated annually. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H .0805 (a) (7). Submit the updated SOPs for review by December 31, 2011. A written response is required. Comment: The facility’s SOP on writing SOPs specifies an annual review. This is also a NELAC requirement. E. Finding: Laboratory reagent blanks for Metals analysed on 06/20/2011 and 06/26/2011 were observed to exceed 50% of the reporting limit. Requirement: For analyses requiring a calibration curve, the concentration of method and reagent blanks must not exceed 50% of the reporting limit, unless otherwise specified by the reference method. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Comment: SOPs commonly state that blanks should be less than the reporting limit. Mercury – SW-846 Method 7470A Mercury – SW-846 Method 7471B F. Finding: The Initial Calibration Verification (ICV) standard concentration is not at the mid-point of the calibration curve. Requirement: The initial calibration verification (ICV) standard is prepared by the analyst (or a purchased second source reference material) by combining compatible elements from a standard source different from that of the calibration standard, and at concentration near the midpoint of the calibration curve. Ref: EPA SW -846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods; 3rd Edition, Method 7000 B. Rev. 2, February 2007, Section 7.10. Requirement: After initial calibration, the calibration curve must be verified by use of an initial calibration blank (ICB) and an initial calibration verification (ICV) standard. The ICV standard must be made from an independent (second source) material at or near midrange. Ref: EPA SW -846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods; 3rd Edition, Method 7000 B. Rev. 2, February 2007, Section 10.2.1. 1,2-Dibromoethane (EDB) – SW-846 Method 8011 G. Finding: The BFB surrogate is only being monitored for detection and the percent recovery is not being calculated. Requirement: The surrogate recovery data (Sec. 8.6) should also be used to evaluate the data. Recoveries of both matrix spike compounds and surrogates that are outside of the acceptance limits suggest more pervasive analytical problems then problems with the recoveries of either matrix spikes or surrogates alone. Page 3 #481 SGS North America, Inc. Ref: EPA SW -846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods; 3rd Edition, Method 8000 B. Rev. 2, December 1996, Section 8.5.5. Requirement: It is necessary that the laboratory evaluate surrogate recovery data from individual samples versus surrogate recovery limits developed in the laboratory. The general considerations for developing in- house acceptance criteria for surrogate recoveries are described in Sec. 8.7. Ref: EPA SW -846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods; 3rd Edition, Method 8000 B. Rev. 2, December 1996, Section 8.6.1. Metals – SW-846 Method 6010 C H. Finding: Boron, Molybdenum Strontium, Tin and Titanium are not mentioned in the initial calibration section of the Metals SOP. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7). IV. PAPER TRAIL INVESTIGATION: No paper trail performed. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendations will help this lab to produce quality data and meet certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all findings. Report prepared by: Todd Crawford Date: August 17, 2011 Report reviewed by: David Livingston Date: August 19, 2011