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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5159
Laboratory Name: Phillips Plating Co., Inc.
Inspection Type: Field Maintenance
Inspector Name(s): Todd Crawford
Inspection Date: July 21, 2010
Date Report Completed: July 26, 2010
Date Forwarded to Reviewer: July 26, 2010
Reviewed by: Jason Smith
Date Review Completed: August 2, 2010
Cover Letter to use: ___ Insp. Initial Insp. Reg. Insp. No Finding X Insp. CP
Unit Supervisor: Dana Satterwhite
Date Received: August 2, 2010
Date Forwarded to Alberta: August 3, 2010
Date Mailed: August 3, 2010
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Phillips Plating Co., Inc.
NPDES PERMIT #: NC0001881
ADDRESS: P.O. Box 336
Bridgeton, NC 28519
CERTIFICATE #: 5159
DATE OF INSPECTION: July 21, 2010
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Jerry Phillips
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 area reserved for analytical work was very cluttered. Dirty and hazardous conditions that were observed in
2008 still exist. The requirements associated with Findings C and D are new since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Housekeeping
A. Finding: The area where sample analyses are performed was dirty and cluttered to the extent that it could
affect analytical results.
Requirement: A best effort must be made to perform analyses in a manner where possible sources of
contamination or error will not be introduced. Ref: Quality Assurance Policies for Field Laboratories.
B. Finding: Old, expired chemicals are being stored in the work area. Cited previously on 12/02/08.
Requirement: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards,
consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only
listed as a month and year (with no specific day of the month), the last day of the month will be considered
the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes
may indicate potential contamination and the item should be discarded, even if the expiration date is not
exceeded. If no expiration date is given, the laboratory must have a policy for assigning an expiration date.
If no date received or expiration date can be determined, the item should be discarded. Ref: Quality
Assurance Policies for Field Laboratories.
Comment: Very old, expired chemicals are being stored in the small room where analyses are
performed. Many of the bottle labels were faded or corroded to the point that they could not be read.
Many of the chemicals were 40 or more years old. Strong acids and bases were positioned right next to
each other on wooden shelves that were severely bowed. This is extremely hazardous. This same
condition existed and was commented on in the report for the last inspection in 2008. The response to the
last inspection report stated that the “bench area was cleaned up, and the other chemicals removed”. It
did not appear to the auditor that any chemicals had been removed.
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#5159 Phillips Plating Co., Inc.
Documentation
C. Finding: The laboratory is not making corrections in an approved manner. Cited previously on 12/02/08.
Requirement: All documentation errors must be corrected by drawing a single line through the error so
that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-Out®,
correction tape or similar products designed to obliterate documentation are not to be used. Write the
correction adjacent to the error. The correction must be initialed by the responsible individual and the date
of change documented. All data and log entries must be written in indelible ink. Pencil entries are not
acceptable. Ref: Quality Assurance Policies for Field Laboratories.
D. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as
well as, documentation of standards and reagents prepared in the laboratory.
Requirement: All chemicals, reagents, standards and consumables used by the laboratory must have
the following information documented: Date Received, Date Opened (in use), Vendor, Lot Number, and
Expiration Date. A system (e.g., traceable identifiers) must be in place that links standard/reagent
preparation information to analytical batches in which the solutions are used. Documentation of solution
preparation must include the analyst’s initials, date of preparation, the volume or weight of standard(s)
used, the solvent and final volume of the solution. This information as well as the vendor and/or
manufacturer, lot number, and expiration date must be retained for chemica ls, reagents, standards and
consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre -
made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories.
E. Finding: Performance testing (PT) sample analyses are not being documented in the same manner as
environmental samples.
Requirement: The analysis of PT samples is designed to evaluate the entire process used to routinely
report environmental analytical results. Therefore, PT samples must be analyzed and the process
documented in the same manner as environmental samples. Ref: Quality Assurance Policies for Field
Laboratories.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports
(DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for January, March and May,
2010. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing
data.
V. CONCLUSIONS:
We are concerned with the findings that were cited previously and not corrected.
Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (13) and (14):
A laboratory may be decertified for any or all parameters for up to one year for any or all of the following
infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control program as set
forth in the application, and these Rules; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this Section or of a Laboratory
certification.
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#5159 Phillips Plating Co., Inc.
Correcting the above-cited findings and implementing the recommendations will help this lab to produce quality
data and meet certification requirements. Please respond to all findings.
Report prepared by: Todd Crawford Date: July 26, 2010
Report reviewed by: Jason Smith Date: August 2, 2010