The market for environmental testing laboratories has changed enormously over the last three years as a result of a seismic shift in the UK market and numerous changes in legislation. In order to survive, analytical companies have had to be adaptable, far-sighted and innovative in their provision of the comprehensive service that their clients require.
The reduction in market size, particularly with respect to soil testing (as this is heavily dependent upon a thriving construction industry), has raised the level of competition in the market and laboratories need to focus on efficiency and excellent customer service.
The environmental analysis market is generally driven by legislative requirements and a number of revisions, new standards, and EU policy documents are/will be causing changes to the industry.
Deviating (or non-conforming) samples
UKAS is the accreditation body responsible for auditing laboratories to both ISO 17025 and MCERTS (the Monitoring Certification Scheme of the Environment
Agency of England and Wales) in the UK, and they participate in the European Accreditation (EA) system concerned with the harmonisation of standards across Europe. A recent policy document issued by this organisation can be found at: www.european-accreditation.org/content/ea/europNetwork.htm
This document has now caused UKAS to raise a mandatory action for all laboratories to implement this policy with respect to deviating samples. UKAS has now issued its own statement regarding this action: www.ukas.com/media-centre/news/news-archive/2010/Guidance_on_Deviating_Samples.asp and during the last year has highlighted this issue to all laboratories during the annual audits.
Deviating (or non-conforming) samples are defined as those which may have been compromised in some way during sampling, transportation, storage or analysis, and which may cause the integrity of the data to be questioned. Examples of deviating samples include:
• No separate volatile container supplied
• Headspace present in volatile or BOD container
• No preserved bottles supplied
• Holding time exceeded
• Temperature exceeded
• No sampling date supplied (mandatory for MCERTS)
• AQC failed during run and sample cannot be repeated
• Deviation from method, e.g. limited sample size or matrix issues
If samples are found to be non-conforming upon receipt at the laboratory, the client should be informed immediately and if the testing continues, this non-conformance will be flagged in the report issued to the client.
The onus is now on the site staff to ensure samples are taken correctly, or this will impact on the integrity of their final report. This may take more time, but will ensure more robust data in the long run.
Operator Monitoring Assessment (OMA) and MCERTS for waters
In England and Wales, OMA came into effect in 2009 and MCERTS for waters in July 2010, but Phases 1 and 2 of OMA only relate to Urban Waste Waters (UWW), covering sewage treatment and water treatment works. Phases 3 and 4 will extend to trade effluents from April 2011 through to April 2012. There is a condition of consent that water companies must use MCERTS accredited companies for both sampling and analysis. Currently, there is no published timeframe for extending MCERTS to other environmental waters such as ground waters or surface waters.
The MCERTS for waters standard states that companies engaged in the sampling must be accredited. It also states a temperature range of 1 – 8°C for sample storage and includes the assertion that filtration should be performed at point of sampling. These requirements will all impact on the time involved for sampling, but again, will provide more robust data.
Prior to the implementation of OMA, much of the water analysis was performed in Environment Agency laboratories. However, it is now available for other laboratories to undertake, although much of the effluent monitoring can be performed using in line monitoring instruments. Flow monitors and automatic samplers must be MCERTS accredited and this requirement will extend to online analytical monitors as more of them become MCERTS accredited.
Environmental Protection Act revision
Revision of Part IIA of the Contaminated Land Section of the UK’s Environmental Protection Act, 1990. DEFRA and WAG are currently seeking public consultation (deadline March 16) for revising the statutory guidance (first introduced in 2000), with respect to identification, classification and remediation of contaminated land. Their aim is to update the guidance, making it fit for purpose, providing greater clarity on the meaning of SPOSH (Significant Possibility of Significant Harm) and how it should be assessed.
Part IIA is one of several ways in which land contamination can be addressed. Most contaminated land is dealt with through the planning system (although
PPS 23 is also subject to revision). Part IIA provides a means for dealing with unacceptably high risks. The regime is not intended to be used on sites where some contaminants may be present, but where there are low levels of risks.
The intention is to categorise sites according to red, amber/red, amber/green and green, ranging from sites assumed to pose SPOSH, to those assumed not to. Background and normal levels may not be included in this regime. Therefore, if it was established that a site is at, or close to background levels of contamination, it would be dismissed from further investigation and a decision taken that the land is not contaminated in accordance with the revised guidance.
It should be remembered, however, that Part IIA applies to sites that meet the definition of contaminated land and effective action cannot be achieved by either planning or voluntary action. Even within the constraints of the current economic climate, there remains a need to regenerate contaminated land and such revisions to Part IIA are unlikely to reduce the need for environmental testing of contaminated soils.
Revision of BS10175
This is the British Standard for the Investigation of Potentially Contaminated Sites – Code of Practice, which is undergoing a substantial rewrite to incorporate recent legislative changes. The previous standard was issued in 2001. The standard is now applicable to land with naturally elevated concentrations of potentially harmful substances.
The new standard will update terms and definitions with reference to BS ISO 11074:2005 soil quality vocabulary, including definitions of elements such as risk assessment, conceptual model, controlled water, hazard, soil. Normative references have been added including BS EN ISO 17025:2005, BS ISO 5667 and reference is also made to key Environment Agency guidance including the MCERTS Performance Standard and the framework for the use of rapid measurement techniques (RMT).
Laboratory references have been moved to the further reading section with respective links provided. Text has been added to state that, where appropriate, analytical methods should be MCERTS accredited for all relevant matrices.
The informative text on laboratory analysis has been updated and moved to Annex H within the guidance. The advantages and disadvantages of specific analytical techniques are summarised in Table H1. This section reaffirms the Agency’s current position on bioaccessibility testing. Annex I provides information on the suitability of sample containers. Another Annex is devoted to the growing importance of on-site screening methods, consistent with the RMT guidance.
A clearer definition of measurement uncertainty for sampling and analysis has been incorporated into Annex G. This is likely to lead to increased focus on measurement uncertainty and in particular the recognition that errors associated with sampling are generally significantly greater than those associated with analysis. Closed spaced incremental cluster samples are likely to improve the authenticity of the sample. Further reference is made to
Eurachem/EUROLAB/CITAC/Nordtest/AMC guide Measurement uncertainty arising from sampling. A minimum of eight duplicate samples is recommended to ensure that uncertainty estimates are suitably robust.
Update on WRAS guidance
UKWIR (UK Water Industry Research) recently published a document Guidance for the Selection of Water Supply Pipes to be used in Brownfield Sites, which led to the withdrawal of the Information and Guidance Note 9-04-03, Laying Pipes in Contaminated Land, WRAS 2002 (Water Regulations Advisory Scheme).
It is widely accepted that the original WRAS document was incomplete, outdated and inappropriate. There has long been a strong case for its revision, particularly to bring it in line with current risk assessment practice. The origins for the prescribed WRAS parameters can be traced back to the 1983 ICRCL threshold levels, based on gasworks’ contaminants – criterion not relevant to risk of permeation or corrosion of buried water pipes.
Fundamental problems persist with the updated UKWIR guidance, too. These have caused some issues for consultants and laboratories, and the new document may need to undergo revision in the future. The UKWIR guidance includes an extensive list of contaminants, which seems to be overkill. It refers to a staged process of investigation, involving a desk study, site walkover, preliminary risk assessment and site investigation, but defaults to a mandatory analytical suite covering:
1. VOCs 1a. BTEX and MTBE 2. SVOCs 2a. Ethers 2b. Nitrobenzene 2c. Ketones 2d. Aldehydes 2e. Phenols 2f. Cresols and Chlorinated Phenols 3. Mineral Oil C11-C20 4. Mineral Oil C21-C40 5. Corrosive contaminants (Conductivity, Redox and pH) 6. Amines (only where identified by the Desk Study)
Data assessment of the above parameters forms part of the Site Assessment Report. Data supported threshold values are used to assist in the selection of pipe materials. The document was subject to consultation within the water industry but little external consultation with the wider contaminated land community.
On first publication, the guidance included conductivity thresholds for Wrapped Steel and Wrapped Iron pipes of 40 µS/cm. The maximum admissible drinking water concentrations are ten times this value. UKWIR was forced to publish a subsequent erratum with corrected values.
The generic groups still contain compounds that do not belong within those classes (for example Benzo(a)pyrene is listed as a VOC, 1,2-Dichloropropane is listed as an SVOC). The guidance also specifies the analytical technique required for testing – there are examples were this is inappropriately prescribed.
If the new guidance remains in the current format, it could lead to much more extensive testing on contaminated sites. However, in the majority of cases, where the cost of investigation exceeds the cost of installing a particular pipe material, it is likely to lead to water companies adopting an overly conservative blanket approach and specifying barrier pipe for all Brownfield sites, regardless of site-specific levels of contaminants.
Loss of landfill tax exemption
The exemptions from landfill tax will no longer apply for contaminated soil, and this has led to a significant increase in the proportion of on-site treatment for soils. This is an area of varied techniques, depending upon the type and concentration of contamination, e.g. soil washing, heat treatment or bioremediation.
This is likely to cause an increase in testing for laboratories, as the soil should be monitored during remediation, and needs to be verified as acceptable before re-use on the site.
Changes within the laboratory
EU directives and standards constantly demand lower limits of detection. This can cause issues for laboratories, particularly with difficult matrices, such as landfill leachates.
Technology, in the guise of instrument manufacturers, attempts to bridge this gap with ever more sensitive detectors or improved sample introduction systems. However, these instruments are costly and many smaller laboratories may find difficulty in sourcing funding, particularly in the current economic climate. This in turn may lead to greater polarisation within the industry, with some laboratories focusing on specialised, expensive analysis and others concentrating on high volume throughput for more standard analyses.
It may also become necessary to obtain larger sample volumes which would result in increased costs for sample preparation within the laboratory. This is because the extraction of very low concentrations of organics from water, for example, (to avoid the affects of background contamination) is a time consuming process.
The increase in on site testing is likely to impact on the volume of samples sent to laboratories for testing. On site test kits/instruments have improved over the last two or three years, and a BS standard is now available which covers best practice. However, there are limitations with most of these methods, which may not achieve the same detection limits as laboratory analysis and still need trained staff to use them correctly. There is a high risk that they may be used incorrectly by inexperienced or untrained staff. However, they are useful in defining ‘hot spot’ areas and obviously provide rapid data, but it is difficult to gain accreditation for on site tests, due to the lack of control in their use. If accredited data is needed, laboratory analysis is required.
Electronic data handling
This area has probably seen the most significant changes over the last two or three years, and is likely to continue development. All laboratories now offer some kind of electronic reporting, and the requirement for hard copy reports has dwindled to miniscule numbers. However, it is not sufficient to just offer standard Excel spreadsheets, because consultants and contractors require a variety of formats and do not want to spend time manipulating data to fit with their reports. Examples of these are AGS, EQuiS and National Grid format, plus a standard csv file, as well as client specific formats.
It should be stressed that offering a PDF report is not an electronic data deliverable, because you cannot manipulate the data. This is often not appreciated by many people within the industry.
Currently, many consultants and contractors use AGS v.3.1, but v.4 was released in May 2009, which has much greater functionality, and Holebase is now compatible with AGSv.4. Laboratories should now be working to offer this format to their clients.
The demand for additional functionality has increased significantly and systems such as ALcontrol’s @mis, for example, offer many useful features, including:
• Data available 24/7 in real time • Reporting individual or multiple batches • Archiving data for up to six years • Setting project specific acceptance values, and automated flagging if these are exceeded • Advanced query search on sample, batch, project, location, site, or date window • Numerous reporting formats, plus vertical/horizontal conversion • Access through website – no specific software needed • Access to collection/container ordering – simple three step system
The other function offered by @mis is self scheduling, and this aspect should experience major expansion during 2011. Again using @mis, site engineers can log sample data and schedule tests via a hand held PDA or laptop (via internet connection). The container is scanned with a bar code reader, the location/reference information typed in, and sent.
This means the samples are registered at the laboratory before they arrive and can then be passed straight into the testing area, with no delays for logging in and scheduling. This can save one to two days (or longer) on the turnaround/holding times, and soggy, illegible chain of custody sheets will be a thing of the past.
Currently, only 25% of sample batches are received with correctly completed documentation and this causes significant delays to sample processing.
Case study – the Avenue Project
The advantages of recent developments in the management of sampling and analysis are exemplified at a large remediation project near Chesterfield in the UK. Covering 80 hectares, the Avenue Project is a heavily contaminated site presenting an enormous challenge to its remediation, engineering and environmental contractors.
The volumes associated with the project are unprecedented in the UK remediation sector; more than two million cubic metres of material are being excavated with a significant volume of this having to be processed. Within this more than 100,000m3 of contaminated sediments from the site’s silt lagoons are also being processed. Over the lifespan of this project ALcontrol will have tested in excess of 10,000 samples for between five and 18 species.
Soil and water analysis at the Avenue performs two key functions. Firstly, to inform the management of the treatment processes and secondly to provide verification that either treated soils meet with the required specification.
With the turnaround time for analysis a critical factor, the results for most of the analyses is required within five days in order to plan remediation activities accordingly, and Alcontrol’s technical staff have worked hard to ensure the delivery of timely analytical data with the online @mis system, exporting results in
AGS format which helps manage the enormous volume of data that is being produced.
Environmental laboratories have experienced severe pressures over the last two years, with a large drop in sample numbers due to the contraction of the construction industry and a reduction in public funding. This has led to increased competition between laboratories, with contractors and consultants putting pressure on pricing, so any advantage a laboratory can offer is vital.
The use of autosamplers on all instruments, so that they can work unattended at night, and improvements to sample handling/preparation, are essential for a laboratory to run as efficiently as possible. Shorter turnaround times with improved data handling can all assist in providing a better service to the client.
Laboratories that can offer additional services such as electronic reporting and technical support will survive the next year or so, after which time, the market will hopefully start to recover.
Hazel Davidson is the Technical Marketing Manager for ALcontrol Laboratories. She has worked for ALcontrol Laboratories for 30 years, initially as an analyst, but then in a series of managerial roles. Special projects included the integration of several laboratory acquisitions, relocation of the laboratories from Chester to Hawarden, a Phare project in Bulgaria and Romania (implementing quality systems), and a UN project involving training for Iraqi environmental scientists in Jordan. Hazel participates on several industry committees (BSI, MCERTS, SCA and EIC), is a frequent speaker at conferences, and runs several seminars each year for Alcontrol.
ALcontrol provides testing and analytical services for soil, water, food, oil, asbestos and air to help clients demonstrate compliance with regulations and achieve their health, safety and environmental goals. More than 2000 employees in 30 laboratories across 11 European countries support a global customer base providing millions of tests per year.
For further information, please contact:
ALcontrol Group Head Office Units 7 & 8 Hawarden Business Park, Manor Road, Hawarden, Deeside, Flintshire CH5 3US UK
T: +44 (0) 1244 528 700 E: [email protected] W: www.alcontrol.com
Published: 10th Mar 2011 in AWE International