[ARCHIVED Proposed 310 CMR 4.00 & 310 CMR 42: Timely Action Schedule and Fee Regulations and Certification and Operation of Environmental Analysis Laboratories (2007 - 2) March 2007]

MassDEP received comments from one individual, David Knowlton of Nashoba Analytical, LLC in Littleton, Massachusetts.

Comment:  The commenter proposed an additional separate fee for the certification of several anions that are analyzed by ion chromatography methods.

Response:  Under Mr. Knowlton's proposed fee schedule, some labs may pay a smaller fee than under the present structure if they use ion chromatography for several anions, but laboratories using ion chromatography for only one or two anions would pay a higher fee than they do now.

MassDEP is not changing its current certification structure under which laboratory certification fees are grouped according to analytes and groups of analytes, rather than by methods or analytical techniques.  Laboratories may be certified in one or more methods for each analyte for one fee.  Some of the analytes are present in both potable water and non-potable water matrices for one fee.  Fees reflect the average amount of time and effort MassDEP spends reviewing details of the method(s) employed by the laboratory, standard operating procedures for each method, and proficiency tests associated with each analyte and method.   

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