Edward W. Pickering, President,
Independent Testing Laboratory Association
The Engineering Center
One Walnut Street
Boston, MA 02108

Wesley E. Stimpson, President,
Licensed Site Professional Association
One Walnut Street
Boston, MA 02108

February 3, 1998

RE: "Certificates of Proficiency" for the VPH/EPH Round Robin Studies

Dear Mr. Pickering and Mr. Stimpson:

This correspondence is in response to letters each of you wrote to the Department expressing your organization's opposition to DEP issuing "Certificates of Proficiency" to laboratories who successfully used the VPH/EPH analytical methods during the Round Robin Studies.

Before the VPH/EPH inter-laboratory method validation process began, DEP invited all laboratories certified by Massachusetts to participate in the VPH/EPH round robin studies. As you are aware, participation in the VPH/EPH project was not without its costs. Laboratories had to pay upfront for the first round robin samples they received and analyzed, and throughout both of the round robin analyses, had to expend a considerable amount of staff time, supplies, and valuable instrumentation time for this project. Recognizing the level of commitment necessary for participating in the study, DEP offered as an incentive for participation a "Certificate of Proficiency" to qualifying participants. Without this added incentive DEP believed that an insufficient number of labs would participate in the study.

DEP has surveyed the 27 labs that participated in the Round Robin Studies and has received responses back from 22. Nine labs wanted their certificate and another twelve said they want a Certificate if anyone else gets one. Only one lab said they do not want a Certificate. Based on this survey, 21 out of 22 participants want their certificate. We also understand that participating laboratories who were deemed proficient are already using their round robin results for marketing purposes. Therefore, we will stand by our commitment to recognize qualifying participants in the Round Robin Studies.

However in response to your comments, the document has been renamed as a "Record of Proficiency", to minimize any confusion with the more formal DEP laboratory certification program that the word "certificate" could imply.

Finally, all participating laboratories should be aware that DEP has received a request pursuant to the Public Records Law to disclose the names and identification numbers of those laboratories referenced in the Fall 1997 Round Robin report. As indicated to you last fall before the 2nd Round Robin began (letter September 15, 1997), the second Round Robin effort was NOT designed as an anonymous study, and each submittal bears the name of the laboratory providing the data.

The Public Records Law requires state agencies to disclose, upon request, all records and data that do not fall into very narrow categories of "confidential" information. We do not believe that the 2nd Round Robin Study falls into any of these categories for which information may be withheld and will honor the disclosure request.

I want to thank you for your organizations continued interest and participation in the development of the Waste Site Cleanup Program, and specifically for your assistance to this program and the Division of Environmental Analysis in the research, development and implementation of the VPH/EPH approach.

Sincerely,

[Signature on Original]