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Corporate Overview Consolidated Auditing and Proficiency Testing Programs. George E. Detsis Manager, Analytical Services Program Office of Environment, Health, Safety and Security Office of Sustainability Support 2014 ASER Workshop Los Alamos, New Mexico November 4-6, 2014. Topics.
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Corporate Overview Consolidated Auditing and Proficiency Testing Programs George E. Detsis Manager, Analytical Services Program Office of Environment, Health, Safety and Security Office of Sustainability Support 2014 ASER Workshop Los Alamos, New Mexico November 4-6, 2014
Topics • Program accomplishments • Common problems -- audit findings • DOECAP lessons learned • Future considerations
Accomplishments Implemented Department of Defense (DoD)/DOE Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, and updated the Lab Audit Checklists 20 Lab Audits, which includes 1 Lab Surveillance and 4 Lab Closure Audits 8 Treatment, Storage, and Disposal Facility Audits Processed Corrective Action Plans Maintained a cadre of 134 trained volunteer auditors
Accomplishments(cont.) DOECAP TSDF Checklist Pilot – The facility completed the audit checklists in advance and self-identified deficiencies (treated DOECAP “SI” as observations rather than audit findings) Initiated a DOE Technical Standard on Lab Proficiency Testing (PT) Engaged DOE managers – Briefings on audit results/recruiting for auditor participation Analytical Services Program – FY 2013 Report
DOECAP Making a Difference • Improving Lab/TSDF Performance • Improved QA programs • Reduction/elimination of legacy waste streams • Corrective action plans that address “causal effects” to prevent reoccurrences • Improving audit report quality – findings tied to requirements, specific requirements are cited, and the supporting evidence identified by the auditors is explained • DoD/DOE Consolidated QSM improves the ability of Labs to prepare for Federal agency audits
Common Problems -- FY 2014 Lab Findings • Procedures, Procedures, Procedures • Laboratory practices/SOPs do not accurately reflect the current analytical method • Facilities lack the necessary SOPs • Employees not trained to latest/approved procedures (lack of training documentation). • Employees not following approved laboratory procedures • Procedures not updated annually • Not running quality control samples at required frequency • Not maintaining equipment (preventive maintenance) and supplies (reagents/solvents) records. • Not updating Quality Assurance Management Plan • Opening incoming sample shipments outside of a ventilation hood, which means that personnel are potentially being exposed to hazardous materials.
Common Problems -- FY 2014 Lab Findings (cont.) • Performing calculations associated with sample analysis using spreadsheets with formula cells that are not write-protected. • Using acceptance criteria for analytical balances and pipettes that do not meet QSM requirements. • Lack of analytical waste segregation, labeling , storage and disposal practices • Lack of internal audits, and annual management review that fosters continuous improvements • Logbook documentation issues
Common Problems -- FY 2014 TSDF Audit Findings • Outbound shipping paperwork does not meet the requirements; for example: • Technical Name requirements for hazardous material shipments • Shipping Description and Hazard Class for hazardous material shipments • Required content and signatures on outbound shipping papers • Not ensuring that workers complete the required training for work under the hazardous waste management permit and/or failing to properly document completion of the required training.
Common Problems -- FY 2014 TSDF Audit Findings (cont.) • Not meeting the requirements for: • Chemical storage (incompatibles) • Waste segregation • Universal waste labeling and marking • Failing to properly label measuring and test equipment with the calibration status.
DOECAP Lessons Learned • Need to incorporate consistent DOE contract language for lab closures associated with the timeframe for waste disposition • What will be the consequences of the Hanford Site Lab Closure? • Taxpayer cost savings • DOE will be farming that work out to other commercial labs
Mixed Analyte Performance Evaluation Program (MAPEP) Accomplishments • 130 labs participation -- 88 domestic and 42 foreign • Semiannual PT evaluations: • MAPEP Series 30: Shipped March 2014 • MAPEP Series 31: Shipped August 2014 (reporting deadline November 5 ,2014)
MAPEP Accomplishments (cont.) • Initiated DOE - PT Technical Standard • Performed special studies for uranium and strontium • RMCC -- International collaborations – building lasting partnerships through science, not weapons
Participation in MAPEP Improves Performance Laboratories’ performance for analysis of iodine‑129 in water
DOE Senior Management Support for MAPEP DOE Chief Health, Safety, and Security Officer memo on December 30, 2013, to program line and field element managers recommends that all onsite and sub-contracted environmental laboratories performing radiological, inorganic, or organic analyses for DOE be encouraged to participate in MAPEP.
Laboratory Audit Programs – Overall Objective The overall objective is to provide data of known, documented quality to field managers for use in making sound environmental management and cleanup decisions.
Future Considerations • DOECAP Auditing Activities • New labs being considered • New non-radiological TSDFs being considered • Budget considerations – FY 2015 budget remains flat
Future Considerations (cont.) • Continuing TSDF Pilot Study of Self – Identified findings/completed checklists • More focused DOECAP audit scopes: • Laboratory Audit Disciplines • Quality assurance • Data quality for organic, inorganic, and radiochemistry analyses • TSDF Audit Disciplines • Quality assurance • Environmental compliance and permitting • Waste operations
Conclusion Flexibility Dealing with reorganizations, loss of institutional knowledge and changing priorities Maintaining excellence and consistency while continuing to provide value-added stakeholder benefits – risk reductions/performance improvements
George E. DetsisOffice of Environment, Health, Safety and Securitygeorge.detsis@hq.doe.gov301-903-1488