August/September 2011

2011 Accreditation Policies Released

(Effective September 13, 2011)  

Expect New Applications early September

On July 15, 2011, AIHA Laboratory Accreditation Programs released the 2011 Accreditation Policies to be effective September 13, 2011. You may find the link to the 2011 Policies on the table of links to the left of any page on the www.aihaaccreditedlabs.org website as a sub-bullet under the current, 2010 Policy Modules. This will be moved to the main Policy Module bullet as of the effective date in September.

You may also notice a few changes for organization and ease of use to the format of the page, including a section for Policy interpretation/explanation, followed by the Policies and associated Guidance documents in table format. The change summary document is located here.  As opposed to previous years' release that included a zip file of the changes tracked, we have created a downloadable pdf of the fully tracked, complete Policy document that is embedded in the change summary document.

This year, we have also established an open comment period from the release date until the September 13 effective date.  Please provide any feedback you like.  Any negative feedback to the Policies will be processed through our complaint procedures and changes to policies needed to address feedback will also be considered for the next Policy release.

Regarding changes to documents ancillary to Policy release, the 2011 Accreditation Application will be released and posted with a goal date of September 5, to allow those laboratories receiving notifications of their accreditation expiring June 2012 to download the application that will be effective as of their submission date. The transition from the 2010 Application Review and Site Assessment Checklist to 2011 should not affect the Application review status of those laboratories that have been received by the AIHA-LAP office and are in queue for site assessment. However, those laboratories that have late Application submissions beyond the 30 days allowed in their reaccreditation reminder letter will need to submit the 2011 version of the Application. Other ancillary documents that will be released in or before early September include:  the EMLAP and ELLAP Scope pages to include the newest Fields of Testing; the Onsite Document Review List; and the Preparing Deficiency Responses Form.

Laboratory Items of Note  

17025 Article in August 2011 Synergist

Our site assessors tell us that they are finding that some labs are using yellow HSE test slides for checking the resolution of their PCM microscope/analyst system.  According to OSHA and NIOSH experts, Phase Shift Test Slides are certified by the UK Health and Safety Laboratory according to the visibility of the blocks of lines. The Mark II test slides have been replaced by Mark III slides in three different types. This has resulted in confusion in applying the requirements outlined in the OSHA asbestos regulations 29 CFR 1910.1001, 29 CFR 1926.1101, and 29CFR 1915.1001, and in NIOSH Method 7400.

OSHA and NIOSH officials tell us that the requirement is best met by either the Red or the Green Mark III certified slides because they both have at least one line set that is invisible, allowing the 3 degree benchmark to be bracketed. The Yellow certified slide does not have an invisible line set in a properly working microscope and thus, cannot assure that the microscope has the proper degree of phase shift.

OSHA and NIOSH recommend that either the Red or the Green Mark III certified slides may be used, as long as they perform within the limits given in the accompanying documentation. The Yellow certified slides should not be used. The previous types, Mark I and Mark II may be used as long as they still perform within the limits of the accompanying documentation.

At present, AIHA-LAP does not have a policy that allows assessors to cite a deficiency for labs using the yellow slides for PCM work but such a policy may be issued in 2012.  Until then, labs are encouraged to follow this guidance.   For additional information, please review the Phase Shift Test Slide Interpretation guidance. 

Samples from Third-party PT Acceptable for Internal Demonstration of Competency

The Proficiency Testing Task Force has determined it is acceptable for a laboratory to use those third-party proficiency testing providers that have not been added to the AIHA-LAP “approved provider” list as found on the www.aihaaccreditedlabs.org website to obtain “blind” spikes/samples for internal demonstration of competency.  Some third-party providers may be able to provide a la carte compounds on a given matrix by request (e.g. SUMMA canisters). These samples can be used for internal demonstration of competency if they represent samples on a matrix similar to the Field of Testing for which the lab is seeking accreditation and the lab can ensure that the provider has run enough QC on their samples to demonstrate their “known” values are accurate. AIHA PAT Programs’ stock samples can also be used for this purpose. AIHA-LAP would like to notify our accredited labs of this option of created spikes, to relieve the labs of the burden of having to create their own spikes and the subsequent additional time and material burden.    

Tips/Reminders for Laboratories

Give Us Feedback

Just had an assessment?  Please remember to give your feedback by filling out the AIHA-LAP Feedback Form during your accreditation process or at any time during the year. You may find the form on our Program Fees, Guidelines and Forms webpage here.  You also should feel free to contact Heather Thompson (Quality Systems Manager) at hthompson@aiha.org, Angela Oler (Accreditation Manager) at aoler@aiha.org, or Cheryl Morton (Director, AIHA-LAP) cmorton@aiha.org  at any time to discuss any comments or concerns you may have.  

Report Significant Changes

Per Policy 3.8.1, accredited laboratories are reminded that they are required to report significant changes within 20 business days of the change. The following changes need to be reported to AIHA-LAP, LLC staff:

• Personnel changes that include technical manager and quality manager. Check Policy 2A.5 and the specifics of your accreditation program to ensure that these positions fulfill the qualifications outlined.
• Facility location and/or ownership—not only is it required by Policy 3.8.1, but your accreditation covers only the laboratory as named on the certificate of accreditation and the facility address as listed.

Always Use Your Lab ID

Please remember to use your accredited laboratory identification number and include it on all correspondence that your laboratory sends to AIHA-LAP, whether by email (subject line), fax, or in hard copy. The six digit number assigned to your laboratory by AIHA-LAP is a unique identifier and will ensure that all correspondence from your laboratory is assigned to the appropriate laboratory record.

 

Regulatory News     

CPSC Adopts Testing Requirements for Phthalates in Children’s Toys

The U.S. Consumer Product Safety Commission (CPSC) announced its new third party testing requirements for phthalates adopted to ensure that children’s toys and child care articles meet the federal phthalates limits.  Phthalates make plastics and other materials more flexible. The Consumer Product Safety Improvement Act of 2008 (CPSIA) permanently banned the use of three phthalates in concentrations greater than 0.1 percent in children’s toys and child care articles and temporarily banned the use of three others in concentrations greater than 0.1 percent in children’s toys and child care articles that can be mouthed, sucked or chewed pending further study. Since February 2009, it has been unlawful to manufacture or import children’s toys and child care articles violating these standards.

While makers and sellers of toys and child care articles have had to comply with the phthalates requirements for more than two years, CPSC has voted previously to give manufacturers, importers and private labelers additional time to put a third party testing program into place. CPSC has approved a stay of enforcement on the requirement for third party testing and certification of these children’s toys and child care articles to the phthalates limits until December 31, 2011. The Commission will enforce certification of compliance with the phthalates limits based on third party testing of children’s toys and child care articles manufactured or imported after that date.

AIHA-LAP is currently exploring opportunities for laboratories to be accredited to CPSC-CH-C1001-09.1 under AIHA-LAP’s Industrial Hygiene Laboratory Accreditation Program.  We will be polling our laboratories in a few weeks so you can tell us what your needs are.

CPSC Announces New, Lower Limit for Lead Content in Children's Products

On July 18, CPSC also announced its ruling that there was insufficient evidence to make a determination that manufacturers of children's products sold in the United States could not meet a total lead content limit of 100 parts per million (ppm) for a product or product category. The new total lead content limit, which is called for in the CPSIA, went into effect on August 14, 2011 for manufacturers, importers, retailers and distributors of children's products.

Through the CPSIA, Congress set tough new levels for lead content in products designed or primarily intended for children 12 and younger. Lead is a heavy metal that is toxic for children, and associated with lowered levels of learning, impaired hearing, brain damage and, at high levels, can be fatal.

Starting on August 14, 2011, manufacturers, importers, retailers and distributors of children's products must comply with the new 100 ppm federal limit for total lead content. CPSC officials say that they will not enforce the CPSIA's independent third party testing requirement for total lead content until December 31, 2011, due to a stay of enforcement that is already in place.  The stay of enforcement does not apply to children's metal jewelry, which currently must undergo independent third party testing.

Please note the lead content levels for children's products are different from the levels Congress set for lead in paint or surface coatings. The limit for lead in paint or surface coatings is .009 percent. The .009 percent level has been in place since August 14, 2009 and independent third party testing is required for all paints or surfaces coatings used on children's products.  AIHA-LAP currently accredits lead in paint CPSC methods meeting the requirements of 16 CFR Part 1303:  CPSC-CH-E1003-09, CPSC-CH-E1003.09.1, and ASTM F2853-10.

AIHA-LAP Hosts Second Laboratory Accreditation Forum  

AIHA-LAP hosted its second Accreditation Forum at AIHce in Portland, OR on May 15.  The two-hour Forum gave laboratory directors/staff from AIHA-LAP accredited labs (as well as those labs seeking accreditation) a chance to hear how the international agreements that AIHA-LAP has signed, watch the World Accreditation video and hear how to better market their laboratories using the ILAC recognition.  Former Chief Site Assessors Ronald Peters and Maureen Hamilton also gave presentations on the measurement uncertainty and traceability policies (adopted last year) that included tips on how to identify calibration certificates from ILAC MRA signatory laboratories.  A reception was held before and immediately after the Forum where outstanding volunteers and site assessors were honored (see story below).  Slides from the presentations can be found on the AIHA LAP website (click here).  For more information, please contact Cheryl Morton at cmorton@aiha.org or at (703) 846-0789.

AIHA-LAP Recognizes Outstanding Leadership

AIHA-LAP is pleased to announce the recipients of its 2011 Leadership Awards which were presented at a reception held in Portland, OR on May 11, 2011:

• Evan Campbell Award - Site Assessor of the Year
• James H. Nelson, PhD
• Harriotte A. Hurley Award - Analytical Accreditation Board Member of the Year
• Larry S. Pierce, PhD, CIH
• Newton Whitman Award - Technical Advisory Panel Reviewer of the Year
• Stacey Bolling
• Chief Site Assessor Award
• Christine A. Kearney
• Analytical Accreditation Board - Past Chair Award
• David Sandusky, CIH