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** Drinking Water Certified Laboratories - Direct Lab Reporting Procedure (download here ) ** Direct Lab Reporting Procedure Effective Date: April 1, 2006
The 2005 Oregon Legislature amended ORS 448.150 to require certified/accredited drinking water laboratories report directly to the Department of Human Services-Drinking Water Program (DHS-DWP) any analytical result that exceeds a Maximum Contaminant Level (MCL). Final regulatory language [OAR 333-061-0040(1)(b)] states:
Laboratories that issue final test reports shall report the validated results of any analysis directly to the Department and to the water supplier if the analysis shows that a sample contains contaminant levels in excess of any maximum contaminant level specified in the water quality standards within (24) hours of obtaining the results. Subcontracted laboratories shall report such results to their client laboratory within (24) hours.
Q: When does this requirement become effective?
A: April 1, 2006. Beginning on that date, all reporting labs must submit analytical results exceeding established drinking water MCL standards to DHS-DWP within 24 hours.
Q: How does the lab notify DHS-DWP?
A: FAX a copy of the validated lab report number to (971) 673-0458.
This is a dedicated FAX machine only for receiving these reports. Reports must include water system name, PWS ID number, and source identification. No special reporting forms or other documentation is necessary.
Q: How will DHS-DWP confirm receipt of the faxed report from the lab?
A: Upon receipt, DHS-DWP will date-stamp the received lab report and fax back the date-stamped copy to the fax number noted on the original transmittal.
Q: Can the lab report electronically instead of by FAX?
A: No. For now, DHS-DWP is set up to receive direct lab notification by FAX method only. Should electronic reporting become available in the future, all labs will be notified.
Q: Which contaminants must be reported? A: Labs must report all analyses indicating exceedence of an established drinking water MCL standard. Reportable MCL categories are:
Bacteriologicals (all routine and repeat positive total coliform, fecal coliform and E. coli results) Inorganic Chemicals ( Nitrate, Arsenic, etc.) Synthetic Organic Chemicals (Carbofuran, etc.) Volatile Organic Chemicals (Trichloroethylene, etc.) Disinfection By-Products (TTHMs, HAA5s, Bromate and Chlorite) Radionuclides: [Gross alpha (including radium-226), combined radium-226/radium-228, Uranium and Beta/Photon emitters]
The rule does not pertain to an MCL violation as it relates to compliance. Further, the rule does not apply to Action Levels for lead and copper, or to treatment technique standards.
Q: What are the penalties if labs do not report as required?
A: Labs that do not follow the direct lab reporting requirements prescribed in OAR 333-061-0040(1)(b) will be considered as failing to comply with NELAC Standard 5.5.10.1, stating:
The results of each test, or series of environmental tests carried out by the laboratory shall be reported accurately, clearly, unambiguously and objectively, and in accordance with any specific instructions in the environmental test.
As with any NELAC standard, failure to comply may be cause to lose accreditation.
Q: Does the laboratory need to report an analysis challenged by a client or if the lab is requested to change the sample type (e.g. “Routine” to “Special”) after the results have been determined?
A: The lab must request the water supplier provide a written explanation to the lab for any change request. The lab must then FAX the analytical results, accompanied by the explanation, to DHS-DWP for evaluation and follow-up.
If you have questions, please contact:
Joseph Carlson, Interim Manager Data Management, Compliance and Enforcement Unit Oregon Department of Human Services - Public Health Division Drinking Water Program 800 NE Oregon St, Ste 640, Portland, OR 97232 fax. 971-673-0457 e-mail: joseph.r.carlson@state.or.us
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