Effective January 2012, all source testing at sources regulated under 40CFR Part 75 must be performed by organizations complying with the ASTM D7036 standard, ‘Standard Practice for Competence of Air Emission Testing Bodies’ (AETBs). Owners and operators of many regulated facilities are already requiring compliance (and accreditation) with the standard, in anticipation of the expansion of this requirement to other sources, including those regulated under 40 CFR Part 60 and Part 63.
AETBs must create and maintain a comprehensive quality management system (QMS) that includes organization and management, document control, training and certification for qualified individuals (QIs), operating procedures, procurement, reporting, and identification and control of non-conforming work, among many other elements.
While the US EPA places the direct burden of compliance (and significant penalties for non-compliance) on the AETBs, owners and operators of sources also have important responsibilities to consider.
Regulated sources are obliged to verify and document that they are using test bodies that comply with the ASTM standard. They may meet this requirement by one of two means:
- Verify the compliance of self-certified firms by the obtaining and reviewing of the AETB’s current quality manual, the results of all of the AETB’s external and internal audits during the 12 months prior to each test, descriptions of any corrective actions implemented by the AETB during the 12 months prior to each test and the AETB’s training records for the 12 months prior to each test
- Obtain a copy of the firm’s certificate of accreditation through an independent assessment body
Currently, the only independent assessment body for the ASTM D7036 standard is the Source Testing Accreditation Council (STAC). The STAC web site lists firms that have obtained interim accreditation under this program. Independent assessments for firms that have had interim status for at least 12 months are scheduled to begin in the second half of 2011. Firms that successfully complete this step in the process will be fully accredited.
Employing an independently accredited, verified testing firm will relieve facilities of the burden of independently verifying firms’ compliance with the standard (essentially performing its own program audit).
Leading the way in quality, Golden Specialty was the first firm to obtain interim accreditation in the ASTM D7036 standard, and leads the industry in internal compliance assessment through its quality management system. To arrange a consultation regarding your source testing needs or for information on our emissions testing capabilities, laboratory services, or instrumentation service and sales, please call Ron McCulloch at +1 919 400 7956 (rmcculloch@goldenspecialty.com) or Dr Scott Swiggard at +1 281 476 9898 (sswiggard@goldenspecialty.com).