Welcome back! It's time for question #3 of our ongoing EPA Tier 3 informational series. While today's question and answer may be the shortest in the series, it may be the most important of the bunch. Let's get to it!
Catch up on the rest of the EPA Tier 3 informational series: Ongoing Precision and SQC accuracy requirements.
Do Tier 3 requirements change as ASTM methods are updated? Or are they frozen in time?Quite the important question when looking to stay compliant through the years. I went straight to the regulation source for this one. But first, you might be asking yourself,
"Gee Chris, why is this even a question? Are ASTM methods updated that often?"
They certainly can be! This method in particular has been updated 3, count 'em, THREE times since the initial publication of the Tier 3 rule.
- D6299-13 (Currently called out in the CFR Tier 3 rule)
- D6299-13e1
- D6299-16
- D6299-17 (Currently published in ASTM Volume 05.03)
While some ASTM methods may go years without the slightest change, the subcommittee responsible for this method, D02.94 on Quality Assurance and Statistics, prefers to stay on the leading edge of quality control and statistical clarity. After all, this method is the basis for many of the industry's statistical quality control (SQC) best practices.
BEFORE you jump to the latest and greatest to come out of D02.94, keep in mind this advice direct from the EPA:
The Agency would need to do a rulemaking to change any test method(s) that are incorporated by reference by the Office of the Federal Register in our regulations at 40 CFR 80. We specifically cite the year version of an ASTM test method that is referenced in our regulations, same with standard specifications, otherwise, I think we would be giving folks outside the Agency the authority to change our regulations without public notice and comment, which would likely be a violation of the Administrative Procedures Act.
So there you have it. ASTM D6299-13 will always be the method to abide by for EPA Tier 3 compliance. Whoa! Pump the brakes there friend. As we have already seen, the Agency is not afraid to do these rulemaking changes as they see fit.
Our best advice? Do your best to stay up-to-date on the current language of 80.47 AND keep an eye on D6299 for possible upcoming changes required of your SQC program.
Please stay tuned to the Team ASI Blog as we provide the clarity needed to comply with EPA Tier 3.
Happy Charting,
Chris