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Monitoring for Aeromonas as a UCMR List 2 Contaminant: Voluntary Performance Testing Program for Laboratory Approval

A proposed Rule was published March 7, 2002 (67 FR 10532) which identifies the approved analytical method for Aeromonas monitoring as a UCMR List 2 contaminant and the laboratory approval program. Below is a copied portion of the preamble where this program is specified.

C. Laboratory Approval and Certification
This rule proposes that laboratories wishing to analyze samples for Aeromonas for the UCMR must use USEPA Method 1605. USEPA has previously specified, in Sec. 141.40 (a)(5)(ii)(G)(3) (66 FR 2273, January 11, 2001), that Aeromonas analyses must be performed by laboratories certified under Sec. 141.28 for compliance analyses of coliform indicator bacteria using an USEPA approved membrane filtration procedure. Because of differences between USEPA Method 1605 and existing membrane filtration methods for coliform indicator bacteria, laboratories performing USEPA Method 1605 must also participate in performance testing (PT) studies to be conducted by USEPA. Laboratories wishing to be approved to use Method 1605 for this monitoring must submit a ``request to participate'' letter to USEPA and to analyze 10 samples for Aeromonas using Method 1605. USEPA has established 45 days following the publication of the final rule as the latest date by which it will accept the ``request to participate'' letter. A second PT study will only be conducted if more than 90 days remain between the reporting of the results of the first study and the beginning of Aeromonas monitoring, January 2003, to provide utilities with at least 45 days to contract with laboratories that have received approval. Upon completion of the Aeromonas PT Program, USEPA will provide each successful laboratory with an approval letter identifying the laboratory by name and the approval date. This letter and a copy of the laboratory's certification under Sec. 141.28 for compliance analysis of coliform indicator bacteria using an USEPA approved membrane filtration procedure, may then be presented to any PWS as evidence of laboratory approval for Aeromonas analysis supporting the UCMR. Laboratory approval is contingent upon the laboratory maintaining certification to perform drinking water compliance monitoring using an approved coliform membrane filtration method. USEPA intends to post a listing of the laboratories that have successfully completed each PT study at http://www.epa.gov/safewater/.

A laboratory's request letter should include the following information:

  1. Laboratory Name
  2. Complete Laboratory Mailing Address
  3. Proof of the laboratory's certification under §141.28 for compliance analysis of coliform indicator bacteria using an USEPA approved membrane filtration procedure
  4. A copy of the laboratory's Initial Demonstration of Capability (IDC) as well as blank and negative culture control data as specified in Sections 9.4 through 9.6 of Method 1605. A summary table for this information is attached.
  5. Contact Person at the lab
  6. Contact Phone, FAX, and e-mail (if available)

The "request letter" package should be mailed to:

Aeromonas PT Program Coordinator
U.S. Environmental Protection Agency (MS-140)
26 W. Martin Luther King Dr.
Cincinnati, Ohio 45268

Laboratories should also FAX (513-569-7191) the request letter with certification confirmation. We suggest laboratories request receipt confirmation to ensure registration.

Some important FAQs about the Aeromonas PT Program and monitoring....

How much demand will there be for UCMR List 2 monitoring of Aeromonas?
If your laboratory is interested in participating in this voluntary PT program, they should consider the fact that commercial laboratory demand for the analysis of the List 2, Screening Survey contaminant Aeromonas, will be very limited. Commercial laboratories which gain Aeromonas approval will only be competing to support the monitoring at those 120 large public water systems (PWS) which have been selected as part of the List 2 Microbiological Screening Survey. The complete list of systems required to monitor for List 2, Aeromonas can be found in Table 2 on a web page posted at: www.epa.gov/safewater/standard/ucmr/list2largesystems.html. Be certain to specifically look toward the middle of this page for Table 2, where the List 2, Aeromonas systems are listed. Each of these systems will need to collect a total of 18 samples from defined locations in their distribution system throughout 2003. EPA has laboratory contracts established for the 180 small PWSs which are also required to monitor.

How many PT studies will be offered?
At least three studies are planned during 2002. Laboratories will only need to pass one of these studies to qualify for approval. No additional PT studies for Aeromonas will be offered after the last study conducted in the last quarter of 2002. Laboratories which fail an earlier PT study will not automatically be enrolled in the later studies and will need to resubmit request letter. This will ensure that the laboratory is still interested in pursuing Aeromonas laboratory approval.

What is the schedule for these PT studies and deadlines for submitting request letters?

The first Aeromonas PT study will occur during the week of April 22, 2002. Laboratories interested in participating in this study should submit their request letter by April 5, 2002. EPA expects that laboratories intending to participate in this first study will be those which already have some experience with the method and which have already completed their Initial Demonstration of Capability (IDC). Laboratories which participated in the validation of USEPA Method 1605 may submit their IDC information from that validation. The second PT study is being scheduled for mid July 2002 with a deadline for request letter submission of June 14, 2002. The dates for the third PT study have not yet been established but are expected in early fall. A fourth PT study may be scheduled if sufficient time is available prior to the start of monitoring in January 2003. The timing and deadlines for these later studies will be updated when more information is available. This updated information will be posted on the main UCMR web page (www.epa.gov/safewater/ucmr.html).

How will approval to conduct Aeromonas monitoring be granted?
Laboratories may participate in the voluntary PT program before the final rule is promulgated. After the laboratory has submitted its IDC data, provided proof of certification, and successfully passed the PT, it will receive a letter indicating its approval is pending. Laboratory approval letters will not be issued until the final rule is promulgated. Laboratory approval will be limited and specific to the duration of the UCMR (1999) Aeromonas monitoring period.

Application for Participation in Voluntary Aeromonas Performance Testing Program

Laboratory Name:
Contact Person:
Complete Mailing Address:


Phone: Fax:
E-mail Address:

Initial Demonstration of Capability Data

 

Aeromonas CFU

Colony Color

Oxidase Result

Trehalose Result

Indole Result

9.4 Initial Precision and Recovery

       

Spiked Reagent Water #1

         

Spiked Reagent Water #2

         

Spiked Reagent Water #3

         

Spiked Reagent Water #4

         

Mean CFU

         

RSD of CFU

         

9.5 Blank

         

9.4.3 Positive Control

A. hydrophila

         

9.6.4.1 Oxidase Negative Control (E. coli)

         

9.6.4.2 Trehalose Negative Control (P. aeruginosa)

         

9.6.4.3 Indole Negative Control (B. cereus)

         
Mail to:
Aeromonas PT Program Coordinator
U.S. Environmental Protection Agency (MS-140)
26 W. Martin Luther King Dr.
Cincinnati, Ohio 45268
Fax to:
513-569-7191

Include a copy of proof of certification for coliforms by membrane filtration.

 

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