To follow on from the topic of Triad and cost of on site analysis to try to answer Ruth's valid question - How can a user be certain a technology is reliable?
For chemical analysis, the UK relies on MCERTS. MCERTS for soil analysis is only available if the analysis is carried out in a laboratory and that exact laboratory has MCERTS accreditation for that analysis. If a lab with MCERTS for a particular analysis moves that exact same analyser and the staff that operate it to an alternative location, it is no longer an MCERTS accredited analysis. That is why MCERTS accredited on site analysis for soil is not possible. Theoretically, MCERTS should allow for this, but a published performance protocol must be available to compare the new technology against. There is one for stack monitoring and another for water flow meters, but nothing for soil analysis. The Env Agency is responsible for putting this performance protocol together, but currently have no budget to do so.
This shows that MCERTS is not about analytical quality, but about procedure. MCERTS follows some aspects of similar International Standards (ISO), but unlike ISO methods or accredited methods in the USA, Australia (almost everywhere else actually) MCERTS does not proscribe the exact method to be followed. This is why in the UK we have TPH methods that are all MCERTS accredited, yet if all the labs are sent the same sample, the results you would get back are likely to be around x5 different between the lowest and highest result. The reason is that the current common TPH method called GC-FID that most labs use for their MCERTS accredition, while seemingly similar, can and does have significant differences within the method. Different solvents allow different extraction efficiency, different extraction methods (boil, sonicate, simple shake etc) also affects extraction efficiency. Variations in sample preparation also affect the final result. The GC can use short or long columns, different injection protocols, different detector types, different oven temperatures, inlet temperatures, ramp times, cooling cycles etc etc. The permutation of options is huge, the consequence of which is a highly variable method that MCERTS gives the illusion of accuracy and precision to.
Trying to show a new technology is the equivalent of the old technology within this framework is impossible. When legislative frameworks take around 10 years to change, new technology is not encouraged, so technology developers go to countries where the framework is more technology friendly. In the US technology and innovation is encouraged, so inventors make things, get them approved and sell them eventually to the more "backward" looking countries. The QED was evaluated in the US, approved and is now recommended as a better analytical method than the lab GC-FID for TPH (a joke, because the QED is designed and built in the UK, yet no UK mechanism is available to accredit it)
An option is for any environmental technology to go down the ETV (environmental technology verification) route. There was an ETV program in the US, but the ETV contractors became greedy (Yes Battelle, its you!!) which kills the scheme because innovation comes from small companies who cannot afford corporate fees. NICOLE, the European equivalent to CLAIRE is bringing an ETV scheme out, but as of yet there is no analytical devices section. A potentially excellent alternative for on site analysers is the new ISO 14034 standard that provides a way for technology developers to have their technology claims independently verified. Unfortunately, the UK will not accept ISO standards for some bizarre and arcane reason only known to a select few that give their place of residence as LaLa Land. Sadly, they are the people who make up the rules. Lobby the Env Agency. Accepting new technology in 99% of cases reduces costs, improves efficiency and is generally a good idea.
To be fair the 2016 MCERTS guidance states that the Env Agency will accept data from on site or rapid methods provided there is a good QA/QC procedure and that some samples are sent off for MCERTS analysis. There is also an awareness within the Env Agency that not all MCERTS analysis is that reliable, which is why they will also adopt a "lines of evidence" approach. This means if you submit 10 on site results that show X levels of contamination, but the lab shows Y, the on site methods, provided they have the required QA/QC are more likely to be accepted. I am not sure if this message has filtered down to LA planning/contaminated land officers though.
It is not technology that holds us back, but the inability of our legislative and approval processes to keep up with technology. It is a common and time honoured UK trait.
Hopefully this goes someway to answering the question raised. There are times however when dealing with UK bureaucracy that I think we are being encouraged to just paint ourselves blue, live in a mud hut and go back to a simpler albeit much shorter and probably disease ridden life
To unsubscribe from the CONTAMINATED-LAND-STRATEGIES list, click the following link: