2012 US EPA Method Update Rule (MUR) Implementation Notification and Requirements
On May 18, 2012, the USEPA published a final MUR that approved the addition of new methods and changes to existing methods. Over 100 methods are affected; including those listed as USEPA methods, Standard Methods (SM), ASTM Methods and other test procedures given in Part 136 of Title 40 of the Code of Federal Regulations (40 CFR). The rule also provided a number of clarifications related to method requirements, sample preservation, holding times and method modifications. Among the more significant changes is a new Section 136.7 that provides “essential” quality control requirements. Additionally, some technologies and method references were removed. See Attachment 1 for details. A copy of the rule with related information can be found on the USEPA’s Office of Science and Technology website at: http://water.epa.gov/scitech/methods/cwa/update_index.cfm
In addition, on June 20, 2012, the USEPA issued a letter (ATP Case Number N12-0006) that detailed the need to follow the editorial revisions made to the methods from the 22nd edition and the online version that were included in the MUR. On June 21, 2012 the USEPA further clarified two corrections that needed to be made to the table found in the June 21, 2012 letter (SM 3113-2004 did not have a 2011update and that 6200C-1997 should be 6200C-2011). Links to the June 20, 2012 USEPA letters are provided below.
Effective with this notice the State of New Jersey will begin a phase-in period to implement the requirements of the MUR as follows:
- Immediately, for methods that were added as new (not simply an update to the most current approved version) laboratories may submit a “Request for Modification in Certified or Applied Status”. The request should include an application with appropriate fees, a copy of the laboratory’s Standard Operating Procedure (SOP), method detection limit (MDL) study results where required and the acceptable results of a Proficiency Testing (PT) sample performed and reported by the method for which certification is being sought. Laboratories may begin to use these requested methods at the time they are granted certification.
- By March 31, 2013 (for changes not addressed in the above bullet), laboratories shall submit a FY14 Renewal Application that includes all changes in certification to meet the method and Quality Assurance/Quality Control (QA/QC) required in the MUR. The enclosed FY14 Renewal Application package includes an Annual Certified Parameter List (ACPL) incorporating the method changes required in the MUR. This ACPL is for information purposes only and is to be used only as part of the renewal application process. Changes to the approved versions of SM noted in the MUR document as “-2011” for example, are abbreviated as “-11” on the ACPL. A helpful link for laboratories to use to identify the location (edition or online version) of the SM approved method options is included below. Most if not all approved SM options noted as “-2011” are found in the 22nd edition of SM.
Upon receipt of this notice through to July 1, 2013, laboratories may use either their current certified methods and QA/QC, or the methods and QA/QC required in the MUR.
- By July 1, 2013, laboratories shall have completed all changes (method and QA/QC) required in the MUR, in addition to the QA/QC currently required by N.J.A.C. 7:18. Up until July 1, 2013 laboratories may continue to analyze samples using those methods in their FY13 certification.
Effective in the FY14 ACPL all methods not listed in Part 136 of Title 40 of the CFR will be eliminated and will be replaced with the versions given in the MUR as reflected on the ACPL that is part of the renewal package. Please note that to be granted New Jersey Secondary NELAP accreditation it will be necessary for a laboratory to hold Primary Accreditation in the newly approved methods with another Recognized NELAP Accreditation Body. As an alternative, a laboratory can provide a letter from its Primary Accreditation Body stating that it has been approved in the new methods but as of yet its scope of accreditation has not been updated.
Also, if a laboratory requires that it remain accredited in a method that the MUR has removed it will be necessary to provide justification. Justification can be in the form of documents such as a copy of a permit, QA Project Plan or contract listing method requirements.
Further information on the State of New Jersey MUR activities will also be posted on the OQA’s Bulletin Board.
If you have any questions or concerns please contact the OQA at 609-292-3950 or the OQA’s email address at OQA@dep.nj.gov