Article Laboratories

Water Testing Cost Amendments

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DEFRA’s Water Classification Directions to the Environment Agency

Could water testing costs (either as part of due diligence work or operationally in relation to discharge consents) be set to rise in the future?  Darren Wilcox of Peter Brett Associates LLP ponders this and other questions raised as a result of the draft Directions.

In October 2008, DEFRA issued a draft “Directions to the Environment Agency on classification of water bodies” for consultation as part of its duties under the Water Framework Directive (WFD). PBA has reviewed the draft and contributed to the consultation process through a direct response to DEFRA.

Surface Water Classification
We note that the proposed new requirements for classifying surface waters are significantly more complex than the existing Environment Agency General Quality Assessment (GQA) scheme for rivers and canals.

With the GQA scheme, analytical costs for determining the classification of a river sample are typically less than £20. To classify the same river sample using the proposed method in the new draft Directions could cost in excess of ten times this amount.

The Directions are also not clear on how many exceedances of the 33 environmental standards would be required in order to classify an surface water body as failing to achieve good chemical status.

Groundwater Classification
To classify groundwaters, DEFRA has produced different assessment standards for different aquifers in different catchments of England and Wales. This has lead to the publication of a 160 page annex detailing different groundwater quality thresholds.

In many cases, the proposed threshold values are lower than prescribed concentrations for UK drinking water (specified in the water supply regulations). PBA has questioned the sustainability of aspiring to a situation where groundwater quality is superior to tap water quality.

The low groundwater threshold values proposed may lead local authorities or the EA to set unreasonably stringent remediation target values for groundwater where brownfield sites have recorded slight groundwater contamination issues. This in turn could lead to excessive costs for brownfield redevelopment in the future.

Darren Wilcox
Peter Brett Associates LLP

Article Laboratories

Classification and testing in BS 5930 and BS 1377-9

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The BSI Committee for Geotechnical Testing has been working to help provide guidance on the changes to geotechnical testing methods introduced by new EN ISO standards.

The National Forewords to the following standards have been changed and now provide clause by clause details of where the new standards impact on BS 5930 and BS 1377-9:

Geotechnical investigation and testing. Identification and classification of soil. Identification and description

Price £72*  Member Price £36     ISBN 0 580 40481 1

Geotechnical investigation and testing. Identification and classification of soil. Principles for a classification

Price £72*  Member Price £36     ISBN 0 580 47508 5

Geotechnical investigation and testing. Identification and classification of rock. Identification and description

Price £102*  Member Price £51     ISBN 0 580 43574 1

Geotechnical investigation and testing. Field testing. Dynamic probing

Price £118*  Member Price £59  ISBN 0 580 47636 7

Geotechnical investigation and testing. Field testing. Standard penetration test

Price £102*  Member Price £51     ISBN 0 580 47637 5

These amended documents are now available.

The relevant sections in the BS documents are now superseded and BS 5930 and BS 1377-9 are being amended in the short term to remove those conflicting sections.

In the long term a much broader revision of the British Standards is necessary, not only to cater for further European test methods, but particularly following the publication of BS EN ISO 22475-1 Geotechnical investigation and testing which was implemented in March 2007.

It is important to note that where conflict arises between British and European standards the BS EN ISO documents take precedence and should be used.

Ways to order:
Contact BSI’s Customer Services team quoting reference 5390D-SA
Call + 44 (0)20 8996 9001
Fax + 44 (0)20 8996 7001

*P&P: Charge of £5.95 UK (inclusive of VAT) added to subtotal.


Article Contaminated Land Laboratories


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The Environment Agency’s Monitoring Certification Scheme for the Chemical Testing of Soils:
What it is. How it affects you. What you need to do.

MCERTS Monitoring Certification Schemes were first introduced in industrial sectors with regulated processes that resulted in stack emissions. The scheme requires those companies to deliver monitoring results that are “valid, reliable and accurate”. To get to this position depends on using the appropriate resources – correct test methods, competent personal, accredited organisations and suitable equipment and planning.

The MCERTS scheme for chemical testing of soils was introduced by the Environment Agency to support their regulatory activities and make informed, quality assessments on the management of contaminated land under a number of regimes, including, Part IIa of the Environmental Protection Act 1990, Pollution Prevention and Control Regulations 2000 and the Waste Management Licensing Regulations 1994.

The scheme is applicable to all testing laboratories and procurers of analytical services, where results generated for the chemical testing of soil are submitted to the Agency. In order to gain accreditation on the scheme, laboratories are required to have their processes, essentially test methods, in a quality management framework, by both the United Kingdom Accreditation Service (UKAS) to the international standard ISO 17025 and also MCERTS requirements.

There are increasing pressures on businesses to comply with Environment Agency regulations and European and international standards. Using a laboratory with MCERTS accreditation alleviates some of this pressure because it guarantees the proper use of suitable methods, standards, services and equipment, trained and qualified personnel, quality assurance and quality control all leading to reliable data. MCERTS accreditation also assures users that the laboratory meets performance standards set out in current international standards and the growing requirements of EC directives.

Failure to meet the regulations can be costly, both financially and to a company’s reputation. An MCERTS accredited laboratory assures the user that they have met standards in a number of areas including:

  • The selection and validation of test methods

  • Sampling pre-treatment and preparation

  • The estimation of measurement uncertainty

  • Participation in proficiency testing schemes

  • The reporting of results and information

The benefits of the scheme include:

  • Providing assurance to stakeholders of the quality of data from testing

  • A level playing field, based on the Agency’s requirements, is established

  • Identifying that the chemical testing of soil is a critical component in producing defensible data for regulatory purposes.

In order to guarantee reliable data from the chemical testing of soils and therefore reassurance that risks are minimised, procurers of testing should:

  • Ensure the chemical analysis results submitted to the Agency for regulatory purposes conform to MCERTS requirements.

  • Check that the laboratory conducting the testing has MCERTS accreditation for all the parameters requiring analysis. Accreditation is given on a parameter-by-parameter basis. If they do not have the correct accreditation sub-contracting of the test required to another MCERTS laboratory may be required. If a suitable laboratory does not appear to be available, contact the Environment Agency for advice.

  • Check that the test methods employed by the laboratory are appropriate and fit for purpose in terms of the parameter, the Critical level of interest (CLI) and the matrix. The CLI may be a soil guideline value or a regulatory limit.

  • Check with the laboratory that the sampling processes, preservation and transportation are appropriate.

  • In collaboration with your chosen laboratory, have complete audit trails available that address aspects such as sample location, depth of sample, date and time of sample, reference identity and the laboratory used.

The MCERTS scheme for the chemical testing of soils was phased in, but has been fully operational since 1 March 2005. Therefore, all data for regulatory purposes should now be to the MCERTS standard. Laboratories and the procurers of testing need to work together to ensure that the test data provided meets the requirements and satisfies the needs of the ultimate client.

Cliff Billings Group Technical & Quality Manager STL UK


EA’s position on MCERTs

From 1st March 2005, the Environment Agency has required accreditation to our Monitoring Certification Scheme (MCERTS) where laboratory soil testing results are submitted to us as part of a regulatory regime for which we have statutory responsibility.

We strongly recommend that MCERTS accredited methods are used for soil testing in activities to do with site remediation, whether carried out on a voluntary basis or to comply with planning requirements. This is particularly important in relation to any waste management issues on the site.

Jackie Harrison Environment Agency

Contaminated Land Working Group Meetings

In recent meetings of the Contaminated Land Working Group, it has been clarified that the EA is a consultee but not a Statutory Regulator for planning applications. This means that MCERTs data may not always be required at the planning stage. Although the EA recommend MCERTS, the final decision is up to the Local Authority.

Some AGS Members feel that all tests should be to MCERTS so that the reports can be used at a later date. At present, the EA is expected to take a pragmatic approach to historical data obtained before the introduction of MCERTS and take account of whether the laboratory is now accredited, and other relevant factors. However, this may not always be the case, particularly for data collected after March 2005, and the need to ‘future proof’ data should be seriously considered.


Meet NHBC Requirements with MCERTS

The NHBC welcomes MCERTs accredited testing and supports it’s use in association with robust and representative soil sampling strategies when investigating sites affected by contamination. It brings transparency and consistency to the analytical testing techniques and encourages discussion between the consultants and testing laboratories which can only be a positive step forward.