Certifications

Think of it like getting your car repaired. The mechanic working on your brakes might need a specific state certification to be qualified to do that work. However, the lab that tests the quality of the brake fluid the mechanic uses might not need a state certification specific to “brake fluid testing.” As long as the lab follows proper testing procedures and quality control, the results are still valid for determining if the brake fluid meets the required standards.

Therefore, while certain activities related to RCRA, UST, and wastewater management often require state certification, the testing performed to assess these areas can be valid if conducted by a competent laboratory following recognized standards and methods, even if the state doesn’t have a specific certification program for that exact type of testing.

It’s crucial to always verify the specific requirements of the relevant state and regulatory agency to ensure that both the testing and any associated activities meet all applicable regulations.

1. Regulations Focus on Specific Activities and Roles:

Certification often targets operators and those directly responsible for regulated activities. For example, wastewater treatment plant operators might need state certification to oversee the treatment process and ensure compliance with discharge permits. Similarly, individuals who install or remove underground storage tanks (USTs) may require specific certifications.

Testing, on the other hand, is a technical service. While the results of the testing are crucial for demonstrating compliance with RCRA (Resource Conservation and Recovery Act), UST, and wastewater regulations, the act of performing the test itself might not always require a specific state-issued certification for the testing laboratory or personnel.

2. Validity of Testing Relies on Quality Standards, Not Always State Certification:

Accreditation vs. Certification: The validity and reliability of environmental testing often depend on adherence to recognized quality standards and protocols. Laboratories frequently seek accreditation from independent bodies (like The NELAC Institute – TNI) that assess their competence in performing specific tests. This accreditation demonstrates technical proficiency and data defensibility.

Standardized Methods: Environmental testing typically follows standardized methods (e.g., EPA-approved methods). As long as a laboratory adheres to these scientifically sound procedures, the results can be considered valid for regulatory purposes, even without a specific state certification for that particular testing category.

Data Quality Objectives: Regulatory agencies are primarily concerned with the quality and reliability of the data used for compliance decisions. If a lab can demonstrate that its testing procedures meet the required data quality objectives, the lack of a specific state certification for RCRA, UST, or wastewater testing might not automatically invalidate the results.

3. State Regulations Vary:

Not all states have comprehensive certification programs for all aspects of environmental work. Some states might focus their certification efforts on operational roles (like UST installers or wastewater operators) and rely on the quality assurance processes of testing laboratories for the validity of analytical data.

💡States may accept data from accredited laboratories, even if they don’t offer a specific state certification for that type of testing. The accreditation process itself can provide a level of confidence in the lab’s capabilities.