Guide for sampling and analysis of bisphenol A (BPA) in industrial effluent: chapter 9

Chapter 9

9.0 Documentation and Reporting

• 9.1 Record Keeping
• 9.2 Reporting
• 9.3 Labelling and Identification
• 9.4 Chain of Custody
• 9.5 Data Review

9.1 Record Keeping

Facilities must keep their P2 Plan and any records pertaining to the Plan for a minimum of five years following the implementation of the Plan. Please refer to the Notice Requiring the Preparation and Implementation of Pollution Prevention Plans with Respect to BPA in Industrial Effluents published by the Minister of the Environment under Part 4 of CEPA 1999 for details on record keeping requirements.

Facilities should keep all records up-to-date and accessible for inspections. Records pertinent to sampling and analysis may include:

• Monitoring plan;
• Date and time of sampling activities;
• Sample collection type (grab or composite) and sampling method;
• Sampling location;
• Identification of sampling staff;
• Malfunctions and corrective actions taken;
• Maintenance log, including the frequencies and types of maintenance performed;
• Calibration, cleaning and repair logs;
• Date that the samples were sent to the laboratory for analysis;
• Date that the analysis test was performed;
• Laboratory test method, including detection limit;
• Laboratory accreditation number;
• Laboratory address and phone number; and
• Any other relevant information.

9.2 Reporting

Facilities must submit the information required in the schedules of the Notice Requiring the Preparation and Implementation of Pollution Prevention Plans with Respect to Bisphenol A in Industrial Effluents published by the Minister of the Environment under Part 4 of CEPA 1999.

As part of the reporting requirements for sampling and analysis, facilities must submit the following information in order to complete Table 4.5.1 found in Schedules 1, 4 and 5 of the P2 Planning Notice:

• Temperature and pH of the effluent at the time of sampling;
• Concentration of BPA in the effluent following laboratory analysis;
• Date that the samples were collected and date that the analysis test was performed; and
• Name, address, phone number and accreditation number of the laboratory that performed the analysis.

Note: If sampling has occurred at a site other than the final discharge point, facilities should record and report sampling site location information such as location in relation to final discharge point, the rationale for the site location, and the predicted concentration of BPA at the final discharge point as a result of any removal or treatment of BPA by the industrial facility. This information should be reported under Part 8.0, “Factors to Consider,” subsection 4(6), of Schedules 1, 4 and 5 of the P2 Planning Notice.

9.3 Labelling and Identification

Samples should be labelled so that they can be readily identified at all times. Sample labels should be durable, and be able to stay on the sample container even when wet. The ink used to mark a sample container label should be insoluble in water.

Labelling on samples should contain as much information as possible. The labels should specify a clear and unique identifying code that can be cross-referenced to the monitoring location and time of sampling. Labels may also contain the following:

• Date and time of sampling;
• Location and name of sampling site;
• Job or project number;
• Name of the sample collector;
• Container pre-treatment and preservatives added; and
• Observations that may affect the method or results of analysis.

The information listed above should also be recorded on the sampling sheet and retained as a permanent record.

9.4 Chain of Custody

COC procedures and documentation give confidence that the sample integrity has not been compromised. The COC documentation is a record used to trace possession and handling of a sample from collection, analysis, reporting and disposal.

COC control is based on the principle that a sample is always in someone’s custody and as such they are responsible for it. If the sample is far away from the location of the analytical laboratory, the sample collector may make use of a courier service to deliver the samples to the laboratory. The sample collector must ensure that the samples are not tampered with, by securing the lid of the sample cooler with tape so that it is obvious if the items have been tampered with. This will ensure the integrity of the COC. When the samples change custody, the new person who is responsible for them will sign and date the seal on the cooler so that the custody chain can be easily traced.

Prior to packing the samples, the sample collector should complete the COC form. The original form remains with the samples at all times to enable the completion of custody details at each stage of progression through transportation, analysis and reporting.

In order to confirm receipt and appropriate transfer and handling, a final copy of the COC form should be obtained from the laboratory. The laboratory should also include a copy of the completed COC form as part of their analytical report.

9.5 Data Review

It is important that the results of the sampling event analysis are reviewed prior to assessment and interpretation. Major issues in the quality of sampling or analysis can be highlighted via simple reviews. These reviews provide useful information on the accuracy and precision of sampling and analytical methods.

Compare duplicate samples results (if required): The variation between duplicate samples should be within the tolerances for the analytical procedure. Typically, differences between duplicates are quantified as a relative percentage difference (RPD), which is calculated using the following formula:

where R₁ is the result of sample and R₂ is the result of duplicate sample.

If the RPD is greater than 20%, an investigation into the cause should be initiated and documented.

Compare triplicate samples results (if required): The variation between triplicate samples should be within the tolerances for the analytical procedure. Typically, differences between triplicates are quantified as a percentage relative standard deviation (RSD), which is calculated using the following formula:

where σ is the standard deviation of the triplicate sample results and is the average of the triplicate results.

Intra-laboratory precision is considered generally good if the RSD is less than 10%^{Footnote 3}. If the RSD is greater than 20%, an investigation into the cause should be initiated and documented.

Review blank samples results: The concentrations of analytes of concern in blank samples should be below the detection limit. If high concentrations are reported, the sampling event will be thoroughly reviewed to determine whether contamination occurred.