Facility Audit: Deer Park, TX - Clean Harbors

A. Standardized Documentation
Standardized documentation is necessary if the goal of consistent laboratory procedures within
the corporation is to be realized. Such documentation includes the following:
• Standard operating procedures for sampling
• Standard operating procedures for analytical methods
• Quality assurance/control procedures
• Data management and reporting procedures
B. Standardized QA/QC and Analytical Procedures
The basis for most of the analytical procedures used EPA SW-846, Standard Methods for
Wastewater Analysis, and ASTM methods. Calibration frequency, duplicate and spike
frequency, data reduction and review, etc., are defined in the referenced methods and Clean
Harbors enforced through corporate procedures. Quality control techniques are employed to
ensure that measurement processes are maintained within acceptable levels of accuracy and
reproducibility.
C. Performance Evaluation Samples
The use of performance evaluation samples employed in "round robin" evaluations contribute to
the objective assessment of a laboratory's analytical abilities. Deer Park labs are engaged in EPA
performance evaluation programs for DMR (Discharge Monitoring Reporting).
Quarterly “round-robin” performance evaluation program addresses commonly analyzed
parameters and is administered by the Clean Harbors corporate designated laboratory to further
supplement the program.
External laboratories which provide analytical services to Clean Harbors facilities must be able
to demonstrate acceptable performance on EPA administered performance evaluations and/or
those from state certification programs, when appropriate, upon request. They may be required
to participate in the Clean Harbors audit program.
Participation will depend upon the scope of services provided. Acceptable performance on these
evaluations is an important aspect of a laboratory's ability to defend the data which it generates.
D. Staff Training
Deer Park trains staff in procedural technique and in understanding the basic needs and reasons
for a quality program used for samples of incoming waste loads and plant generated wastes.
Training is provided by qualified facility staff, Clean Harbors personnel, or an instrument
manufacturer’ representative. The training location may be on-site or at a manufacturer's
location.
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