SIR #: 399
Section: V1M6, Section 188.8.131.52
Section 184.108.40.206.d states that all radiochemical results shall be reported with an estimate of uncertainty, as discussed in Section 1.5.4.
However, section 220.127.116.11.f states that “project- or client-specified reporting requirements can take precedence over the requirements of this Standard”.
Does part f, section 18.104.22.168 supersede section 1.5.4.b and 22.214.171.124.d if a client requests that all types of radiochemistry uncertainty (i.e., Total uncertainty, counting uncertainty, Standard Uncertainty, k-factors) in section 1.5.4.b shall not be included on the report?
TNI FINAL RESPONSE:
Section 1.7.3 applies to Data Evaluation and Reporting, with 126.96.36.199 (Reporting Results) specific to results shown on the final deliverable(s) to the client. 188.8.131.52.f was included in acknowledgement that certain programs (e.g. SDWA) target a level of uncertainty based upon method requirements (e.g. detection limit goal), and that State reporting forms, which may be filled out by the laboratory, often do not include a place to list the uncertainty. If a client does not want to see any uncertainty results on their final report, that is their prerogative (although in the Committee’s opinion the result is not “complete” without some form of uncertainty). However, this does not absolve the lab of the requirements of other sections of Module 6 or the Standard as a whole, including Module 2, Section 5.10 (Reporting the Results). The third paragraph in Module 2, Section 5.10.1 states:
“In the case of tests or calibrations performed for internal customers, or in the case of a written agreement with the customer, the results may be reported in a simplified way. Any information listed in 5.10.2 to 5.10.4 which is not reported to the customer shall be readily available in the laboratory which carried out the tests and/or calibrations.”
Thus, regardless of what is presented on the report, the uncertainty must be determined by the laboratory and readily available. And, if a client requests data be “reported in a simplified way”, the laboratory must maintain the written agreement. Also, note that Module 2, Section 184.108.40.206 requires that the report shall include “a statement of compliance/non-compliance with requirements and/or specifications”.