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Tribal Quality Systems

EPA R4 and USET - Innovative Approaches to Tribal Quality Systems
by Lisa Berrios on 15 August 2013

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Transcript of Tribal Quality Systems

Innovative Approaches to
Tribal Quality Systems

QMPs
QAPPs

About Region 4
The Response
Why this makes sense for R4
A Collaboration between
Tribes and EPA Region 4

Steve Terry, USET
Barbara Caprita, EPA R4
Lisa Berrios, EPA R4
Examples
Rotation of Drinking Water funds
SESD Technical Assistance
Solid Waste Peer Mentoring
Shared Support through USET
Challenges of a
6 Tribe Region
Funding
Workgroup representation
Economies of Scale
Quality Systems!
The Issues
Traditional QMPs and QAPPs do not work for many R4 Tribes
Technical support and resources are needed to support R4 Tribal quality system efforts
Role and responsibilities of key staff need to be identified
Improve review and approval processes and timelines
QMPs
Tribes requested joint approach
USET lead in development
Umbrella QMP
Tribe Specific QMPs
In process

QAPPS
Graded Approach
Adapted from Brownfields Model
Program Level QAPPs & Project/Site Specific
Accountability
Tribal QA Coordinator
Coordinated Review Process
POs included in training
Goal of 3 month review and approval
Flexible
Takes into account size, resource and capacity of Tribal environmental programs
Streamlines
Efficient – reduces redundancy
Reduce costs
Accelerates review and approval process
Not required; traditional QAPPs are still ok

Take Home Messages
Tribally Driven
Partnership between EPA R4 and Tribes
One size does not fit all
Make it Work for You
6 Federally Recognized Tribes
Tribal Population
33,500
.05% of R4 Total Population
300,000 acres trust lands
R4 Tribal
Snapshot
Benefits of a
6 Tribe Region
Camaraderie
Flexibility
Accessibility
Did you hear the one about the Captain
who sailed without a QAPP?
His ship QAPP-sized!
Places
Catawba River
Everglades
Great Smokey Mountains
The QA
Challenge

EPA Region 4 and Tribes Take Action
Umbrella
Quality Management Plan
A novel solution to EPA requirements
• EPA Requirements for Quality Management Plans EPA QA/R-2 (Document EPA/240/B- 01/002 March 2001) outlines how to develop a Quality Management Plan.
• Non-EPA Organizations, such as Tribes, are required to document their Quality System in a Quality Management Plan (QMP) as seen in 40 CFR 30, 31, and 35 for assistance agreement recipients.
Investigating
the Facts
• It is a means of documenting how a Tribe will plan, implement, and assess the effectiveness of its Quality Assurance and Quality Control (QA/QC) operations applied to all environmental programs.
• The process of planning, implementing, and assessing these management systems is Quality Management.
• The product of this process is the Quality System.
• Management and Organization
• Quality System Components
• Personnel Training and Qualifications
• Procurement of Items and Services
• Documents and Records
• Computer Hardware and Software
• Planning
• Implementation of Work Processes
• Assessment and Response
• Quality Improvement
Quality Elements
What Is A QMP?
Purpose - To document the overall policy, scope, applicability, and management responsibilities of the organization's quality system.
– Approval Page
– QA Policy Statement
– Organizational Chart
– QA Manager Authorities and QA Staff roles – List Technical Activities and Programs
– Quality System implemented and understood – Dispute Resolution Process, if needed
Management and Organization
Quality System Components
• Purpose - To document how an organization manages its quality system and defines the primary responsibilities for managing and implementing each component of the system.
– Describe the Quality System
– Implementation Tools for the Quality System
– Organizational Components of the Quality System
Personnel Training and Qualifications
Purpose - To document the procedures for assuring that all personnel performing work for an organization have the necessary skills to effectively accomplish their work.
-Policy Statement regarding training
Identify and document that personnel have and maintain the appropriate knowledge, skill, and professional or other certifications, accreditations, licenses, or other formal qualification necessary
-Retraining based on changing requirements
Investigating
more Facts
Procurement of Items and Services
Purpose - To document the procedures for purchased items and services that directly affect the quality of environmental programs.
-Review and approve procurement documents for accuracy
-Review and approve applicable responses to solicitations
-Acceptable quality of procured items and services is adequate

Documents and Records
Purpose-To document appropriate controls for quality-related documents and records determined to be important to the mission of the organization.
-Identify quality related documents and records
-Review for conformance to technical and quality system requirements
-Records and documents accurately reflect completed work
-Maintain documents and records, including disposal
-Establish and implement appropriate chain of custody and confidentiality
Computer Hardware and Software
Purpose - To document how the organization will ensure that computer hardware and software satisfies the organization's requirements.
*Existing computer hardware and software performance is compatible with user requirements
*Purchased computer hardware and software meets user requirements
*Data and information produced from computers meet resource management requirements
Planning
Purpose--To document how individual data operations will be planned within the organization to ensure that data or information collected are of the needed and expected quality for their desired use.
-Using a systematic method for planning purposes
-Develop, review, approve and revise a Quality Assurance Project Plan
-Evaluate and qualify data collected from other sources or other uses for a new use
Implementation of Work Processes
Purpose - To document how work processes will be implemented within the organization.
-Work follows approved planning and technical documents,
-Identify where Standard Operating Procedures (SOPs) are needed.
-Review, approve, revise and withdraw SOPs.
-Document use of SOPs.
Assessment and Response
Purpose- To document how the organization will determine the suitability and effectiveness of the implemented quality system and the quality performance of the environmental programs to which the quality system applies.
-Assess Quality System Annually.
-Implement assessment and report results to management.
-Determine personnel qualifications for conducting assessment.
-Personnel have authority to conduct assessment.
Management’s response.
-Identify corrective actions and implement same.
-Resolve disputes caused by assessment

Quality Improvement
Purpose - To document how the organization will improve the it's quality system.
-Ensure conditions which affect quality are:
*Prevented, identified, and corrected as soon as possible
*Document corrective actions
*Track corrective actions to closure.
-Encourage staff at all levels to communicate the Quality System, identify improvements, and offer solutions.

Challenges
Some Definitions first.
Tribal QA Manager – The Person identified by the Tribe as being responsible for certifying and administering the Quality System.
Tribal Project Manager – The Tribal Staff Person designated as being in charge of a project.

How do Tribes with small environmental staff cope with the nuances of a Quality System?
Does the Tribal Project Manager become the Tribal QA Manager with subordinate staff becoming Tribal Project Manager for this purpose?
Will that lead to a conflict of interest or unwillingness of staff to speak up on Corrective Actions?
How will Quality Assurance Project Plans play out under the Quality System?

Potential Solutions
*Have EPA act as an environmental adviser to the Tribal QA Manager. This way, someone other than environmental staff can be the Tribal QA Manager.
*This will assist in resolving conflict of interest and unwillingness of staff to speak up.
*QAPPs are the backbone of the Quality System.
*Conversely, SOPs are the backbone of QAPPs.
EPA Region 4 Approach
Region 4 is taking the Graded Approach
This Means
-EPA recognizes that a “one size fits all” approach to QMPs will not work.
-For example, the QMP for a fundamental research program to determine Air Quality Standards for a specific region is different from a Tribal Program collecting Air Quality data on the Reservation.
-The Graded Approach means that Quality Systems for different Tribes and Tribal programs will vary according to the specific objectives and needs as stated in the Scope of Work.

-EPA R4 Tribes suggested an Umbrella QMP be developed
-EPA contracted with United South & Eastern Tribes, Inc. (USET) to develop an Umbrella QMP
-USET developed the Umbrella QMP which contains specific generic language
-Tribes will compose their own specific QMP

-Tribes can reference the Umbrella QMP which allows their QMP to be less wordy
-Tribal QMP will demonstrate specific Tribal needs applicable to their Quality System
-Tribal QMP will include Tribal Program Level QAPP and Project/Site Specific QAPPs
-SOPs will be the starting point for developing Tribal QAPP

The Umbrella QMP is
Tribally Driven
Take Home Message
Preparing A Program Level & Project/Site-Specific QAPP
An Alternative Streamlined Approach to Traditional Quality Assurance Project Plans
There once was a man named Dan
Who wasn't an organized man
He played it by ear
His boss fired his rear...
Dan should've used the QA Plan!!
A Few Words About
this Presentation
1) Assumes you know the basics of why Non-EPA organizations funded by EPA are required to develop a QA Project Plan.

2) The slides provide an overview of the Region 4’s approach for QAPPs- Program Level and Project/Site-Specific QAPP.

the graded approach
One Size Does Not Fit All!
The Graded Approach
The level of detail in each QAPP will vary according to the nature of the work being performed and the intended use of the data.
If a Grant or Project is small and/or the QA requirements are minimal a QAPP can be less complicated.
*Use common sense!
*The complexity or lack of it will be a big factor.
*The size of the grant is also a major factor.
*Many sections of the QAPP may not be applicable. If so, use N/A to indicate
*Program – Level QAPP and Project/Site-Specific QAPPs may work for you!

Planning your project and writing the QAPP

EPA requires that you plan and document certain aspects of your project including:
1) Project Management - how you will organize and run the project
2) Measurement and Data Acquisition - how you will collect and report data
3) Assessment and Oversight - how you will check that all activities are completed correctly
4) Data Evaluation - how you will review and interpret the data

Program Level and Project/Site-Specific QAPPs
*Ensure the necessary level of quality for all projects is covered by the Program Level QAPP.
*In contrast to a traditional QAPP, the Program Level QAPP serves as an umbrella under which multiple data collection, production and use activities may be conducted over an extended period of time.
*Project/Site-Specific QAPP serves as a plan for the project or site.
*Saves time and money, and streamlines the review and approval process.
The Process
*Program Level QAPP is developed first
-Consists of routine processes and procedures
*EPA Approves Program Level QAPP
*Project/Site-Specific QAPP(s) are developed
-Initial Project/Site-Specific QAPP
-Project/Site-Specific QAPP Addenda

Tribe ABC has a growing environmental program. In addition to a GAP grant for capacity building, the Tribe has water and air monitoring programs, and is assessing contamination at a former gas station for proposed reuse as a community park. The Tribe has had a CWA 106 grant for 3 years, and recently adopted new testing protocols for Memorial Lake.
Tribe ABC has an EPA approved Program Level QAPP that addresses the routine components of the Tribe’s quality assurance system. The Tribe has also developed Project/Site Specific QAPPs for the Roaring River location and the Memorial Lake location. The Tribe has submitted a revised Project/Site Specific QAPP providing new testing protocols for Memorial Lake.
The Tribe has air monitoring sites at the Tribal Administration Building and at Old Town. PM 2.5 and ozone is monitored at both locations. Based on EPA guidance, the Tribe has developed pollutant specific QAPPS for ozone and PM 2.5. Each pollutant-specific QAPP includes both monitoring locations.

Case Study
Standard Operating Procedures
*Use SOPs for QAPP
*SOPs provide consistency
*Reference SOPs in appropriate element
*Attach SOP in appendix or include on a CD
*Utilize EPA Region’s SOPs

Would You Like to Test Drive? Checklist of
What is Needed to Start
Existing QMP and QAPPs
Awards and Workplans
Tribal organizational chart
SOPs
R 4’s Tribal QAPP Instructional on the DVD/CD
R4’s Template for Program Level QAPP on the DVD/CD
R4’sTemplate for Project/Site-Specific QAPP on the DVD/CD
In Closing
We wanted to provide you with an overview of EPA Region 4’s approach to Tribal QAPPs -Program Level and Project/Site Specific QAPP.

For you: DVD/CD with Instructions for QAPPs, Template for Program Level QAPP and Template for Project/Site-Specific QAPP.
Questions?
Contacts
Lisa Berrios, Region 4 Tribal Relations Coordinator, Regional Administrator’s Office, (404) 562- 8318
berrios.lisa@epa.gov
Steve Terry, Senior Project Coordinator, Tribal Community Support, USET
sterry@usetinc.org
Until August 30 Barbara Caprita, Region 4, (404) 562-8415
caprita.barbara@epa.gov
See the full transcript