Auditing Environmental Data
When reviewing any data generated for environmental purposes (or any business critical issue) the letters MMMD (or PMMD if you want to be politically correct!) is a useful mnemonic for me:
Man (or Person!) – who takes the originating sample (be it an emission or discharge), are they trained and competent? Do they have the required certifications if applicable (e.g. M-Certs)? You could even consider witnessing the sampling process.
Method – what is the process and procedure used? Is it an approved method (e.g. to the correct ISO, protocol, Blue Book method etc.). Consider also how the sample is taken and the sampling devices used (e.g. taking a clean water sample in a contaminated container is not good practice!). Where is the sample point – is it correct and appropriate (e.g. if in a process line, it should be on a straight run and not on elbows and bends). What about sample preservation, storage and chain of custody issues? These can be specific according to the determinand being sampled.
Machine – what is doing the analysis to generate the data? Is it appropriate and fit for purpose, does it have to be calibrated – if so to what level and standard? Do the people doing the calibrations have the necessary approvals (e.g. ISO 17025 or M-Certs)? What are the internal or external tolerances? Consider ranges, accuracy and precision.
Data – how is the analysis turned into a number? Are there any data interfaces and conversion processes used? If it’s compiled into a spreadsheet or database then are the formulas correct, what conversion factors have been used, are the units of measurement correct, have there been data transcription errors, what level of detail is required? Can the data be verified from the source information? What records are kept and how long do they have to be kept for (e.g. legal for requirements). What assurance processes are there in place, are there any internal audits of the data process, do there need to be documented procedures in place?
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