Guide to Writing Quality Assurance 

Project Plans for Ambient Air 

Monitoring Networks 
EPA-454/B-18-006

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This Page Intentionally Left Blank

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Guide to Writing Quality Assurance Project Plans for Ambient 

Air Monitoring Networks 

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Air Quality Assessment Division

Research Triangle Park, NC

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Table of Contents

QAPP Purpose..................................................................................................... 1

QAPP Structure Overview ................................................................................... 2

QAPP Elements................................................................................................... 4

Section 1: QA Project Plan Identification and Approval .......................................................................... 5

Section 2: Table of Contents.................................................................................................................... 6

Section 3: Distribution / Notification List................................................................................................. 6

Section 4: Project/Task Organization....................................................................................................... 7

Section 5: Problem Definition/Background ............................................................................................. 9

Section 6: Project/Task Description ....................................................................................................... 10

Section 7: Quality Objectives and Criteria for Measurement Data ....................................................... 11

Section 8: Training.................................................................................................................................. 13

Section 9: Documentation and Records................................................................................................. 14

Section 10: Network Description (or Sampling Process Design)............................................................ 16

Section 11: Sampling Method Requirements ........................................................................................ 17

Section 12: Sample Handling and Custody ............................................................................................ 18

Section 13: Analytical Methods ............................................................................................................. 20

Section 14: Quality Control Requirements ............................................................................................ 21

Section 15: Instrument/Equipment Testing, Inspection, and Maintenance Requirements..................24

Section 16: Instrument Calibration and Frequency ............................................................................... 25

Section 17: Inspection/Acceptance Requirements for Supplies and Consumables ..............................26

Section 18: Non-Direct Measurements.................................................................................................. 26

Section 19: Data Management .............................................................................................................. 27

Section 20: Assessment and Response Actions...................................................................................... 28

Section 21: Reports to Management..................................................................................................... 30

Section 22: Data Validation and Usability.............................................................................................. 31

Section 23: Validation and Verification Methods.................................................................................. 33

Section 24: Reconciliation with Data Quality Objectives....................................................................... 35

Completed QAPP? A Few Reminders Prior to Submittal to EPA! .......................................................... 36

Additional References....................................................................................... 38

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Disclaimer

The statements in this document, with the exception of referenced requirements, are intended solely as 

guidance. This document is not intended, nor can it be relied upon, to create any rights enforceable by 

any party in litigation with the United States. This guidance may be revised without public notice to 

reflect changes in EPA’s approach to implementing 40 CFR Parts 50, 53, and 58.

Mention of commercial products or trade names should not be interpreted as endorsement. Some types 

of instruments currently in use in monitoring networks may be described within this guide. Sometimes 

these products are given as a typical and perhaps well-known example of the general class of 

instruments. Other instruments in the class are available and may be fully acceptable.

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Acknowledgements

This document began as part of a project in EPA Region 4 to develop a new tool to assist Region 4

State/Local/Tribal (SLT) air monitoring organizations with writing and/or revising Quality Assurance 

Project Plans (QAPPs) for ambient air monitoring networks. The initial product was developed through 

collaboration between Stephanie McCarthy (EPA Region 4), Jason Bodenhamer (Forsyth County Office of 

Environmental Assistance and Protection), and Melinda Ronca-Battista (Institute of Tribal Environmental 

Professionals) and shared with Region 4 S/L/Ts in October 2017.

In December 2017, an EPA QAPP Workgroup formed with a goal of finalizing the document such that it 

could be used as a new tool to assist personnel in any S/L/T monitoring organization across the EPA 

Regions. Workgroup members included EPA quality assurance (QA) and ambient air monitoring 

technical staff responsible for reviewing and approving QAPPs submitted by S/L/Ts. The document was 

peer-reviewed by additional EPA QA staff in the Regional Offices and the Office of Air Quality Planning 

and Standards (OAQPS). The following EPA staff are acknowledged for their contributions: 

Region 1: Robert Judge, Peter Kahn

Region 2: Mustafa Mustafa

Region 3: Verena Joerger, Kia Long

Region 4: Anthony Bedel, Stephanie McCarthy

Region 5: Bilal Qazzaz

Region 9: Mathew Plate, Roseanne Sakamoto

Region 10: Chris Hall 

OAQPS: Michael Papp

Names that appear in bold are the members of the EPA QAPP Workgroup.

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QAPP Purpose 

A Quality Assurance Project Plan (QAPP) is your agency’s specific planning document for conducting a 

specific monitoring project. It is an overview of your agency’s specific business rules, policies, and

quality assurance/quality control (QA/QC) procedures for conducting the monitoring project – in other 

words, it is how your agency plans to assure the quality of your project’s data. The QAPP is designed to 

help your agency produce high quality data in a consistent manner. It is designed to help improve 

communications with all staff involved with the monitoring project, as well as detail their responsibilities 

such that all parties are aware of their roles within the project. The QAPP also helps participants 

understand the importance of the specific monitoring project and can serve as both a training guide and 

legacy documentation.

40 CFR Part 58, Appendix A, Section 2.1.2 states:

The QAPP is a formal document describing, in sufficient detail, the quality system that must be 

implemented to ensure that the results of work performed will satisfy the stated objectives. 

[Primary Quality Assurance Organizations (PQAOs)] must develop QAPPs that describe how the 

organization intends to control measurement uncertainty to an appropriate level in order to 

achieve the data quality objectives for the [environmental data operation (EDO)]. The quality 

assurance policy of the EPA requires every EDO to have a written and approved QAPP prior to 

the start of the EDO. It is the responsibility of the PQAO/monitoring organization to adhere to this 

policy. The QAPP must be suitably documented in accordance with EPA requirements (reference 

3 of this appendix) and include standard operating procedures [SOPs] for all EDOs either within 

the document or by appropriate reference. The QAPP must identify each PQAO operating 

monitors under the QAPP as well as generally identify the sites and monitors to which it is 

applicable either within the document or by appropriate reference. 

Reference 3 in the above quote is the EPA document EPA Requirements for Quality Assurance Project 

Plans (EPA QA/R-5).

The QAPP can and should contain generalities that explain specific concepts, define terms, and so forth; 

however, the QAPP is not a guidance document. Instead, the QAPP is the complete picture of how the 

specific project will be planned, implemented, evaluated, and reported by your agency. 

Writing a QAPP requires a good knowledge of the ambient air monitoring program and quality assurance 

(QA) ahead of time. The QAPP writer should have access to the Code of Federal Regulations (CFR), 

specifically 40 CFR Parts 50, 53, and 58, and EPA guidance when preparing a QAPP, in addition to the 

agency’s Quality Management Plan (QMP) and any other relevant policies, state regulations, and so 

forth. References to assist the QAPP writer are provided throughout this guide and at the end of the 

document in the References section. 

The QAPP must be written and approved before monitoring commences. By establishing the agency’s 

plan and business rules up front, decision-making during the project should be consistent. 
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Please note that when developing some agency-specific practices for a particular project, instrument 

testing may need to occur. Any data collected during this experimental phase should not be used in 

decision making. 

QAPP Structure Overview 

EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5) specifies the required elements 

within a QAPP. The EPA QA/R-5 document states that the QAPP must be composed of standardized, 

recognizable elements covering the entire project from planning, through implementation, to 

assessment. Typically, there are 24 elements within a QAPP. To simplify the QAPP development

process, EPA provides flexibility to agencies based on a project’s specific objectives; by supporting a 

“graded approach,” all 24 elements may or may not need to be addressed, depending on the QAPP 

category. See Appendix C of the EPA Quality Assurance Handbook for Air Pollution Measurement 

Systems Volume II (January 2017) for more information on the graded approach and QAPP categories. 

For a QAPP that is designated as a “Category 1 QAPP” – which describes projects used to directly 

support rulemaking, enforcement, regulatory, or policy decisions – all 24 elements must be included. 

With that in mind, regulatory ambient air monitoring QAPPs – such as those created for State or Local 

Air Monitoring Stations (SLAMS) monitoring – are Category 1 QAPPs and must discuss, to the best extent 

possible, all 24 elements. No element should be omitted. This guide will discuss all 24 elements of a 

Category 1 QAPP, but serves as a framework for other air monitoring QAPPs (i.e. Categories 2-4) as well. 

There are 3 conventions for structuring the 24 elements within ambient air monitoring QAPPs. Any of 

these 3 structures are acceptable. One structure includes numbering QAPP elements 1 – 24 in straight 

numerical order. The other structures divide the QAPP into 4 sections and number them either 

numerically or alphabetically (for example, Section 1.1, 1.2, 1.3, 2.1, 2.2, 2.3, and so on, or Section A1, 

A2, A3, B1, B2, B3). 

The cross-walk that follows lines up the different structures.

For simplicity, the QAPP elements described in this guide will use Sections 1 – 24. Regardless of the 

QAPP structure’s naming convention, the following describes the sections of the QAPP and what they 

aim to accomplish:

• Sections 1 – 9 (or Group 1 or A) describe the overall plan for the monitoring project (i.e., project

management).

• Sections 10 – 19 (or Group 2 or B) describe how the plan will be implemented (i.e., data

generation and acquisition).

• Sections 20 – 21 (or Group 3 or C) describe how the project will be assessed and at what

frequency (i.e., assessment and oversight).

• Sections 22 – 24 (or Group 4 or D) describe how the resulting data will be evaluated (i.e., data

validation and usability).
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QAPP Structure Cross-Walk
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QAPP Elements 

Because a QAPP is a plan, written before the project commences, its QA/QC commitments should, 

ideally, be written in future tense (e.g., “The agency will perform...). 

The use of citations to reduce verbiage and redundancy in writing is encouraged. However, the use of 

citations should be specific, in order to point the reader to the particular information that is needed

within the referenced material. For example, if citing the CFR, use the specific, complete reference (e.g.,

40 CFR 58.16, 40 CFR Part 58, Appendix A, Section 2.3.1, etc). If citing an agency SOP, point the reader 

to the specific section or chapter within the SOP where the necessary information can be found (e.g., 

“See Data Validation SOP, Revision 1, Section 4.2(b)”). You can also use citations for specific sections 

within the QAPP itself, so that information does not have to be repeated verbatim. For example, “See 

Section 9.4 of this QAPP for more information.”

Additionally, the following items are recommended best practices to enhance the appearance and 

usability of the QAPP, as well as improve document control.

 A Cover Page is recommended for the QAPP. If used, inclusion of the agency’s logo is suggested. 

 Include a header which contains the following information: 

• document control number or unique identifier, 

• the version/revision number,

• the version/revision date, and 

• page numbering. 

Header Notes: 

1. Page X of Y format is recommended as the best numbering practice. 

2. The header generally is not included on the cover page, but will start with the first page 

following the cover page. However, it is acceptable to include the header on the cover 

page.

 An Acronym List is recommended for the QAPP. It can be included after the cover page, prior to 

Section 1, or it can be included as an appendix at the end of the document. The Acronym List 

does not have to be long and should only include acronyms used within the QAPP.

 References (i.e., bibliography) can be included in the document. If compiled, it is recommended

that all references be included at the end of the QAPP, as a final section or appendix.

 If this is a QAPP revision, a Revision History section is recommended. If used, update the 

Revision History section henceforward, summarizing the changes made on future revisions. 

Revision Histories do not need to contain lengthy explanations or detail every edit, but rather 

summarize the changes so that they can be more easily tracked over time. Revision Histories 

can be placed at either the beginning or end of the document. 
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Example:

Revision Number Date Responsible Party Description of 

Change

1 1-8-16 John Operator Section 4.0: Revised and 

lowered calibration scale. 

Added information on 

automated calibrations.

Section 4.2. Changed audit 

point concentrations.

2 1-4-17 John Operator Revised Section 4.1: 

certification frequency 

changed to annual. 

3 1-8-18 John Operator Changes throughout 

document as a whole due 

to instrument model 

upgrade; new figures and 

tables, additional QA/QC, 

and new maintenance 

requirements added.

 If this is a new QAPP, a Revision History page is not needed. (Note: Recommend that a “0” be 

used as the Revision Number for a new document.) However, if desired, a Revision History page 

(table) can be created that will serve as a placeholder for future revisions.

Example:

Revision Number Date Responsible Party Description of 

Change

0 1-3-18 Jane Author New Document; 

Initial Release

Section 1: QA Project Plan Identification and Approval 

Reminder: Sections 1 – 9 discuss project management.

In this section of the QAPP – which is typically just 1 page – include the following information: 

• Name of the agency

• The official title of the QAPP, along with the version/revision number

• A statement that commits the agency to adhere to the requirements of the QAPP
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• Placeholders for the signatures of staff members (include position titles) in the chain-ofcommand who need to review and approve the document, including the agency’s Quality 

Assurance Officer/Manager (or equivalent)

• Signature line for the EPA Designated Approving Official

Example Language:

Title: _________________________________________

The attached QAPP is hereby recommended for approval and commits ______Agency’s Name_________ 

to follow the elements described within.

Section 2: Table of Contents 

For this section of the QAPP, list the titles of all sections, subsections, and appendices (if applicable)

found within the document. Provide associated page numbers for all sections, subsections, and 

appendices. 

Include a separate “List of Tables and Figures” that follows the main contents. Provide page numbers 

for all tables and figures. It is recommended that tables be listed first, followed by figures.

Section 3: Distribution / Notification List 

For this section of the QAPP, list the names and titles of the individuals involved in the project who will 

be notified of the QAPP and receive a copy. This should include any partnering agencies and 

contractors/subcontractors who participate in the project. Include an address/location for each 

individual (can also include email addresses and phone numbers). The distribution list can be presented 

in tabular format (such as the following table structure) or the information can be detailed out in a list.

Distribution/Notification can be in hardcopy form, electronic, or both. 

Name Position Division/Office Address/Location

The individuals in this list will be notified/receive copies of any QAPP revisions or amendments during 

the course of the project. Revisions and amendments must be approved prior to implementation and 

distribution. Please note that if the PQAO for which the QAPP is being prepared includes multiple 

organizations, the distribution list for the QAPP may need to be abridged. In this case, include the above 

information for the key project personnel, including upper management and QA staff, from all 
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organizations within the PQAO. Then, add a disclaimer, such as the following: “The QAPP will be 

distributed to other personnel and operators beyond this list, in accordance with the organizational 

chart(s) presented in Section 4 of this QAPP.” 

The location of the official, controlled version of the QAPP should be identified. This could be a signed 

hardcopy located in a centralized records repository, an electronic version maintained on the agency’s 

local area network (LAN), or an electronic version maintained on the agency’s website (recommended), 

among other locations. 

Section 4: Project/Task Organization 

This section of the QAPP discusses the roles and responsibilities of all key players in the project, 

illustrating the chain-of-command and lines of communication. This section clarifies which positions 

have been delegated authority to complete particular tasks.

Include organizational chart(s) in this section. Is an independent QA function demonstrated in the 

chart(s)? If not, the verbiage in this section should clarify which position(s) serve in a QA oversight role 

and demonstrate, through the stated duties, the QA function. The verbiage in this section should 

match/clarify what is illustrated in the organizational chart. The terminology that is used to define 

positions should be used consistently throughout the QAPP. Ideally, the terminology should follow into 

the agency’s SOPs as well.

Include discussion of any contractors/subcontractors or partnering agencies in this section and describe 

the tasks they perform. Explain the lines of communication with these partners. For example, does the 

laboratory QA Officer contact the agency’s QA Officer when there are issues? Or, would a laboratory 

manager contact the Air Program Manager in such times? Describe the process established for your 

project. 

This section of the QAPP also identifies the Primary Quality Assurance Organization (PQAO) under which 

the agency operates. If multiple monitoring organizations operate under a single PQAO, each 

monitoring organization must be identified with the QAPP and the lead agency clearly identified.

When describing the responsibilities of the key positions, answer the following questions (if applicable 

to your network):

• Does the agency operate under an approved quality management plan (QMP)? Is it referenced 

somewhere within the section?

• Who has the authority to stop work? For example, if there is a personnel/equipment safety 

issue in the field due to an approaching storm, who could order a site to power down? Similarly, 

if an assessment shows severe data quality issues, who could issue an order to halt data 

collection until corrective actions have been implemented?

• Who has the authority to direct work to resume after a stoppage?

• Who has authority to install additional monitors within the network, or to order monitors to be 

discontinued or replaced?
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• Who is primarily responsible for developing the Annual Network Plan (ANP) and the 5-year 

Network Assessment?

• Who serves as a liaison to the EPA Regional Office and is the primary point of contact? 

• Who is the “tie breaker” (i.e., final decision maker) when a disagreement exists? This is 

especially important with regards to data validation activities. Often, this is the agency’s QA 

Officer/Manager (or equivalent).

• Who verifies data? 

• Who validates data?

• Who certifies data?

• Who is ultimately responsible for the quality of the project’s data? (This may or may not be the 

same person who performs data certification activities and generates the requisite reports.) 

• Who is responsible for writing the agency’s QAPP/SOPs? Who is responsible for revising and 

maintaining them? (These may not be the same individuals.)

• Who is responsible for ensuring QAPP/SOP revisions are communicated and distributed to all 

parties in the distribution list?

• Who is the AQS Administrator for the program? Similarly, who is responsible for AQS data 

entry? (These may not be the same individuals.)

• Who manages other database systems (such as EDAS, AirVision, Envidas)?

• Who manages the agency’s air monitoring documents and records?

• Who tracks inventory and orders supplies/consumables, when needed? (These may not be the 

same individuals.)

• Who operates, calibrates, and performs required quality control (QC) checks on 

analyzers/samplers?

• Who performs preventive maintenance? Instrument repairs?

• Who certifies/verifies standards (if performed in-house)? 

• Who tracks the certification of standards to ensure that all used within the network are National 

Institute of Standards and Technology (NIST)-traceable and accurate?

• Who collects physical samples, such as particulate matter (PM) and lead?

• Who conducts performance audits? Systems audits? 40 CFR Part 58, Appendix E siting 

evaluations?

• Who judges the success of corrective actions, once implemented, to ensure they are 

appropriate and effective?

• Who oversees training for the ambient air monitoring program?

• Who performs gravimetric analyses of PM filters (e.g., an individual within the monitoring 

program, an inter-departmental laboratory, or a contractor laboratory)?

• Who performs analyses of lead and/or air toxics samples (e.g., an inter-departmental laboratory, 

a contract laboratory hired by the agency, or an EPA national contract laboratory)?

• If operated in-house, who is the laboratory analyst? 

• Is there a lab supervisor? If not, who oversees the work of the laboratory analyst?

• Who serves as a liaison to the laboratory, especially if laboratory activities are outsourced?

• Is there a back-up laboratory in place? If so, identify the laboratory and explain the potential 

responsibilities (i.e., which analyses, etc).
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• If utilizing a contractor(s), who within the agency is responsible for contractor oversight and 

assessment of deliverables? 

• Are the district/regional offices within the PQAO accounted for?

• Are all agencies operating under a multi-organizational PQAO accounted for?

Section 5: Problem Definition/Background 

In this section of the QAPP, state the specific environmental problem that is to be investigated, decision 

to be made, or outcome to be achieved. For example, if the QAPP is being developed for a SO2 DRR 

Project, then this section will detail the promulgation and implementation of the regulations related to 

the SO2 DRR and provide a timeline on how the monitoring project will be carried out at your agency. 

Similarly, if the QAPP is for SLAMS criteria pollutant monitoring, this section will provide information on 

the Clean Air Act (CAA), the National Ambient Air Quality Standards (NAAQS), and the specific agency’s 

formation of an ambient air monitoring network to determine compliance with the NAAQS.

Include sufficient background information in this section to provide a historical, scientific, and/or 

regulatory perspective for the project. If data has been collected in the past or this is a revised QAPP, 

historic information / data should be summarized. For example: An ongoing SO2 monitoring project, 

where historic data showed the area to be non-attainment – which prompted an expansion of the 

network near a source(s) and the need for additional data. 

The document review cycle for the QAPP and, ideally, its associated SOPs should be included. As a best 

practice, monitoring organizations should document the annual review of the QAPP, and record the 

review date and name/signature of the individual completing the review (even if no revisions to the 

document were required). The method for documenting and tracking the QAPP review cycle could be 

documented in this section, which is an important part of an organization’s quality system. Or, this 

information could be presented in Section 9 of the QAPP. 

When describing the project background, answer the following questions:

• What is the environmental problem / issue to be studied?

• Which specific pollutant(s) is the QAPP addressing?

• What is the background / history of the problem?

• Why is this project important?

• Is this a regulatory criteria pollutant network? If so, describe the CAA & the applicable NAAQS. 

• Is a specific regulation driving the project? If so, specify which one (e.g., the SO2 DRR). Explain 

how the specific regulation resulted in your agency initiating this monitoring project. 

• Is this an on-going, long-term regulatory monitoring project? If so, when was the project start 

date? If unknown, approximate how long the monitoring network has been operational.

• Is this a short-term project? Is it regulatory or research-based? 

• Is this a new QAPP or the revision of an existing QAPP? If it is a revision to an existing QAPP, 

when was the original QAPP developed for this project?

• How many years of monitoring data are needed to fulfill the project’s data requirements?
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Section 6: Project/Task Description 

In this section of the QAPP, provide a summary of the work to be performed. If this is for a new air 

monitoring project (such as the SO2 DRR example), then provide a schedule (timeline) for 

implementation and expected milestones. If this is for an existing SLAMS criteria pollutant monitoring 

network, an implementation schedule is not needed since the monitoring network is already established

(and earlier versions of the QAPP can be reviewed to find this information). With this in mind, Section 5 

should contain enough historical information to explain that the monitoring network has been 

established for (X) years; resultantly, the QAPP establishes procedures that continue to maintain the 

existing network. 

Include a general overview of the pertinent work activities for this project, such as field activities and

sampling, laboratory activities, data review and assessments, and products/reports to be generated. 

Include a list or table with the assessment schedule in this section. The assessments themselves do not

have to be explained in this section – instead, they should be explained later in Section 20. 

Also include a table with the critical documents and records that will be maintained during this project. 

Cautionary Notes: 

1. An example critical document table was provided in the Model QAPP for the PM2.5

Program used by many air monitoring agencies in the late 1990s/early 2000s. Do not

include documents/records in this table that your agency does not actually maintain. (A 

common example here is “control charts.”) Instead, augment this table with any 

documents or records that you do maintain that are unique to your agency and not 

included. You can describe the documents using your agency’s terminology, but be sure 

to define those terms within the body of the QAPP. 

2. Documents listed in this table should be discussed in more detail in Section 9. Make sure 

the documents listed in the table in Section 6 mesh with the documents discussed in 

Section 9. 

When summarizing the project, answer the following questions:

• What is the monitoring objective(s)?

• Does the section summarize the work that is required to collect, document, and report the 

ambient monitoring data? For example, for this project you will need to: design a network and

deploy instrumentation; develop procedures; establish QA/QC criteria; perform assessments; 

validate data; and report the data to AQS. 

• What measurements are expected to be taken during this project? In other words, what types 

of data will be collected and reported to support the monitoring objectives? (Ambient data, 

QA/QC data, site metadata, etc)

• What regulatory standards are pertinent to the project (e.g., SO2 DRR)?

• What are the typical field activities performed in your network to support the project?

• What are the typical laboratory activities performed in your network to support the project?
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• Are laboratory activities contracted out?

o Who is the contract lab? 

o Does your agency maintain copies or have access to the laboratory’s QAPPs and SOPs? 

If so, where are these documents found (or how do you access them)?

o How do you maintain QA oversight of the laboratory work and resulting data? Provide a 

brief summary of the steps taken by your agency to ensure the contract laboratory will 

provide services and produce data that can meet the project’s objectives. 

• What are the required assessments and who is responsible for completing them? 

Section 7: Quality Objectives and Criteria for Measurement Data 

In this section of the QAPP, define the quality objectives and criteria for the ambient air monitoring 

project. This section is the core of the document, because all of the agency’s business rules for data 

quality should be summarized here – and subsequent sections of the QAPP will reference the criteria 

established herein. 

The Data Quality Objectives (DQO) process is a series of logical steps that guides managers or staff to a 

plan for the resource-effective acquisition of environmental data. It is both flexible and iterative, and 

applies to both decision-making (e.g., compliance/non-compliance with a standard) and estimation (e.g., 

ascertaining the mean concentration level of a pollutant). The DQO process is used to establish 

performance and acceptance criteria, which serve as the basis for designing a plan for collecting data of 

sufficient quality and quantity to support the goals of the study. This formal 7-step process is described 

in the EPA document Guidance on Systematic Planning Using the DQO Process (EPA QA/G-4, February 

2006). Please see this document for more information on the DQO process.

EPA utilized the DQO process to establish the DQOs for the criteria pollutant network; because of that, 

State/Local/Tribal air monitoring organizations (S/L/Ts) collecting data for NAAQS decision-making 

purposes do not have to go through the seven steps of the DQO process themselves. With that in mind, 

this section of the QAPP does not have to list the 7 steps of the DQO process and describe how EPA

performed those steps. The same holds true for other monitoring programs in which EPA utilized the 

DQO process to establish the quality criteria that will be utilized by project participants. However, if the 

monitoring agency is not monitoring for NAAQS compliance, or if the project itself has additional DQOs 

beyond those found in the CFR, those DQOs should be described here, along with a description of the 

process used by the agency to develop the objectives in order to meet the needs of the data user. 

DQOs are qualitative and quantitative statements that:

• Clarify the intended use of the data (Why are the data needed?)

• Define the type of data needed (What measurements are required and what do they need to 

represent?)

• Specify the tolerable limits on the probability of making a decision error due to uncertainty in the

data (How much measurement uncertainty can be tolerated in the data set?)
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For the S/L/Ts collecting data for regulatory decision-making purposes, the quantitative DQOs for most 

of the criteria pollutants can be found in 40 CFR Part 58, Appendix A, Section 2.3. These regulatory 

criteria establish the allowable measurement uncertainty and decision rate error in the collected data 

sets. Please note that monitoring organizations can establish more stringent DQOs for the criteria 

pollutant network than are currently stated in CFR; however, the DQOs cannot be less stringent. 

Data quality indicators (DQIs) are quantitative and qualitative characteristics associated with the 

collected data (i.e., calculated statistics). The QAPP should list the DQIs for the monitoring project, 

provide brief definitions for each, and then explain how the DQIs are measured / determined by the 

agency. 

Measurement quality objectives (MQOs) are the acceptance or performance criteria for individual DQIs. 

They are designed to evaluate and control various phases (sampling, preparation, analysis) of the 

measurement process to ensure that total measurement uncertainty is within the range prescribed by 

the DQOs. Therefore, MQOs should be established at various measurement phases in order to meet the 

DQOs.

When formalizing the quality objectives and criteria in this section, answer the following questions:

• Does the QAPP describe the process the agency used to develop its DQOs in order to meet the 

needs of the data user? If not, does the QAPP indicate that the project will utilize DQOs 

established by EPA?

• Does the QAPP contain statements that describe the qualitative DQOs?

• Does the QAPP contain the tolerable error limits (quantitative DQOs) for the pollutants 

measured? In other words, does the QAPP plainly describe how much uncertainty / error the 

agency will accept in their aggregated data sets for each of the pollutants measured?

• Does the QAPP reproduce the Data Validation Templates found in the EPA Quality Assurance 

Handbook for Air Pollution Measurement Systems Volume II (i.e., QA Handbook) and include 

them as the agency’s MQOs? If not, does the QAPP contain tables that summarize the MQOs 

for each pollutant? (Note: MQOs don’t have to be in tabular format, but it is strongly 

recommended for ease of use.)

• Does the QAPP define the Data Quality Indicators (DQIs): precision, bias, accuracy,

completeness, and sensitivity?

• For each DQI, does the QAPP explain how the agency measures / quantifies the specific metric? 

For example, has the agency determined the level of sensitivity that must be obtained in order 

to accurately assess whether the pollutant of interest exists at the monitoring site? For 

instance, with NCore, this may include utilizing trace-level monitors. For air toxics, on the other 

hand, this may include running laboratory analyses using SIM-mode, as opposed to full-scan. 

• Are limits established for each quantitative DQI? Frequency?

• Are statistical reporting units included?

• Is representativeness appropriately addressed?

• Is comparability appropriately addressed?
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Note: If adopting the EPA QA Handbook’s Data Validation Templates and including them in the QAPP as 

your MQOs, most of these bullets will be adequately addressed. 

It is recommended that the data validation templates be personalized to reflect your agency. For 

example, it is recommended that the Information/Action column contain a reference to the agency SOP 

where the requirement can also be found. Similarly, tables should be removed if the pollutant is not 

monitored (e.g., don’t include the CO template if the agency doesn’t monitor for CO). Also, if the agency 

monitors continuous PM2.5 using a TEOM, then the requirements for the BAMs and GRIMMs can be 

stricken from the template (unless the agency is planning to start utilizing BAMs and/or GRIMMs in their 

network, and this QAPP is being submitted in advance of the start of the new monitoring efforts). 

Section 8: Training 

In this section of the QAPP, identify and describe your agency’s training and/or certification 

requirements. This section can describe the general training/career development courses for any 

employee within the agency; however, this section should also explain the specific ambient air 

monitoring training that will be provided to project participants. 

Discuss how training will be provided, tracked, and documented. Discuss how proficiency will be 

assessed, identifying the individual(s) responsible for determining whether project participants can 

successfully and independently perform the monitoring activities. Additionally, the process for ensuring 

project participants stay current on QA and monitoring-related competencies should be described in this 

section as well. Finally, this section of the QAPP should identify where training records will be 

maintained and by whom. 

See Section 4 of the QA Handbook for more information on air monitoring training programs. 

When describing your agency’s training requirements, answer the following questions (if applicable):

• Does each job title (position) have specific training requirements that must be fulfilled that 

documents the employee can fully execute the responsibilities of the position? If so, describe 

the requirements.

• Who makes the determination that project staff are sufficiently trained to perform assigned 

monitoring tasks?

• Must staff perform and pass a Proof of Competency (POC) or Demonstration of Capability (DOC) 

review (or equivalent)? If so, how often and where is it documented?

• Does the agency have an in-house air monitoring training program? Is it detailed in another 

document, such as the agency’s QMP? If so, reference the document. If not, detail the air 

monitoring training program here. 

• Does the in-house monitoring training program include written exams? If so, describe. 

• Is air monitoring-specific QA training provided to all project staff? If so, by whom, in what form, 

and on what frequency?

• Is on-the-job training (OJT) with a senior staff member or QA Officer provided for data 

verification/validation activities? Explain. 
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• Is hands-on instruction (OJT) with analyzers/samplers provided? Explain.

• On what frequency is OJT provided?

• Does the agency host an annual workshop/training event and invite site operators and/or other 

monitoring staff to attend? If so, describe here. Are records kept detailing the training agenda 

and who attended? Are training evaluation forms completed upon workshop completion? 

• Are certificates of completion issued when the project participants are found to be proficient or 

have completed a particular training / workshop / exam? Where are these certificates retained

and by whom?

• Do project personnel complete proficiency tests (PTs), or otherwise demonstrate operations of 

specific air monitoring equipment in some formal fashion? Explain. 

• How is the need for refresher training assessed and subsequently provided?

• Is vendor-provided training utilized? When taken, how is the training documented?

• Are EPA-provided courses utilized? AQS webinars? Air Pollution Training Institute online (selfinstructional) courses?

• Which documents are required reading? The QAPP and SOPs? Examples may include 

instrument user manuals, EPA guidance documents, and the CFR, among others. 

• How is the completion of required reading tracked and documented?

• Does the QAPP clarify which training activities (courses) are required versus which training 

activities are optional?

Section 9: Documentation and Records 

In this section, describe your agency’s document control system. In other words, the process for 

distributing the most current approved QAPP, as well as notifying project staff of any revisions/updates

to the QAPP, and ensuring that staff utilize only the current version. This description can also be 

included in Section 3, Distribution List, if preferred. The section should also describe the document 

control process for distributing the most current version of SOPs, QA/QC forms, blank data entry forms, 

and so forth. These controlled documents may be maintained on the agency’s LAN or website 

(recommended), or through other means. 

Also, in this section of the QAPP, identify the project records that will be maintained, how/where the 

records will be stored, and any record retention requirements. This section should include information 

about records generated in the field (e.g., data forms, logbooks, chain-of-custody forms, etc.), records 

generated in the laboratory, QA reports generated, Corrective Action Reports, and so forth. Emails are 

also considered records; if the agency uses email as a primary means of communicating procedural 

updates and/or otherwise significant monitoring information, the process for retaining significant emails 

should be discussed. 

To reduce verbiage, it is recommended that a table be included that summarizes the records that will be 

documented and maintained, including where they can be found within the agency. See Section 5 of the 

QA Handbook for more information on documentation and records. 
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When describing your agency’s documentation and recordkeeping requirements, answer the following 

questions (if applicable):

• Does the QAPP explain how new copies of quality system documents (e.g., QAPPs, SOPs) are 

distributed to staff? 

• Does the QAPP explain where “old” quality system documents are retained? Are the “old” 

documents archived?

• Does the agency maintain a “master list” of all current, controlled documents (such as QAPPs 

and SOPs)? Where is this “list” posted (such as on the agency’s LAN or website)? Who is 

responsible for maintaining it?

• Does the QAPP describe the process for preparation, review, approval, revision, and withdrawal 

of SOPs? What is the frequency of SOP reviews? 

• Does the agency use email to issue important notifications to staff regarding updates or changes 

to monitoring policies and procedures, etc? Are copies of these email records maintained and 

filed? If so, where?

• Does your agency have a specific records retention policy for air monitoring 

documentation/records? If so, state it. If not, see the general records retention requirements 

in 2 CFR 1500 and include those requirements within the QAPP.

• Are there any special requirements for retaining data/records/documentation that is involved in 

litigation?

• Does the QAPP distinguish between hardcopy and electronic documentation requirements, if 

applicable?

• Has your agency “gone paperless”? If so, does your agency follow the guidance in the April 2016 

EPA Technical Note titled Use of Electronic Logbooks for Ambient Air Monitoring? Document 

how your agency meets this guidance. 

• For handwritten documentation, are best practices listed in the QAPP to guide the reader (e.g., 

instructions such as use of indelible ink, single-line strikethrough for incorrect data entries with 

corrections to the side, initialed and dated, etc)? 

• Are handwritten records, such as site logbooks, backed-up (i.e. scanned)? If so, on what 

frequency? Where are the scanned copies maintained?

• Does the agency utilize paper or electronic strip charts? Are those charts documented? 

• Does the agency utilize any commercial or in-house developed databases where records are 

stored? If so, describe.

• Does the agency collect physical samples in the monitoring network? If so, are chain-of-custody 

forms (COCs) utilized? Where are they retained?

• Are Corrective Action Reports utilized? If so, where are they filed and maintained?

• Where are audit reports (internal and external) filed and maintained?

• Where are NIST-traceability certification records filed and maintained?

• If the agency operates an in-house laboratory, where are laboratory records filed and 

maintained?

• If the agency outsources any laboratory operations, where are data packages received from the 

contract laboratory filed and maintained?
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• Where are training records maintained?

• Are site files created that contain photographs, addresses, geographical measurements (GPS 

coordinates, Appendix E criteria), and other pertinent information regarding individual air 

monitoring sites? For example, some sites may have lease agreements in place, etc. that must 

be maintained. If so, where are these records filed within the agency?

• Who is responsible for maintaining the records and files discussed in this section?

• Is access to any of the records limited? If so, who has access? Please briefly describe the type of 

access (e.g., “read-only”, “add”, etc) granted to project personnel.

• Are electronic records backed-up? If so, how and on what frequency?

• While in storage, are records (hard copies and electronic) protected from damage, loss, and 

deterioration?

• When software upgrades occur, are archived records similarly updated? 

Section 10: Network Description (or Sampling Process Design) 

Reminder: Sections 10 – 19 of the QAPP discuss data generation and acquisition activities.

This section is referred to as “Sampling Process Design” in the EPA QA/R-5 document. For other 

sampling projects, this would be where you would lay out your overall design for collecting samples –

e.g., map your targeted sampling areas, upwind (upstream) and downwind (downstream) sample 

locations, and so forth. With that in mind, for criteria pollutant ambient air monitoring, this is the 

section that discusses the network design and rationale. For air projects that are generating data for

purposes of NAAQS compliance, the easiest way to do this in the QAPP is to reference the CFR – because 

it is there that the sampling design structure has been outlined. The agency must meet the network 

design criteria spelled out in 40 CFR Part 58, Appendix A (i.e., collocation), Appendix D (i.e., design 

criteria), and Appendix E (i.e., siting criteria) for the resulting data to be comparable to the NAAQS.

All monitoring stations included in the network with monitors/samplers collecting data for the specific 

pollutant(s) covered by the QAPP must be identified in this section. Include AQS identification numbers 

for each site/monitor. If the PQAO represents more than one monitoring organization, the QAPP should 

identify which organization is responsible for the operation of each site/monitor. The QAPP must also 

clearly identify the larger entity that oversees QA in the multi-organizational PQAO. 

The monitoring network design and site listing should already be illustrated in the agency’s ANP. The 

ANP should contain maps, population counts, tables with site IDs, etc. In this case, for a large SLAMS 

network, reference the ANP in the QAPP, and include a hyperlink to where the document can be 

accessed online (if it is available online). However, for smaller scale projects – such as the SO2 DRR or a 

source-oriented lead monitoring project that may only include a few sites – include maps, tables, and

other pertinent information within the body of the QAPP. 

Network objectives, sampling schedule, sampling frequencies (i.e., number and types of samples), and 

so forth can be included here, too – but, these may have already been discussed in earlier sections of 

the QAPP (such as Sections 5 or 6). If so, to minimize redundancy, reference the earlier section(s) of the 

QAPP where the information is located. If not, include a few statements about these items here.
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When describing your agency’s monitoring network, answer the following questions (if applicable):

• What is the rationale for your network design?

• If your network is regulatory, did you cite Appendices A, D, and E to Part 58? If not, why? For 

example, if there is no collocation in your network, you may not need to reference Appendix A. 

In that case, it is recommended that a statement be included that explains that collocation is not 

required in the network. 

• Did you cite Part 58 for operating schedules, etc? If not, why? If information is provided in an 

earlier section of the QAPP, provide a reference.

• Did you state or reiterate the network objectives?

• Did you include information about site types (e.g., maximum concentration, background, 

transport, etc)?

• Did you include information about types of monitoring stations (e.g., SLAMS, SPMS, NCore, PSD, 

etc)?

• If this is a single site, or a small network of monitors, did you provide the specifics about the 

individual site(s)/monitor(s)? For example, for a SO2 DRR site, a statement such as: “This sourceoriented site will be representative of expected maximum concentrations on a neighborhood 

scale.”

• Did you include criteria for evaluating potential sites? 

• Did you include factors that influence site selection?

Section 11: Sampling Method Requirements 

This section of the QAPP describes field work – e.g., collecting physical samples, along with associated 

QC samples. The sampling methods and equipment used in the monitoring network should be identified

here. 

For the ambient air monitoring network, the criteria pollutant sampling methods are established within 

the CFR (in the appendices to Part 50). If monitoring for NAAQS comparability, the field analyzers and 

samplers must be federal reference or equivalent methods (FRMs or FEMs) – and the designation of 

those monitoring methods as FRM/FEM establishes that they have been tested and found to be 

acceptable for this purpose. Include a table or listing in this section that specifies the equipment 

makes/models used in the monitoring network, including their FRM/FEM method designation codes (if 

monitoring for regulatory purposes).

Note: If the QAPP is not for criteria pollutants, or is non-regulatory, then the QAPP will need to include 

more information that demonstrates that the sampling methods employed for the collected pollutants 

are adequate and appropriate.

The next step is to show how these methods will be implemented (the “how to”). For intermittent 

sampling, such as particulates, lead, and air toxics, physical samples will be collected – Section 12 of the 

QAPP will discuss this process in more detail. For the gaseous pollutants, physical samples are not 

collected – but “samples” are analyzed in situ, within the analyzer itself. These analytical instruments 
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are sensitive to climate, so in order to describe how you’re implementing the method, the monitoring 

station’s design and interior shelter requirements must be discussed. 

Ultimately, the “how to” for the analyzers/samplers is found in the individual SOPs that address the 

instrumentation. With that in mind, the SOPs associated with the QAPP should be included as 

appendices in order to explain precisely “how” the samples will be collected. However, at a minimum, 

the QAPP must contain a listing or table that includes the names of the SOPs for which the QAPP 

governs. The SOP titles, revision numbers, and dates should be included in the list/table, so the reader 

is directed to the most current/appropriate versions of the documents. The SOP listing can be included 

in this section of the QAPP or as an appendix at the end of the document, if the list is lengthy. 

When describing the sampling methods employed by your agency, answer the following questions (if 

applicable):

• What are the sampling methods for the pollutants monitored? For example, Teledyne-API or 

Thermo instruments: AQS method codes for ozone would be 087 and 047, respectively. 

• Are the SOPs for the sampling methods included? (Include a table, list, or attach as appendices) 

• What sample probe materials are used within the network (e.g., Teflon® or glass for the criteria 

air pollutants, or stainless steel or glass for toxics)?

• What is the sample probe/train design? This information is needed to help clarify the method 

by which the “sample” is truly collected. Is a single-line candy cane used to pull the ambient air 

into the analyzer? Is a manifold system used? Where are the in-line filters located within the 

sample train? Explain.

• Do you calibrate and/or perform QC checks “through-the-probe”? If so, this design should also 

be discussed.

• Do the analyzers have specific shelter climate-control requirements? If so, include them. 

Climate control requirements can usually be found in the List of Designated Reference and 

Equivalent Methods (ORD) or in the instrument manuals. 

• Does the QAPP include information about possible analyzer interferences and how they will be 

addressed by the agency? For example, analyzers are sensitive to dust build-up, so routine 

cleaning is necessary to protect the instrumentation. 

• Does the QAPP discuss how the probes and sampling trains are maintained, in order to minimize 

interferences?

• Does the agency have any business rules on making method changes or corrections? For 

example, are site operators allowed to swap out instruments (methods) or probe materials as 

needed, or do method modifications have to be approved by someone within the management 

chain first?

Section 12: Sample Handling and Custody 

In this section of the QAPP, provide an overview of the sample handling and custody procedures for 

physical samples collected. In other words, illustrate the sample’s life cycle and chain-of-custody (COC). 

This section includes discussion of particulate, lead, and/or air toxics samples. Discuss sample handling 
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in the field, during transport, and through receipt at the laboratory. This section should also include 

information about sample transport containers and preservation methods. Include examples of sample 

labels, chain-of-custody forms, and/or sample custody logs, which are necessary to document the life 

cycle of the sample. Also include discussion of any devices used to ensure samples are not tampered 

with or subjected to unacceptable conditions. 

COC is a method of documenting who has had possession of (“handles”) the sample throughout its life 

cycle, in order to demonstrate the sample’s integrity. Describe the COC process and required 

paperwork in the QAPP. For example, the COC for a PM2.5 sample should start with the gravimetric lab 

analyst, who prepares the sample media (i.e., clean Teflon® filter) and then releases it to the site 

operator. The site operator will collect the actual sample using the prepared media, then prepare the 

exposed sample for transport, and finally relinquish the sample to either a commercial carrier or directly 

to a sample custodian at the laboratory. For each of these steps, a designated COC record should be 

signed and dated by the individual in possession of the sample, and a copy of the COC retained by the 

individual in possession of the sample. 

Note: A COC record can be paper or electronic and come in a variety of formats, such as carbonless 

triplicate forms, a hanging sample tag (e.g., attached to a summa canister), a sample bag label, etc –

provided there is ample room for the necessary documentation and signatures. In addition to 

signatures, information recorded on the COC should include, but is not limited to, the following: 

individual collecting the sample, time and date of sample collection, location, sample identification 

number, analysis required, preservatives used, sample holding time, turnaround time, organization 

samples were sent to for analysis, date and time. 

Cite specific SOPs where more detailed information on the agency’s sample handling and custody 

procedures can be found. If the SOPs provide options, ensure that the option(s) selected for the current 

project is identified in the QAPP and is clearly understood by all necessary project and laboratory 

personnel. 

Do not leave this section blank or skip it if your project does not produce physical samples. For example, 

if the QAPP is a gaseous-only QAPP, there will be no physical samples to collect and, therefore, no COCs 

to document. Instead, state in this section of the QAPP that “COC” does not apply to this specific project 

because the monitors utilized analyze samples in situ. (The “chain of custody” of data, on the other 

hand, will be discussed in Section 19, Data Management.)

When describing sample handling and COC, answer the following questions (if applicable):

• Are pre-sample custody requirements and procedures included (i.e., any preparatory work to 

prepare the sampling media for subsequent field sampling)? 

• Are post-sample custody requirements and procedures included (i.e., handling of exposed 

samples to ensure integrity)?

• Are there any sample holding times in the field that site operators must be aware of? If so, 

include them. For example, PM2.5 samples must be removed from the sampler within 177 hours 

from the end of the sampling event.
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• Are there any sample preservation methods that operators must be aware of? If so, include 

them. For example, exposed PM2.5 samples must be protected from temperatures above 25°C, 

and therefore, shipments should be chilled in order to maximize analytical holding time.

• Are there any sample holding times in the laboratory that site operators must be aware of? If 

so, include them. For example, if a sample must be analyzed or extracted within X number of 

days after sample collection ends, the operator must be aware of the requirement in order to 

ensure the sample is shipped to the laboratory with enough time to allow the analyst to 

complete the necessary analysis/extraction.

• Are procedures for packing samples for transfer/shipment included? Do the procedures include 

a description of the paperwork that is to be included with the samples?

• Are COC records hardcopy or electronic? Describe.

• Who is responsible for completing the COC record? 

• Who is responsible for reviewing and storing the COC records?

• Are completed COCs backed-up (i.e., scanned or emailed)?

• Are there specific shipment schedules that must be followed? If so, describe them.

• Does the agency utilize custody seals when packing shipment containers? If so, describe.

• By what method are samples shipped to the laboratory? For example, hand-delivery via 

operator because the laboratory is within the same office building, or overnight via commercial 

carrier to the laboratory in another location?

• To whom are the samples shipped (e.g., a sample custodian or the lab analyst)?

• How are samples archived after analysis (if applicable)?

• Does the agency run make-up samples? If yes, include the agency’s make-up sample 

policy/strategy in the QAPP. If no, state that make-up samples are not collected for the specific 

pollutant program.

Section 13: Analytical Methods 

This section in the QAPP is primarily about laboratory work. If you are writing a PM2.5, PM10, lead, or air 

toxics QAPP, this would be the section where you detail the analytical methods used in the laboratory to 

analyze the field samples collected, along with the required analytical QC for those methods. For 

example, you would summarize the requirements of 40 CFR Part 50, Appendix G, for criteria lead, or 

summarize the analytical method equivalent to Appendix G that will be utilized by the laboratory. This 

section also includes a discussion of equipment needed in the laboratory for these purposes (e.g., 

microbalance, ICP-MS, etc). This section should include information about sample media (e.g., glass 

fiber filters, quartz, Teflon®), sample containers (e.g., cassettes, filter envelopes), preservation methods 

(e.g., ice packs), and holding times for the various sample types. Some of this information may have 

already been captured in Section 12; if so, reference the section. To reduce redundancy, the 

requirements do not have to be repeated in both sections.

For the regulatory pollutants (PM2.5, PM10, and lead), the reference methods that are to be followed are 

codified in the appendices of 40 CFR Part 50. For air toxics, however, there are no regulatory methods; 

instead the TO or IO compendia provide information on the analytical methods. To simplify this section, 
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cite the specific regulatory method(s), or TO or IO compendium method(s), that will be used, along with 

the summary of how those methods will be implemented by your agency. Also cite the SOPs where 

more detailed information can be found. 

If you’re writing a gaseous pollutant QAPP, this section should not be left blank or omitted. For criteria

pollutant monitoring, including gaseous, the FRM methods can be found in the appendices to 40 CFR 

Part 50. With that in mind, include references to the appropriate appendix for each pollutant 

monitored. Explain that for gaseous pollutant analyzers, the monitoring methods are “self-contained” 

within the apparatus (analyzer) utilized and no additional analyses at a laboratory are required. If using 

an FEM, explain that the monitoring method is a designated equivalent method. The theories of 

operations for the gaseous monitors can be found in the instrument user manuals, which can also be 

referenced in the QAPP and/or SOPs to address this section. However, if you already detailed this 

methodology in Section 11 of the QAPP then, at a minimum, include a statement here that explains 

analysis at a laboratory is not required because the monitoring method(s) employed analyzes samples in 

situ. 

When describing the analytical requirements, answer the following questions (if applicable):

• Did you cite the appropriate analytical method for each pollutant monitored in the network?

• Did you reference the specific analytical SOPs utilized for each method?

• Did you identify the required QC checks on the analytical equipment (e.g., method detection 

limit (MDL), initial calibration verification (ICV), continuing calibration verification (CCV), etc)? 

• Did you identify the required QC samples for each method (e.g., blanks, replicates, duplicates, 

spiked samples, etc)?

• Did you identify the analytical laboratory? This is especially important if more than one 

laboratory is utilized because the monitoring network samples for multiple pollutant types.

• Did you specify the sample media used?

• Did you specify the laboratory quantitation and QC limits (reporting limits and acceptance 

criteria, respectively) to ensure project sensitivity requirements will be met?

• Did you reference or attach the laboratory QA manual and SOPs?

• Did you identify procedures to follow if laboratory failures occur?

• Did you identify the individual(s) responsible for corrective action and appropriate 

documentation? 

Section 14: Quality Control Requirements 

This section of the QAPP is about the many types of QC checks and samples performed/collected in the 

ambient air monitoring network. In this section, identify those required QC checks or samples for the 

sampling and analytical methods (discussed in Sections 11 and 13). To reduce redundancy, the

laboratory calibration and QC requirements do not have to be repeated in this section, provided they 

were adequately described in Section 13. If not, then add them here. 
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A reference to the QAPP’s MQO tables should be added to this section, since the tables compile the 

necessary QC for each pollutant. Section 14 explains the purpose and rationale for these various QC 

checks and samples. State the frequency for each type of QC check or sample, the acceptance criteria 

for the checks, as well as the associated corrective action if the acceptance criteria are not met. 

Reference the SOPs in this section, identifying where the procedures can be found in more detail.

Recommend utilizing the same terminology in the QAPP that you use “in real life” in your agency; 

ideally, that terminology should carry forward to the SOPs. 

For ambient air monitoring, QC checks include precision checks conducted on analyzers and samplers. 

Calibrations (i.e., adjustments), in general, are part of quality control. Calibration information can be 

included in this section, or it can be included in Section 16. Historically, in many agencies’ air 

monitoring QAPPs, Section 16 has been used to discuss the certification/traceability of the standards 

that are used to complete the required calibrations. 

Audits are QC checks – although, they are used for bias/accuracy determinations. Include a discussion 

of audits (external and internal) in this section.

Include formulas for the necessary QC calculations in this section or reference where the formulas can 

be found.

When describing your agency’s QC activities and requirements, answer the following questions (if 

applicable):

• What is your calibration scale, if it is something other than the full operational scale of the 

analyzer? For example, your ozone analyzer may be designated as an FEM on a 0 – 500 ppb

scale, but you calibrate the analyzer within that range to perform on a 0 – 200 ppb calibration 

scale. 

• If using a calibration scale, what is the rationale for the scale selected?

• What is the calibration acceptance criterion? Is it slope? Percent difference (%d) for each 

point? A combination of both? Explain. 

• How often are calibrations (i.e., adjustments) performed?

• How often are calibration verifications (i.e., unadjusted calibrations) performed?

• Is the acceptance criterion for unadjusted calibrations different than for adjusted calibrations?

• Are multi-point verifications or some other QC check performed prior to a calibration? 

• What types of precision checks do your site operators perform on the gaseous analyzers? These 

checks may be referred to by a variety of names, including “1-pt QC”, “biweekly”, “p-checks”, 

“PCs”, “pre-cal”, “P&A”, “P&B”, “ZPS”, among others. 

• Describe the precision check(s). For example, is a 1-point QC really just a single upscale 

concentration point (50 ppb, for example) and nothing else? Or is it a zero concentration along 

with the 50 ppb?

• What is the rationale for the concentration selected for the 1-point QC check? (See 40 CFR Part 

58, Appendix A, Section 3.1.1)

• How often are the precision checks performed? Are they automated (i.e., controlled by a 

datalogger in the absence of the operator) or conducted directly by the operator? Or both? 
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Please explain in the document so that all checks (and how they’re completed) are accounted 

for. 

• What is the acceptance criteria for the precision checks?

• Are there reasons why some precision checks may not be valid? This is not regarding an 

exceedance of a percent difference acceptance criterion, but rather, something that may go 

wrong such that the QC check itself is invalid (e.g., the site calibrator malfunctioned, yet the 

datalogger still fired off an auto-program to run the check). Provide examples in the QAPP of 

situations in which you would not consider QC checks to be valid. 

• What types of precision checks do you perform on your particulate matter samplers? Describe 

them and include their frequency and acceptance criteria. 

• Do operators have to compute the percent difference calculation manually? Or, is the formula 

captured in spreadsheets or databases utilized by the operators so that they don’t have to do 

this computation directly? Or are both methods for calculations employed? Please explain. 

• Do you control chart your QC results? For example, do you plot your zero concentrations or 

span concentrations over time to watch for drift?

• What do you do if any of the QC checks exceed the acceptance criterion? Discuss corrective 

action.

• Do you have any collocated sampling in your network? If so, describe how the collocation is 

used as a QC check.

• What is the collocation sampling frequency? 

• What is the acceptance criterion for collocated sample pair results?

• Do you collect field blanks? Trip blanks?

• What types of performance evaluations (audits) are performed in your network? Include 

internal and external audits. For instance, external audit examples may include a local agency 

that doesn’t perform its own audits, but is audited by the State PQAO, as well as audited by EPA

(e.g., National Performance Audit Program (NPAP), Performance Evaluation Program (PEP)).

• What is the frequency of the performance evaluations? Once a year, as in the regulations, or 

some other schedule?

• What are the audit levels used during performance evaluations? What is the rationale for the 

targeted audit concentrations? (See 40 CFR Part 58, Appendix A, Section 3.1.2.1)

• What do you do if any of the audit concentrations exceed the acceptance criterion? For lowlevel gaseous audits, in particular, how do you judge the results from Audit Levels 1 or 2?

• If you operate an in-house laboratory, what types of QC checks do you perform on the analytical 

equipment? For example, for a PM2.5 gravimetric lab, this would include balance checks. 

• If you operate an in-house laboratory, what types of QC samples do you utilize? For example, 

for a PM2.5 gravimetric lab, this could include lot blanks, lab blanks, and/or long-term exposure 

blanks.
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Section 15: Instrument/Equipment Testing, Inspection, and Maintenance Requirements 

In this section, identify the equipment (field and laboratory) that needs periodic maintenance, testing, 

or inspection. 

Describe the acceptance testing the agency will perform on its analyzers/samplers, and how this testing 

will be documented. Instruments used for SLAMS monitoring must be FRM/FEM, and with the purchase 

of an FRM/FEM, the agency has confidence that the make/model of the instrument itself has passed 40 

CFR Part 53 acceptance testing requirements. However, the agency should still complete testing of 

individual instruments (upon receipt) to ensure the instruments are fully functional and meet 

performance specifications. If a newly purchased instrument does not pass in-house acceptance testing 

upon receipt, the instrument should be returned to the vendor while still under warranty. 

Describe or reference how periodic preventive maintenance of equipment will be performed. Reference 

applicable SOPs where this information is maintained. Also, describe any periodic inspections that are 

completed in order to ensure the monitoring system itself remains in good working order. 

When describing your agency’s testing/maintenance activities, answer the following questions (if 

applicable):

• How are new instruments tested when first received from the vendor (i.e., newly purchased)? 

Summarize your activities, including documentation. 

• Does new equipment testing include procedures to determine/quantify the method detection 

limit (MDL), particularly for use of low-level instruments in an NCore program? Describe any 

MDL testing here, along with requisite documentation and AQS reporting. 

• What do you do if the instrument doesn’t meet the purchase requirements or performance 

specifications? Explain how deficiencies found are resolved and documented.

• Do you have any SOPs that are specific to instrument performance acceptance testing? If so, 

reference them. If not, summarize your procedures here.

• What general preventive maintenance activities do you perform each month? Each quarter? 

Annually? Where can detailed descriptions of these activities be found? 

• Are diagnostic checks performed before and after maintenance to document the “as found” and 

“as left” condition of the instrument? Where is this information recorded? 

• Are instruments logbooks (or e-logbooks) kept with each instrument that document the testing, 

maintenance, and repairs for the individual instruments? Describe how these activities are 

documented and tracked. 

• Do you maintain critical spare parts to prevent instrument down time? If so, which parts are 

usually on hand?

• Are spare analyzers maintained by your agency? Are these back-ups shelved in a maintenance 

shop/warehouse for future use when a field monitor malfunctions? 

• If spare (back-up) monitors are maintained but shelved, are they tested on some frequency to 

ensure they are still functional (i.e., haven’t developed “shelf disease”)? What is the frequency 

of the testing and how/where is it documented?
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Section 16: Instrument Calibration and Frequency 

In ambient air monitoring, calibrations are considered a type of quality control procedure. Therefore, 

calibrations can be discussed in the QC section of the QAPP (Section 14). In order to reduce redundancy,

though, if calibration requirements and frequency are discussed in the earlier section, then reference 

that section instead of repeating the information. If calibrations are not discussed in Section 14, then 

include the information here. 

An element of calibration that is critical to the ambient air monitoring program that should be 

elaborated on in this specific section is that of traceability. For criteria air pollutant data being used for 

regulatory decision-making purposes, the gaseous and flow standards used to calibrate ambient air 

monitoring instruments must be traceable to NIST. In general, for any air monitoring program, when 

calibrating an instrument, the calibration standard should be NIST-traceable, and of higher accuracy 

than that of the working standard used to periodically test the instrumentation. These concepts should 

be explained in the QAPP, along with your agency’s method for ensuring traceability of standards back 

to NIST.

When explaining the hierarchy of standards, use terminology that is understood by project staff and 

utilized in your SOPs. But, ensure that terminology is defined. For example, your agency may utilize a 

rootsmeter for in-house hi-volume PM10 orifice certifications/verifications. You may refer to the 

rootsmeter in-house as a “local primary standard”. The QAPP should define such “local primary 

standards”, their certification/verification requirements, and frequencies.

When describing your agency’s calibration standards, answer the following questions (if applicable):

• Do you sample for ozone? If so, discuss your photometers. 

• Which photometer levels (i.e., Levels 2, 3, or 4) are utilized in your network and how often are 

they certified/verified? Explain the hierarchy. Identify the standards by the Level number for 

ease of understanding, but you can also use your agency’s terminology to describe the 

standards. For example, “The agency’s ozone bench standard (i.e., Level 2).”

• Do you sample for CO, SO2, or NO2? If so, discuss your gas cylinders and your gas dilution 

calibrators, which contain mass flow controllers which must be verified on a set frequency.

• Do you sample for low-volume particulates? If so, discuss your flow rate transfer standards, as 

well as any manometers, thermometers, or barometers that may be needed for sampler 

calibrations.

• Do you sample for high-volume particulates? If so, discuss your orifices and/or variable plates.

• Are analytical methods performed in-house? If so, describe the laboratory standards and 

reagents which require certification and discuss that process. For example, in a PM2.5 weigh lab, 

the primary set of mass reference standards (i.e., weights) should be recertified annually. 

• Who conducts the certifications/verifications described in this section? Are they certified by the 

vendor or certified in-house? Explain for each standard type. 

• If certified/verified in-house, what is the standard of higher authority (accuracy) that is used to 

conduct the certification? Explain for each standard type. Clearly identify in the QAPP which 

standards the agency considers to be the primary standards. For example, an aneroid 
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barometer can be calibrated against a Fortin-type mercury barometer, which is a primary 

standard. 

• State the certification frequency for each standard type.

• How are certifications/verifications documented?

• How are certifications/verifications tracked in order to ensure standards do not expire?

Section 17: Inspection/Acceptance Requirements for Supplies and Consumables 

In this section of the QAPP, briefly summarize how critical supplies and consumables in your monitoring 

program are inspected and accepted for use. This may include stating acceptance criteria for the 

necessary supplies and consumables.

For regulatory ambient air monitoring, most of the parts needed will be issued by the vendor of the 

FRM/FEM instrument in use. Consumables, such as calibration gases, must be EPA Protocol cylinders 

and other supplies, such as sample lines and fittings, must be Teflon® or glass. With this in mind, the 

CFR has established some of the “acceptance criteria” for the supplies and consumables.

When describing your agency’s inspection/acceptance of supplies, answer the following questions (if 

applicable):

• Are critical supplies and consumables identified? If not listed within the QAPP, cite where this 

information can be found.

• Are acceptance criteria stated, if necessary? 

• How are use of supplies and consumables tracked? 

• Who is responsible for tracking/ordering supplies and consumables?

• Is documentation maintained that demonstrates the supplies/consumables are acceptable for 

use?

• Are procedures in place – such as labeling – to help ensure supplies/consumables are used 

before their expiration dates?

• Does the agency have any policies regarding the use of expired materials? 

Section 18: Non-Direct Measurements 

The purpose of this section is simply to identify types of data that the agency may use to support the 

ambient air monitoring program that they did not directly generate/collect themselves. These 

additional data may be needed for project implementation or decision making. For example, in order to 

determine the number of sites needed in a metropolitan statistical area (MSA), population counts must 

be obtained – so census data may be used. Similarly, if completing a source-oriented monitoring 

project, facility emissions data, along with wind rose data, may need to be obtained for purposes of 

modeling, etc. in order to determine maximum expected concentration areas and so forth. 
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With this in mind, identify the anticipated types of data needed for the monitoring project, if applicable. 

If non-direct measurement data are used, briefly discuss any data quality limitations or concerns, if 

applicable. 

Section 19: Data Management 

In this section of the QAPP, describe how the ambient air monitoring data will be managed, tracing the 

path of data generation in the field/laboratory to the final data use and end storage (i.e., AQS). In other 

words, this section describes the data’s flow path from the “cradle to the grave.” It can also be thought 

of as describing the data’s “chain-of-custody”, illustrating all the processes and people who have 

influenced each data point over the course of its life cycle. 

It is suggested that this section be organized by topics that mimic the flow path of the data, simply for 

ease of understanding. A flow diagram in this section is recommended to help the reader visualize how 

the data is collected and processed.

In this section, identify and describe all data handling equipment and procedures to process, compile, 

and analyze the data, including any computer hardware and software, or paper-based processes.

Discuss the frequency and process for verifying the accuracy of the telemetered data. If data are

transferred amongst entities (e.g., from laboratory to agency) using email, describe this process –

including how the emails with attached data are incorporated into the data management system and 

eventually archived. If data is managed manually, discuss how data transformations and algorithms are 

verified. Whether manual or automated, discuss the frequency and process for verifying the accuracy of 

the final-reported data.

Data security and back-up is also a critical function that should be discussed in this section of the QAPP. 

Describe the process for ensuring original, unaltered data is retained and never overwritten. Discuss 

how data is backed-up and at what frequency. (Note: Daily back-up is recommended.) 

In short, this section should include a discussion of each of the following elements of data management: 

• Data collection and recording

• Data reduction/transformation (i.e., how the data is aggregated into the hourly or daily sample 

concentrations, and later into the design values)

• Data transmittal (e.g., electronic via telemetry, download onto hand-held electronic devices, 

manual via data entry forms)

• Data verification/validation

• Data storage and retrieval

When describing your agency’s data management system, answer the following questions (if 

applicable):

• How and where are data stored? Most likely, monitoring data is stored in multiple locations in 

your agency. For example, data may be stored inside the analyzer/sampler. It may be stored on 
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a site computer and/or site datalogger. It may also be stored in a central polling computer in 

the main office. Explain how it works in your network. 

• What type of data acquisition system is in use? 

• How is data transferred from the monitoring station to the central office? For example, is it via 

telemetry using telephone lines and a modem? 

• Is data transmitted by hand (e.g., data entry forms) or electronically for intermittent samples? 

• Are paper or electronic strip charts used?

• How is data transferred from the laboratory to the air monitoring agency? 

• How are data aggregated? What are the averaging times of the instruments? For example, is 1-

minute data collected from the analyzers? How do dataloggers (or equivalent) reduce the data 

to calculate hourly averages? 

• How is data integrity maintained? Is raw, unaltered data maintained such that the agency can 

always see or retrieve the original data? If so, where and how is the raw data maintained?

• Are procedures to process, compile, and analyze data included in a specific SOP? If so, which 

one(s)? Cite any applicable data handling, processing, and/or validation SOPs.

• Are there procedures in place to test or periodically audit the acceptability of the hardware and 

software configurations? If so, describe. 

• Who is responsible for each data management task? 

• What security measures are in place to ensure data is not unintentionally modified or deleted? 

• How is data backed-up? 

• What is the frequency of back-up? 

• Are recovery measures tested?

• How are the final data stored and archived? 

• How long are data retained?

• When software upgrades occur, are archived data(bases) similarly updated such that data is still 

accessible during its retention period? 

Section 20: Assessment and Response Actions 

Reminder: Sections 20 – 21 of the QAPP discuss project oversight and assessment.

In this section of the QAPP, describe the assessments your agency performs or participates in, in order 

to ensure the air monitoring activities are being conducted as planned and are generating acceptable 

data. State the frequency and purpose of each assessment – some of which are derived from the CFR.

Include the approximate schedule of the assessment activities (again, some are in CFR), and identify the

assessment participants. A table or chart summarizing the assessments and their required frequencies 

is recommended. Note: The assessments described in this section should mesh with the assessments 

listed previously in Section 6. 

At a minimum, this section should include a brief discussion on the following types of assessments:

• Annual Network Plans, which should include Appendix E siting criteria evaluations

• 5-Year Network Assessments
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• Technical Systems Audits (TSAs)

• Internal systems audits (if applicable)

• Performance Audits (internal and external)

• Data quality assessments (DQAs)

• Annual data certification

Cautionary Notes: 

1. Previous Model QAPPs discussed Management Systems Reviews (MSRs) in this section. 

MSRs are not currently conducted by OAQPS, so do not include MSRs in the QAPP – unless 

someone within your agency is tasked with conducting them. If that is the case, please 

describe the internal MSR. 

2. Previous Model QAPPs discussed “Annual Particulate Matter Network Reviews.” This is holdover language from previous requirements. With the advent of the ANP required in 40 CFR 

58.10, all pollutants monitored are reviewed at the same time and reported in one 

document. 

3. Previous Model QAPP language on TSAs is very detailed with multiple subsections. Your 

QAPP does not need to contain that much detail about EPA TSAs and TSA reports. Instead, 

summarize the information. However, if your agency conducts in-house systems audits –

and does so in the manner that is described in the Model QAPP – then keep the language, 

but make sure it is clear that the TSA process being described is not an EPA Regional Office 

process, but rather that of your agency. 

4. Audits of Data Quality (ADQs) occur during EPA TSAs. Previous Model QAPP language

described the data audit that EPA completes. However, your agency should conduct some 

type of ADQ in-house on a prescribed frequency – ideally, monthly. Whatever your in-house 

data audit process is, you should describe it in this section of the QAPP, but make it a standalone section (and not a subsection of EPA TSAs). If the ADQ is conducted during an internal 

systems audit, then state so. (For more information on ADQs, see Section 4.4 of the EPA

Quality Assurance Guidance Document Conducting Technical Systems Audits of Ambient Air 

Monitoring Programs (EPA-454/B-17-004, November 2017.) 

5. Previous Model QAPPs discussed the “Annual QA Report,” and that DQAs would be included 

in the annual QA report. Currently, monitoring agencies complete annual data certification 

packages for SLAMS in accordance with 40 CFR 58.15. 

Also in this section of the QAPP, describe how and to whom the results of the assessments shall be 

reported. Along those lines, discuss how response actions to non-conforming conditions shall be 

addressed and by whom. Include a discussion of stop work orders, where appropriate.

When describing your agency’s assessments and corrective actions, answer the following questions (if 

applicable):

• How do you ensure the project is conducted as described in the QAPP?

• Do you conduct internal systems audits? If so, describe. Who conducts them and on what 

frequency?
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• Do you conduct internal performance audits? If so, describe. Who conducts them and on what 

frequency?

• Do external entities conduct performance audits on the monitoring equipment in order to meet 

the CFR requirements for independent audits? For example, has the agency hired contractors to 

complete the audits? Or, if a local organization is part of a larger PQAO, does the PQAO conduct 

audits on the local’s behalf? Please describe. 

• Do you self-implement NPAP or PEP? If yes, describe.

• Does EPA (or its contractors) conduct NPAP and PEP audits for your agency? If yes, describe. 

• Do you complete monthly or quarterly audits of data quality? If so, describe.

• Do you complete quarterly or annual DQAs? If so, describe. (See Section 15.4 of the QA 

Handbook for more info on DQAs.)

• Who is responsible for reporting the need for corrective actions?

• Is there a process in place that would allow any project personnel to initiate a corrective action 

process, if warranted? If so, describe. If included in an SOP, provide the specific reference.

• How many business days are allowed between the time the need for a corrective action is 

reported and the time the corrective action measure is completed? 

• How are corrective actions tracked and documented?

• Who will assess the effectiveness of a corrective action measure to determine whether it 

successfully resolved the issue?

• Is there a process in place to communicate when corrective action measures are disputed 

and/or unresolved? How would such disputes be elevated? For example, would the issue be 

communicated to the agency’s QA Manager or Director for resolution, or to the EPA Regional 

Office? Describe the mechanism used by the agency to resolve disputes. 

• As a part of QA oversight, does the agency have any emergency/contingency plans that should 

be implemented when certain situations arise or when assessment(s) show that data 

quality/quantity is in jeopardy?

Note: When documenting this section of the QAPP, ensure that the individuals tasked with particular 

assessment roles mesh with those identified earlier in Section 4.

Section 21: Reports to Management 

This section of the QAPP is geared towards illustrating how the results of assessments are 

communicated up the management chain, so that all parties in the ambient air program – including the 

agency director (or equivalent) – are aware of data quality issues and concerns. With this in mind, in 

this section of the QAPP, discuss your agency’s approach to this communication process. Identify the 

frequency and distribution of routine reports issued to inform management of the status of the 

monitoring network (or specific pollutant program), which includes information regarding the results of 

performance evaluations, systems audits, data audits, and/or any significant quality assurance problems 

and recommended solutions. Identify the preparer and the recipient(s) of the reports, and any specific 

actions management is expected to take as a result of the reports.
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For a few of the regulatory-required assessments described in Section 20, the resulting document is 

submitted to EPA for review and approval. Usually, these documents must be routed through the 

agency’s chain-of-command and signed by the agency director (or delegate). Identify those reports 

here. For simplicity, this information could be entered into a table.

Your agency should complete internal reports to management, and possibly external reports that are 

provided to other data users, that are beyond those required in the CFR. When writing this section of 

the QAPP, think about any internal or external reports you generate to share data results and concerns. 

Answer the following questions in the QAPP (if applicable):

• Do site operators compose a routine, monthly/quarterly report to the appropriate Field 

Operations Supervisor or QA Manager that summarizes the month’s monitoring activities and/or 

highlights specific reasons for data loss? If so, discuss.

• Are routine reports prepared that discuss the results of intermittent particulate matter 

sampling? Thinking about PM2.5, for example, a laboratory provides a data package with the 

results of the gravimetric analysis, but it is the responsibility of the agency to combine the lab 

and field results together and validate the data. So, is any type of report generated on a 

monthly/quarterly basis that summarizes the data results, highlights specific reasons for data 

loss, and/or provides estimates of data recovery? If so, discuss.

• Similar to the bullet above, are any reports prepared that discuss the results of criteria lead 

sampling? If so, discuss.

• Does anyone query AQS on a routine basis and generate data completeness reports, in order to 

keep management informed of any potential issues? If so, discuss.

• Is anyone charged with keeping tabs on design values, and reporting to management any 

concerns about specific sites because of the design value estimates? If so, discuss.

• Are written reports issued that contain the results of in-house performance audits or systems 

audits? How are these reports disseminated? For example, if your agency is a large PQAO with 

numerous district/regional offices, do you submit formal reports to those offices? Or, if your 

agency is a PQAO made up of multiple, smaller organizations, do you submit formal reports to 

the smaller organizations within the PQAO?

• If during a performance or systems audit issues are found that require corrective action, do you 

generate a separate Corrective Action Report that is geared towards correcting the specific 

issue? Or is the need for corrective action contained within the body of the main report and not 

separated out?

Section 22: Data Validation and Usability 

Reminder: Sections 22 – 24 of the QAPP discuss how the data resulting from the project are 

validated. 

This begins the final portion of the QAPP where everything comes together in order to determine 

whether or not the agency has met its overall quality goals and the resulting data collected can be used 

– with confidence – for its intended purpose. 
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In this section of the QAPP, the criteria for deciding the degree to which data has met its quality 

specifications should be stated. Data validators should estimate the potential effect that each deviation 

from the QAPP may have on the usability of the associated data, its contribution to the quality of the 

data, and its effect on decisions. In other words, the QAPP needs to explain in this section the process 

by which the data are deemed usable for their intended objective. 

Important Definitions to include in the QAPP:

• Verification can be defined as confirmation, through provision of objective evidence, that 

specified requirements have been fulfilled. 

• Validation can be defined as confirmation, through provision of objective evidence, that the 

particular requirements for a specific intended use are fulfilled. 

Note: To assist with the development of this portion of the QAPP, please review Section 17 of the QA 

Handbook (January 2017 edition). 

When describing how your agency determines data validity and usability, the network as a whole should 

be considered, as well as the life cycle of the sample. Think big picture. This section of the QAPP should 

tie together the following components:

• Sampling Design

• Sample Collection Procedures

• Sample Handling

• Analytical Procedures

• Calibration Procedures

• QC Procedures (e.g., 1-point QC checks for gaseous pollutants, flow rate verifications for 

particulates, etc)

• Data Reduction and Processing Procedures

So, when writing this section of the QAPP, think about the following questions and broadly state how 

your agency addresses them during data review processes:

• How do you know the sampling design conforms to EPA requirements?

• How do you know the instrument (method) used to collect the data is acceptable for the 

project, and how do you know the manner in which the instrument was operated is acceptable? 

• Do you have procedures in place to verify that SOPs have been followed when collecting 

samples/data? 

• Do you have procedures in place that ensure sample integrity throughout the sample handling 

process? Were they followed?

• Have the instruments used to collect the data been calibrated?

• Have routine QC checks been performed to attest that the instrument calibration has not 

drifted?

• Have corrective action measures been implemented, when needed?
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• Do you have any specific criteria for which, when exceeded, you immediately invalidate data 

(i.e., control limits)? If so, include them. 

• Do you have any business rules that state, if specific situations arise, data will not be usable? If 

so, include them. 

Section 23: Validation and Verification Methods 

In this section of the QAPP, describe the methods or procedures to be used when verifying and 

validating data, as well as documenting the process. This will most likely include describing a multileveled (tiered) data review approach that involves multiple staff members. Towards that end, the 

QAPP should describe who is responsible for each level of data review and what each level of data 

review entails. Verification includes both self-review and peer-review of data and records. (Some 

verification activities can be automated through the use of datalogger programming and/or data 

acquisition software packages.) Validation, on the other hand, should be independent of the data 

generation process and involve a more in-depth review, ensuring data meets its intended use. In 

agencies with limited staff, a multi-leveled (tiered) approach may be difficult to implement; however, 

the data review approach utilized should still provide for independence in the validation process. 

In this section, describe the process to accept, qualify, or reject data. Describe how qualified and 

rejected data will be identified. For ease of use, it is recommended that the AQS null value codes and 

QA qualifier flags utilized by the agency be presented in a table or chart. It is further recommended that 

these tables include examples of how and when to apply specific codes and flags. For example, the 

agency may use “BC” (multi-point calibration) for coding data loss during a gaseous analyzer calibration, 

whereas “AT” (calibration) may be used when a particulate monitor is calibrated. 

In addition to AQS flags and codes, the specific criteria used to review and validate data should be stated

in this section of the QAPP. These criteria should have already been established in the MQO tables in 

Section 7 (Quality Objectives and Criteria); with that in mind, you only to need to reference the tables 

again here (adding a phrase such as, “See Section 7 of the QAPP for the MQO tables against which data 

will be validated”.) However, if the MQOs were not presented in tabular form in Section 7, they must be 

included in this section of the QAPP. Moreover, it is important in this section that you clarify how to 

read, interpret, and apply the MQO tables. If adopting the Data Validation Templates found in 

Appendix D of the EPA QA Handbook as the agency’s MQO tables, an explanation of the critical, 

operational, and systematic criteria categories is needed here, along with a description of how agency 

staff will handle data based upon this categorization. 

The agency should discuss in this section how they will “bracket data” using the results of QC checks. 

For example, with an ozone data set, when a QC check exceeds the acceptance criterion, data will be 

invalidated back to the last known, passing QC check; similarly, data will be invalidated forward until the 

time of successful corrective action and recalibration. This bracketing concept should also be applied to 

laboratory data, as appropriate, when reviewing the results of sample batches and its associated QC. 

Weight of evidence should also be discussed in this section – which can involve using professional 
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judgment to make calls about overall validity and determining whether data meets the needs of the end 

user. For example, if QC checks on an ozone analyzer are performed at a frequency that does not meet 

the biweekly requirement in the CFR (i.e., critical criterion), but the results of the QC checks show that 

the analyzer operated within its established acceptance criteria, the agency may determine that the 

data is valid because, for its end use (e.g., NAAQS comparisons), the passing QC results provide enough 

empirical evidence to support the data’s overall validity. As another example – when a sample has been 

found to deviate from multiple operational criteria, the agency may determine the data should be 

invalidated (as opposed to qualified) because too many operational deviations jeopardize the ability to

defend the validity of the sample (and likely do not meet the needs of the end data user). In both of 

these scenarios, the data validator must “weigh” the evidence in order to make a final decision.

When describing your agency’s verification/validation methods, answer the following questions:

• Do you have a Data Validation SOP? If so, cite it. Language for this section can be reduced by 

referencing the SOP, as appropriate.

• Do you utilize a weight of evidence approach when validating data, such as the one described 

above and in Appendix D of the QA Handbook? If so, add language to the QAPP to describe the 

weight of evidence approach. 

• Do you utilize the EPA DASC tool? If so, how does it influence your process?

• How do you bracket data? Explain the concept here, if it has not already been explained in an 

earlier section.

• Which AQS null value codes do you apply to your data set?

• Do you apply AQS QA qualifier flags to your data? If so, which ones?

• Do you identify and flag data that may have been considered an outlier or exceptional event? 

• Is a datalogger utilized in the project that has been pre-programmed to flag data for certain 

events, outliers, or anomalies? Or is all data verification completed by people?

• Who verifies the data? On what frequency does it occur and what does it entail?

• Who validates data? On what frequency does it occur and what does it entail?

• What is the agency’s review process for laboratory-supplied data? Describe, including the 

frequency of the review and what it entails. 

• Is there a hierarchy in this data review process that ensures multiple sets of eyes review the 

data? Describe the hierarchy and explain how it provides adequate independence during data 

validation.

• If your agency does not have a multi-leveled (tiered) data review process because of limited 

staffing, how does your agency maintain adequate independence when validating data? 

Describe the review structure in place and explain how independence is achieved.

• How is the data verification/validation process documented? For example, do site operators 

complete a monthly report where they have verified, flagged, and/or coded the data sets for 

which they are responsible, and then submitted those reports to a QA Manager (or equivalent) 

for additional review and validation? Or, does the QA Manager complete a report each month 

that describes the overall validation of the data set? Describe your process.
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• Is email used to document data validation decisions? If so, describe how email is used in your 

agency’s validation process and how those emails are retained. 

• Does someone within your agency final-review data and approve its release to AQS? If so, what 

does that review entail and how is it documented?

• Is data verified after AQS entry to ensure the accuracy of the data submittal? If so, what does 

this review include and how is it documented?

Note: When documenting this section of the QAPP, ensure that the roles and responsibilities identified 

here mesh with those identified earlier in Section 4. 

Section 24: Reconciliation with Data Quality Objectives 

In this final section of the QAPP, describe how the sample results (which have already been reviewed, 

verified, and validated against the MQOs) obtained from this project will be reconciled with the project’s 

data quality objectives. Remember, DQOs are the qualitative and quantitative statements that describe 

the intended use of the data, the type of data needed, and set tolerable limits on the amount of 

uncertainty in the data sets so that decision makers can use the resulting data with a reasonable amount 

of confidence. With that in mind, the main goal of this final process is to determine whether or not you 

achieved your project’s big picture goals. This section is also where you explain how your agency plans 

to continuously improve (if the project continues) – by looking at the results of various assessments and 

modifying the project objectives/requirements, where appropriate. 

A few of the questions you may ask when reconciling your data include: 

• Was the data within the QC limits? 

• Is the data more or less variable (coefficient of variation) either in time or in space than 

expected? (Implies the sampling frequency or sampling network may need to be increased or 

decreased) 

• Do the results of monitoring indicate a measured concentration consistently far above, far 

below, or near the NAAQS? Levels near the standard may indicate the need for additional 

and/or more frequent monitoring. 

• Do the monitoring data design values indicate that monitoring may no longer be necessary? 

• Have the correct amount of resources been allocated to monitoring? 

Describe the process your agency utilizes here. Outline how the data will be analyzed (e.g., what 

questions will be answered). Describe how data anomalies will be resolved, and discuss how limitations 

on the use of the data will be reported to decision makers. Identify who completes this process for the 

agency and how it is formally documented and communicated.

For air agencies monitoring for NAAQS decision-making purposes, this section should include, at a 

minimum, a description of the annual data certification process using AQS as a statistical tool – and how 

the results of data certification drive potential changes within the monitoring network. Although 

additional assessments over longer periods of time (e.g., 3-year assessments) may also be completed as 
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part of the monitoring project, for SLAMS monitors, the annual data certification process is a key 

identifier in whether or not DQOs are being met (or are on target to be met). If DQOs are not met 

during annual data certification, then the assessment should serve as a catalyst within the agency to 

prompt investigation and corrective action. As such, how the results of data certification will be handled 

within the agency should be described here.

For example, if you generate an AMP 600 and see that a specific pollutant did not meet its DQO, that 

should result in multiple questions by upper management and lead to an investigation by the agency as 

to why the data didn’t meet the objective. The investigation may show that an operator(s) did not 

adhere to protocols; it may show that a new make/model of instrumentation introduced into the 

network was a “lemon”. As a result of the investigation, corrective action measures should be initiated 

that will result in improvements, such that the DQOs can be achieved next year. These corrective 

actions may include training the operators who did not adhere to protocols, or switching out the 

make/model of instrumentation that did not produce the desired results. Or, it could result in 

tightening warning limits (acceptance criteria) in the agency’s SOPs so that calibrations are conducted 

sooner, rather than later. It may involve significant modifications to the QAPP itself. 

Your project may have additional DQOs and require additional assessments beyond annual data 

certification. For some projects, such as NATTS, annual certification is not a component of the project –

as those data are not regulatory. With that in mind, your agency may utilize a more in-depth approach 

to reconciling its data against the DQOs (such as performing assessments as described in the EPA 

document Data Quality Assessment: A Reviewer’s Guide (EPA QA/G-9R, February 2006)). Therefore, if 

your agency’s end-of-year (or end-of-project) analysis goes beyond the general description provided 

here, then detail the additional steps taken by your agency in this section of the QAPP. Answer these 

questions:

• What is the frequency of the analysis? Is it annual? 

• What are the statistical analyses performed? 

• Who performs the statistical analyses? 

• What tools are used to complete the calculations?

• Do you take actions and make changes to your program and/or your QAPP as a result of 

these analyses? 

• Do you compute new confidence limits on your pollutant data sets each year and change 

the acceptance criteria within the QAPP/SOPs as a result of the analysis? Explain your 

process.

Completed QAPP? A Few Reminders Prior to Submittal to EPA! 

Check the document for the following prior to submitting for approval:

 Has the QAPP been proofread in its entirety and checked for accurate and appropriate content?

 Have all the QA/QC elements in the MQO tables (i.e., QA Handbook data validation templates)

been addressed in sufficient detail?
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 Is the QAPP readable? Meaning, is it written in plain language that will be easily understood by 

all project participants?

 Are references to regulations, guidance documents, and other documents accurate and specific? 

Check all citations.

 Beyond ensuring that the citations used are accurate, do the citations actually apply to what is 

referenced? Meaning, is the citation itself appropriate? For example, a reference to 40 CFR Part 

58, Appendix D about siting, when the more appropriate regulation would be Appendix E. 

Check all citations for appropriateness.

 Have citations within the QAPP about the QAPP been cross-checked for accuracy? For example, 

if the QAPP states, “See Section 10 of this QAPP for more information”, is Section 10 the correct 

place in the QAPP to find the necessary information?

 Have references to figures and tables in the QAPP been cross-checked for accuracy? For 

example, if the QAPP states, “See Figure 2 for a map of the monitoring network,” is Figure 2 the 

referenced map of the monitoring network? 

 Has the Table of Contents – its headers and page numbers – been cross-checked for accuracy?

 Has the entire document been checked for spelling, grammar, and typographical errors? 

 Have associated SOPs been attached to the QAPP as appendices or appropriately referenced 

within a list or table(s) in the QAPP, in accordance with 40 CFR Part 58, Appendix A, Section 

2.1.2? If not included as appendices, please ensure SOPs are available to EPA, upon request. 

 Has the document been reviewed, approved, and signed by the appropriate individuals within 

the chain-of-command, including the agency’s QA Manager (or equivalent)?

Note: After the QAPP has received EPA approval, AQS will be updated to reflect the approval status and 

date. 
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Additional References 

The following provides a list of documents which may be helpful to the QAPP writer. Please note that 

the hyperlinks provided are current as of the date of this publication and may change in the future. 

1) QA Handbook for Air Pollution Measurement Systems, Volume II (January 2017)

https://www3.epa.gov/ttn/amtic/qalist.html

2) Requirements for Quality Assurance Project Plans EPA QA/R-5 (March 2001)

https://www.epa.gov/quality/epa-qar-5-epa-requirements-quality-assurance-project-plans

3) Guidance for Quality Assurance Project Plans EPA QA/G-5 (December 2002)

https://www.epa.gov/quality/guidance-quality-assurance-project-plans-epa-qag-5

4) Guidance on Systematic Planning Using the Data Quality Objectives Process EPA QA/G-4

(February 2006)

https://www.epa.gov/quality/guidance-systematic-planning-using-data-quality-objectivesprocess-epa-qag-4

5) Data Quality Assessments: A Reviewer’s Guide EPA QA/G-9R (February 2006)

https://www.epa.gov/quality/guidance-data-quality-assessment

6) List of Designated Reference and Equivalent Methods

https://www.epa.gov/amtic/air-monitoring-methods-criteria-pollutants

7) ITEP Online Training – QAPP 201 & 202 courses

https://itep.scholarlms.com/courses/

Other EPA guidance and Technical Assistance Documents (TADs) which may be helpful to the QAPP 

writer can be found on the EPA’s AMTIC website at: https://www.epa.gov/amtic. 

EPA policy and technical memoranda can be found at the following hyperlink: 

https://www.epa.gov/amtic/policy-memoranda-and-technical-guidance

Specific recent guidance and memoranda that may be especially helpful when developing QAPPs 

include, but are not limited to, the following: 

1) EPA Review of Monitoring Organization’s QAPPs for Critical Criteria Conformance

https://www.epa.gov/amtic/policy-memoranda-and-technical-guidance

2) Steps to Qualify or Validate Data After an Exceedance of Critical Criteria Checks 

https://www.epa.gov/sites/production/files/2018-

01/documents/critical_criteria_qualifier_memo_v1_0.pdf

3) Clarification on Use of Automatic Zero Adjustments 

https://www.epa.gov/sites/production/files/2017-10/documents/technical_notezero_adjustments.pdf

4) Clarification and Guidance on Shelter Temperature Guidance for Ambient Air Pollutant Methods

https://www.epa.gov/sites/production/files/2018-

03/documents/clarifications_on_shelter_temperature_for_gaseous_pollutant_methods_03_20

18_0.pdf

5) Clarification on Statistics for Use of 1-Point QC Checks at Lower Concentrations

https://www.epa.gov/sites/production/files/2017-02/documents/tech_memo_for_1-pt_qc.pdf
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6) Technical Guidance on Identifying Annual PE Audit Levels Using Method Detection Limits and the 

99th Percentile

https://www.epa.gov/sites/production/files/2017-

02/documents/annual_pe_audit_levels_using_mdls.pdf

7) Technical Guidance on the Use of Electronic Logbooks for Ambient Air Monitoring

https://www.epa.gov/sites/production/files/2017-

02/documents/electronic_logbook_final_4_20_16.pdf

8) Clarification on Use of PM2.5 Field and Laboratory Requirements for Low Volume PM10

Monitoring to Support PM10 NAAQS

https://www.epa.gov/sites/production/files/2017-02/documents/pm10-low-vol.pdf

Please be aware that the guidance listed above is current as of the date of this publication and is 

subject to change. The AMTIC website is updated frequently with new publications, so it should be 

checked routinely. The QAPP writer may wish to join the AMTIC Listserv to receive periodic updates and 

notifications.

The Air Pollution Training Institute (APTI) 470 course, Quality Assurance for Air Pollution Measurement 

Systems, also addresses QAPPs and quality system elements that should be addressed within QAPPs, 

and would be beneficial to the QAPP writer.
United States

Environmental Protection

Agency

Office of Air Quality Planning and Standards

Air Quality Assessment Division

Research Triangle Park, NC

Publication No. EPA-454/B-18-006

August 2018