16 

CHAPTER 2 QUALITY MANAGEMENT SYSTEM 

2.1 PRINCIPAL COMPONENTS OF THE QUALTY MANAGEMENT SYSTEM 

The Quality Management System consists of staff, defined functions, tools, and quality 

assurance (QA) procedures. These components are used to ensure that environmental data 

generated by ADEQ, or its contractors/consultants, are of appropriate quality for their intended 

purpose. The ADEQ QA/QC Unit has determined that the following twelve essential elements 

comprise an effective QA System: 

 Stating of ADEQ QA Goals and Policy (identified in ADEQ’s QMP); 

 Adhering to applicable ADEQ QA requirements and criteria (EPA Orders, 

regulations, and guidelines); 

 Defining ADEQ’s QA organizational structure; 

 Describing ADEQ Programs and activities covered by the QA requirements; 

 Outlining the roles and responsibilities of those involved with ADEQ QA 

functions; 

 Utilizing QA tools and procedures; 

 Identifying resource allocations; 

 Establishing a communications process (internal and external); 

 Affording QA training opportunities; 

 Dictating documentation and record keeping requirements; 

 Implementing review and evaluation procedures to ensure continuous 

improvement; 

 Defining key QA terminology. 

2.2 PRINCIPAL TOOLS OF THE QUALITY MANAGEMENT SYSTEM 

ADEQ uses a graded approach to the Quality Management Plan, as does EPA. The graded 

approach recognizes that different projects, depending on size or complexity, may require a 

greater or lesser degree of formal planning. The successful implementation of ADEQ’s Quality 

Management Program requires a consistent and graded approach for QA practices commensurate 

with the intended uses of the data. ADEQ’s QMP requires that a variety of tools and procedures 

be utilized for planning, implementing, and evaluating the Quality Management System. ADEQ 

Managers and staff members will be informed of the availability and use of these tools through 

ADEQ sponsored training. 

The QA/QC Unit presently functions with the guidance and support of a Steering Committee, 

made up of designated QA/QC representatives from each of the three Program Divisions and one 
17 

QA/QC Unit Supervisor, who serves as the committee chair. The QA/QC Unit Supervisor 

resides in the Administrative Services Division, specifically the Business and 

General/Laboratory Services section. This section performs no environmental data collection 

activities and thereby preserves autonomy and independence. The QA/QC Unit, in conjunction 

with the Steering Committee, is responsible for establishing, implementing, and evaluating the 

details of the QMP. 

The QA planning and implementation tools include a Quality Management Plan (QMP), 

establishment of Data Quality Objectives (DQOs), Quality Assurance Program Plans (QAPrPs), 

Quality Assurance Project Plans (QAPjPs), Standard Operating Procedures (SOPs,) and 

Sampling and Analysis Plans (SAPs) or Field Sampling Plans (FSPs). ADEQ’s Program staff, or 

their contractors, create these plans with technical assistance, as necessary, from ADEQ’s 

QA/QC Unit. 

The QA evaluation and assessment tools comprising ADEQ’s Quality Management System 

include Management System Reviews (MSRs), Technical System Audits (TSAs), Performance 

Evaluation (PE) Studies, and Data Quality Assessments (DQAs). These are either arranged for, 

or performed by, ADEQ’s QA/QC Unit. 

All environmental data collection activities conducted by, or on behalf of, EPA Region IX must 

be addressed in a Quality Assurance Project Plan (QAPjP). These details are discussed in 

Section 2.2.4. 

These elements explicitly require clear Data Quality Objectives (DQOs) for each planned data 

collection activity, and also require that data assessments be conducted to evaluate the validity of 

the results. Every field investigation should be constructed in accordance with an approved 

ADEQ QAPjP, or other planning document, suitable for the task. The planning document shall 

ensure that DQOs will be met. Arizona Statutes require that the ADHS Office of Laboratory 

Licensure be responsible for licensing all labs generating data for regulatory use by ADEQ 

described in detail in section 4.2.2. 

2.2.1 Quality Management Plan (QMP) 

ADEQ’s QMP describes the policies, procedures, and systems governing Agency data collection 

activities. It serves as the umbrella document for all QA/QC operations. Future revisions and 

updates to this QMP will be prepared at least annually, and at any other time that significant 

changes occur within ADEQ’s operational structure. The QA/QC Unit will lead this process to 

gain concurrence from all ADEQ Leadership as well as the Region IX EPA QA/QC 

representatives. Revisions and/or updates will be completed and prepared for submission to EPA 

in as expeditious a manner as possible under the particular circumstances for each revision. 

2.2.2 Quality Assurance Program Plans (QAPrP) 

A Quality Assurance Program Plan is a planning document instituted at the level between the 

QMP and a QAPjP. This document is used to describe details that are specific to a Program, or 

Division, when the QMP is too general to encompass the unique circumstances for all Programs. 
18 

It is appropriate to reference Program specific regulations and guidance documents in a Program 

Plan that are utilized for defining data quality objectives such as Soil Remediation Levels (SRLs) 

and Water Quality Standards (WQSs). A QAPrP can encompass a entire Division or it can be 

specific for individual sections or Programs. The appropriate level of planning will be 

determined within the Divisions. For some Programs a QAPrP may be sufficient to be utilized in 

lieu of a QAPjP. The Programs will provide a copy of their QAPrPs to the QA/QC Unit for 

approval, general oversight, and management of the Agency wide Quality System. QAPrPs may 

also need to be sent to Region IX QA office for approval. 

 

2.2.3 Data Quality Objectives (DQO) 

ADEQ is committed to sound science during the generation of environmental data that are 

technically appropriate for their intended use. Environmental data collected should be of 

adequate quality and quantity to support intended regulatory decisions, and when necessary be 

legally defensible. Data Quality Objectives (DQO) are used in the planning phase of all Agency 

data collection activities in the capacity that defined objectives shall be identified before 

sampling goes forward. The Guidance for the Data Quality Objectives Process, EPA QA/G-4 is 

used, as appropriate, for the development of DQOs by the Agency. In many situations, 

regulatory criteria and action limits are the basis for environmental decisions. In these situations, 

the appropriate planning document should state (i.e. QAPrP, QAPjP, FSP, or SAP) that 

regulatory limits are the driving force for Data Quality Objectives, and that the formal EPA DQO 

process is not extensively utilized. Although DQOs are a required element of any Quality 

Assurance Project Plan (QAPjP), these data objectives can be identified with regulatory limits 

and/or action limits that are already in existence, and do not necessarily need to be derived. 

ADEQ Programs should discuss within their QAPrP circumstances and situations for projects 

when the DQO process will be utilized. 

Each Program within ADEQ is responsible for establishing DQOs for projects where ADEQ 

takes the lead role in gathering environmental data or for those projects where ADEQ provides 

oversight. ADEQ’s QA/QC Unit will provide technical assistance, if needed, to determine the 

appropriateness of the DQO process given the intended use of the data. 

The development of data quality objectives (DQOs) is outlined in QA/R-5. For many projects, 

DQOs may be a simple statement of why data are being collected and what data outputs will be 

considered significant. For other projects, the complete statistical hypothesis testing approach as 

described in Agency Guidance QA/G-4, Guidance for the Data Quality Objectives Process may 

be appropriate. 

Data Quality Objectives are intended to accomplish the following 

 Clarify the project objectives; 

 Define the most appropriate types of data to collect; 

 Determine the most appropriate conditions under which to collect the data; 

 Specify the level of uncertainty that is acceptable as the basis for establishing the 
19 

quantity and quality of data needed. 

2.2.4 Quality Assurance Project Plans (QAPjP) 

All QAPjP’s should be developed as specified in EPA QA/R-5, EPA Requirements for Quality 

Assurance Project Plans for Environmental Data Operations. ADEQ requires that all twentyfour elements be addressed before ADEQ’s QA/QC Unit may submit a QAPjP to EPA on 

ADEQ’s behalf. These elements consist of the following: 

Group A Project Management 

A1 Title and Approval Sheet 

A2 Table of Contents 

A3 Distribution List 

A4 Project/Task Organization 

A5 Problem Definition/Background 

A6 Project/Task Description 

A7 Quality Objectives and Criteria for Measurement Data 

A8 Special Training Requirements/Certification 

A9 Documentation and Records 

Group B Measurement/Data Acquisition 

B1 Sampling Process Design 

B2 Sampling Methods Requirements 

B3 Sample Handling and Custody Requirements 

B4 Analytical Methods Requirements 

B5 Quality Control Requirements 

B6 Instrument/Equipment Testing, Inspection, and Maintenance 

Requirements 

B7 Instrument Calibration and Frequency 

B8 Inspection/Acceptance Requirements for Supplies and Consumables 

B9 Data Acquisition Requirements 

B10 Data Management 

Group C Assessment/Oversight 

C1 Assessments and Response Actions 

C2 Reports to Management 

Group D Data Validation and Usability 

D1 Data Review, Validation and Verification Requirements 

D2 Validation and Verification Requirements 

D3 Reconciliation with User Requirements 

The QAPjP dictates the policies and procedures, project organization and objectives, QA 

requirements, and QC activities designed to achieve the desired type and quality of 

environmental data necessary to support project objectives. In ADEQ a QAPjP is utilized for 

collection and analyses of data to support long term and large scale projects. 
20 

For those activities funded by EPA, there are additional influences from the federal level on 

QAPjP preparation. ADEQ Program Plans identify projects requiring QAPjPs and the detail 

required within that planning document. Some Programs utilize abbreviated QAPjPs in the form 

of “fill in the blank” documents, although these shortened documents still need to be completed 

prior to sampling activities. Other Programs within ADEQ, such as Tank Programs, rely heavily 

on Guidance Documents for the planning process and do not require formal QAPjPs as such. 

Short-term projects and one-time events (e.g., emergency response) do not require QAPjPs as 

long as the sampling protocols and objectives are addressed in the Program QAPrP. Whether or 

not a project is funded by EPA, planning documents suitable for the task are required. These 

planning documents, in the form of a QAPjP or an alternative document, are an expected part of 

the Quality System. The detail within the documents, and the circumstances under which each 

form is appropriate, will be described in the Program specific documents. A QAPjP, or the 

equivalent planning document, must be approved by appropriate delegated autonomous Division 

personnel or by the QA/QC Unit. Additionally, all contractors for ADEQ must meet the quality 

assurance and Program requirements established by ADEQ QMP. 

2.2.5 Quality Assurance (QA) Status Reports 

 QA Status Reports are a tool used for documentation and communication of QA activities. 

Although all Programs do not make use of QA Status Reports, some of the Programs may 

require these reports, and when utilized they will be described in the appropriate QAPrP. Each 

plan for environmental data collection should include a section discussing the frequency, content, 

and format of the required QA status report(s). These factors will be determined by the relevant 

ADEQ Program Project/Case Manager. Status reports will be placed in the project file by 

ADEQ’s Project/Case Manager and will be used to help track project progress. Each status report 

should address, at a minimum, the following elements: 

 Status of the project; 

 Changes that occurred in project activities (sampling, QC control measures, 

analytical methods); 

 Results of performance and system audits as they apply; 

 Any corrective actions taken; 

 Any project organizational changes; 

 Results of the assessment of data quality indicators; precision, accuracy, 

completeness, comparability, representativeness, and sensitivity. 

For some Programs, rules or policies supersede these status reports. The policies or rules 

establish requirements similar to status reports, and can function as an alternative. The 

alternative should be referenced in the plan, and may if necessary, discuss elements in addition to 

those listed above. 

2.2.6 Standard Operating Procedures (SOP) 
21 

The use of standard operating procedures (SOPs) in ADEQ serves as one mechanism to ensure 

comparability across Programs and individual environmental data collection projects. SOPs 

must be incorporated, either in full or by reference, in the QAPjPs or QAPrPs. 

ADEQ uses a variety of SOPs, some are EPA developed documents such as Laboratory 

Documentation Requirements for Data Evaluation R9QA/004.2 August, 2001, and others have 

been developed by ADEQ. SOPs developed by ADEQ are peer reviewed. ADEQ’s QA/QC Unit 

is available for assistance in both SOP development and review. ADEQ has a number of general 

SOPs that are maintained within the QA/QC Unit. These SOPs are available for reference and 

can be incorporated into QAPjPs or QAPrPs. SOPs can also be modified to develop specific 

SOPs for a variety of Programs. SOPs for the water sample collection from Public Water 

Systems are maintained on ADEQ’s website. Some other examples of ADEQ’s general SOPs 

are: 

 Collection of Composite Soil Samples for Compliance Purpose; 

 Groundwater Monitoring Well Sampling; 

 Water Sampling from Groundwater Treatment Systems; 

 Soil Vapor Sampling Guidance; 

 Soil Vapor Sampling for Remediation Systems. 

2.2.7 Technical Systems Audit (TSA) 

All ADEQ Programs that employ environmental sample collection and analyses are subject to a 

TSA. TSAs are a principal tool of ADEQ’s quality system and are defined more thoroughly in 

Section 9.2.2. 

2.2.8 Management System Reviews (MSR) 

Management System Reviews (MSRs) will be performed periodically within ADEQ for all 

Programs. Further details on MSRs are provided in Section 9.2.1. 

2.2.9 Corrective Actions 

In the normal case, deficiencies are identified, and corrective actions are initiated, as a result of a 

review or audit. However, there are cases when deficiencies are identified during normal work 

routines, outside a review or audit. In these cases a corrective action memo is generated to 

document and communicate the deficiency. The memo, at a minimum, explains the problem and 

documents procedural changes and actions that will correct the problem and minimize the chance 

for repeat problems and deficiencies. In some situations, no corrective action is required; 

however, it is necessary to document the occurrence. For these situations, the corrective actions 

can be referred to as non-conformances. 

2.3 OPTIONAL PRACTICES FOR THE CONTROL OF DATA COLLECTION 

2.3.1 Field Audits 
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These are "real-time" observation, review, and critical appraisal of field sampling activities. 

Field audits consist of an on-site visit to the sampling location; observation of sampling 

practices; review of project records and sampling SOPs; and, documentation of findings. The 

primary intention of such audits is to ascertain whether the QAPjP specified practices are being 

followed. 

When sampling is being performed by ADEQ personnel, or ADEQ contractors, the lead auditor 

must be an ADEQ employee. In these circumstances, audits may be requested through the 

ADEQ QA/QC Unit, and are performed by non-project personnel to avoid the appearance of 

bias. 

All field auditing activities will result in the production of a written report. Usually, the 

draft findings report should be prepared by the Lead Auditor within 30 days of the observation 

phase of the audit, although it may need to be prepared more quickly in some cases. Whether 

internal or external, the Auditor should send the report to the ADEQ Project/Case Manager for 

review. For external audits, the ADEQ Project/Case Manager will pass the audit report onto the 

auditee for comments. Final reports generated by the Audit Team are to be completed within a 

reasonable and appropriate time. Copies of the Final Report will be stored in the Project file and 

with the auditor. Additional copies will be distributed as appropriate. 

2.3.2 Laboratory Audits 

These are audits of laboratory operations. Such audits may be "real-time" (i.e., performed while 

project samples are under analysis) or performed after analysis is completed. Laboratory audits 

will consist of an on-site visit to the laboratory, observation of analytical practices when 

possible, review of project records and laboratory SOPs, and documentation of findings. A 

laboratory audit is conducted to determine and document whether laboratory practices and 

analytical procedures used are consistent with QAPjP requirements and laboratory tasking 

instructions. 

When analyses are being performed by ADEQ contractors, the lead auditor must be an ADEQ 

employee. In these circumstances, audits may be requested through the ADEQ QA/QC Unit, 

and are performed by non-project personnel to avoid the appearance of bias. 

All laboratory auditing activities will result in the production of a written report. A draft of this 

report is due within 7 calendar days of the completion of the observation phase of the audit, or a 

mutually agreed upon alternative. The draft will be sent for comments to the ADEQ 

Project/Case Manager responsible for the activity observed prior to completion of the report. 

Written comments must be supplied by the ADEQ Project/Case Manager to the ADEQ QA/QC 

Unit within 7 calendar days of the receipt of the draft, or a mutually agreed upon alternative. 

Final reports generated by the ADEQ QA/QC Unit are to be completed within 30 calendar days 

of receipt of comments by the ADEQ Project/Case Manager, or a mutually agreed upon 

alternative. Copies of the Final Report will be stored in the Project’s file and also with the 

ADEQ QA/QC Unit. Additional copies will be distributed as appropriate. 
23 

CHAPTER 3 PERSONNEL QUALIFICATIONS AND 

TRAINING 

3.1 POLICY FOR QUALITY ASSURANCE (QA) RELATED TRAINING 

The purpose of this Chapter is to explain the processes used by ADEQ to ensure that staff and 

managers working in environmental Programs are trained and qualified to perform their required 

QA responsibilities. This includes Project/Case Managers, field personnel, ADEQ QA/QC staff, 

data processors, and the individuals who supervise these personnel. 

3.1.1 Responsibilities 

ADEQ’s Program Unit Managers are responsible for ensuring that each staff member involved 

with collecting or analyzing environmental data has the necessary technical, quality assurance, 

and project management training required for his or her assigned tasks and functions. Section 

Managers are also responsible for ensuring that technical staff maintains the necessary level of 

proficiency to effectively meet ADEQ’s QA/QC responsibilities. ADEQ’s QA/QC Unit will 

serve as the Agency resource for arranging for, and assisting in, defining QA/QC training needs 

on a regular basis to update Program staff with developing QA/QC issues. 

Maintaining staff proficiency in critical technical disciplines (e.g., environmental engineers, 

geologists, hydrologists, hydrogeologists, chemists, and microbiologists) is assumed to be 

determined within the hiring process. 

3.1.2 Identification of Training Needs 

Core training will be coordinated through the QA/QC Unit in conjunction with various Division 

supervisory personnel. Intermediate and advanced skill training will be arranged when the 

appropriate Agency staff identify the need. The QA/QA unit, in conjunction with Program 

management, will identify continuing professional training requirements and address those 

requirements utilizing external resources for the latest technological advances and evolution in 

industry standards. 

3.1.3 Implementation of Training Requirements 

ADEQ staff are encouraged by supervisors to draw upon their educational background, 

experience, technical training, and on-the-job training to enhance their understanding and 

performance of QA-related procedures. 

ADEQ’s QA/QC Unit is developing a training program that will offer, or arrange for through a 

third-party vendor, the following courses on a schedule and frequency suited to meet the needs of 

ADEQ’s staff with QA responsibilities: 

 An Orientation to Quality Assurance Management 

 Establishing Data Quality Objectives 
24 

 Preparing Quality Assurance Project Plans 

 How to Perform a Preliminary Data Review 

The goal is to offer no less than three of the four courses during the year. The classes will be 

open to anyone responsible for QA functions. ADEQ’s QA/QC Unit will also schedule 

impromptu QA training designed to address specific QA needs of Program staff. 

It is a goal that ADEQ Program staff responsible for QA functions (as identified by Program 

management) should complete the above courses within two years from their employment date. 

In addition, they will be encouraged to attend meetings and seminars, and to take formal training, 

in accordance with ADEQ’s training policy, to enhance their understanding of Program specific 

QA requirements within the Programs they work. 

3.1.4 Documentation of Training 

ADEQ’s QA Unit will maintain a record of all QA training taken by staff and managers 

responsible for environmental data generation. ADEQ’s Leadership Team will provide resources 

for QA training for ADEQ Program staff. This training will be provided, through internal 

training and/or external sources, to staff at all levels to ensure that QA requirements and 

responsibilities are understood and implemented at all stages of projects. Some of the training 

required to support ADEQ’s Quality Management System will come from EPA. 
25 

CHAPTER 4 PROCUREMENT OF ITEMS AND SERVICES 

ADEQ procures items such as sampling equipment, instrumentation, field equipment, laboratory 

services, and consulting services. All items and services relating to environmental data 

collection and generation are obtained through the procurement process. The ADEQ public 

procurement process is guided by the Arizona Procurement Code (Arizona Revised Statutes 41-

2501 et seq., and administrative rules and regulations A.A.C. R2-7-101 et seq.). This 

procurement code has modeled itself on the Model Procurement Code as provided by the 

American Bar Association. The procurement process is also governed by State statutes and 

rules, and depending on the circumstances of the procurement, may involve the approval of other 

agencies within the State. Whenever appropriate, requirements for equipment and services 

specific to individual Programs should be detailed in QAPrPs or QAPjPs. Procurement activities 

may range from general and scientific supplies to highly sophisticated scientific instrumentation 

and services which directly affect the quality of environmental measurements. 

4.1 ITEMS 

Within ADEQ, identified equipment needs are submitted to management who prioritize, rank, 

and approve items for proposed procurement. This process allows ADEQ to identify particular 

equipment needs, relative to other needs, in order to facilitate quality in measurement processes. 

Specific monitoring, sampling, and analytical equipment are procured only after quality 

requirements have been discussed among procurement officials, Program personnel, and when 

appropriate, ADEQ’s QA/QC Unit. The Contracts and Procurement Section requires that items 

meet the approved specifications. The criteria for selection of the specific items are outlined 

prior to approval of the equipment. 

4.1.1 EQUIPMENT MAINTENANCE 

ADEQ field personnel are responsible for maintenance of their own field equipment and 

instrumentation. ADEQ has either service contracts or in-house capabilities for the repair and 

maintenance of field equipment and instrumentation. Schedules for preventive and/or corrective 

maintenance are determined and carried out through service contracts or in-house capabilities. 

4.2 SERVICES 

Project managers work with the ADEQ Contracts and Procurement Section to incorporate quality 

control within the specific scope of work for each task assignment. Quality assurance for service 

contracts is based on contractor performance measures which include, but are not limited to, the 

ability of the contractor to adhere to the contract terms and conditions, and the ability of the 

contractor to complete the work in accordance with the ADEQ approved QAPjP, SAP, and/or 

other work plan. Services (laboratory, consulting, drilling, etc.) that are procured through 

ADEQ's procurement process are contracted in accordance with the standard terms and 

conditions of the Uniform Commercial Code as adopted by the State of Arizona. The standard 

terms and conditions, at a minimum, include the following: 

 Contract interpretation; 
26 

 Contract administration and operation; 

 Costs and payments; 

 Contract changes; 

 Risk and liability; 

 Warranties; 

 State contractual remedies; 

 Contract termination. 

The Project/Case Manager from the applicable ADEQ Program can utilize the ADEQ QA/QC 

Unit in finding services appropriate for his or her needs. Prior to procurement of services, it is 

important that the data quality objectives and measurement quality objectives of the specific 

project, as they relate to analytical requirements, can be achieved by the laboratory. The 

laboratory needs to submit a current Quality Assurance Manual (or similar documentation) for 

review before the contract is awarded. 

4.2.1 CONTRACTS WITH EXTERNAL PARTIES 

ADEQ conducts and oversees assessment (site characterization), remediation, and removal 

activities at solid and hazardous waste sites in Arizona. For some of these activities, ADEQ may 

contract directly for environmentally related measurements or data generation. 

ADEQ’s General Laboratory Services Contract goes out to bid every 3-5 years. This contract is 

for General Laboratory Services for a variety of analyses and methodologies and can be awarded 

to one or more laboratories. This process is a collaboration of ADEQ’s Procurement Section, the 

QA/QC Unit, and/or QA/QC Steering Committee. All Divisions can utilize this contract for 

analyses within their Divisions. 

The Monitoring Assistance Program (MAP) is a Program mandated by Arizona Revised Statutes 

49-360, for which ADEQ contracts with vendors to take samples and perform necessary analyses 

for approximately 900 small drinking water systems within the State of Arizona. This contract 

goes out to bid through the Drinking Water Section and is awarded on an annual basis. 

For services procured outside of the general laboratory services contract, and the MAP contract, 

the Programs are responsible for ensuring that the contractors meet the quality assurance 

requirements as outlined in the Program specific QAPrP. It is necessary, at a minimum, to 

obtain a Quality Assurance Manual from any contracting laboratory prior to commencement of 

work. Other areas where contractors and subcontractors are utilized include: ambient surface 

water analyses for chemical and microbiological indices, air quality analyses, etc. 

For contractors performing sampling, the contractors must develop their own QAPrP or QAPjP. 

In some instances where contractors are handling extensive sampling and data management at 

multiple levels, it may even be appropriate for the contracting organization to have an overall 

Quality Management System documented in a QMP. 
27 

4.2.2 Laboratory Licensure Requirements 

In addition to the requirements of the Arizona Procurement Code (A.R.S. 41-2501 et. seq.) and 

the Arizona Administrative Code (A.A.C. R2-7-101 et. seq.), Arizona Revised Statutes require 

that the ADHS Office of Laboratory Licensure license environmental laboratories engaged in 

compliance testing. 

Compliance testing has been defined by Arizona State Law pursuant to A.R.S. 

36-495(1) as any: 

“Laboratory analysis of any matter, pollutant, 

contaminant, hazardous substance or other substance 

subject to regulation pursuant to: 

(a) Title 49 or rules adopted or enforced by the department 

of environmental quality for the purpose of determining 

compliance with title 49. 

(b) Federal environmental statutes or regulations 

administered or enforced by the United States 

environmental protection agency relating to the safe 

drinking water act (42 United States Code sections 300f 

through 300j), the clean air act (42 United States Code 

sections 7401 through 7642), the clean water act (33 United 

States Code sections 1251 through 1376), the resource 

conservation and recovery act (42 United States Code 

sections 6921 through 6939B), the comprehensive 

environmental response, compensation, and liability act (42 

United States Code sections 9601 through 9657) and the 

toxic substance control act (42 United States Code sections 

2601 through 2654) as they relate only to the regulation of 

polychlorinated biphenyls and asbestos.” 

Samples analyzed for regulatory or enforcement decisions by non-ADHS licensed laboratories 

are considered unacceptable for compliance purposes, as statutorily mandated, and should be 

rejected unless no other options are available. As testing requirements evolve with the 

introduction of new contaminants of concern, there may be unique cases when an ADHS 

certified laboratory is not available for the methods required or capable of achieving the required 

limits. For instances when a method is not certified by ADHS, or no ADHS laboratories are 

available, an exception can be made. All other resources should be exhausted before this option 

is utilized. These instances should be communicated to the QA/QC Unit to track overall 

regulatory issues and develop solutions in coordination with ADHS. 

Upon application for an environmental laboratory license ADHS shall issue the license if, after 

investigation, ADHS determines that the application conforms with the standards established by 

ADHS. 
28 

The ADHS Director shall prescribe rules providing for minimum standards of proficiency, 

methodology, quality assurance, operation, and safety for environmental laboratories and may 

prescribe standards for personnel education, training, and experience to meet Federal 

environmental statutes or regulation. The ADHS Director may also allow reciprocity with other 

states, and prescribe the manner and form in which compliance testing results are reported. The 

rules shall be developed in cooperation with the Director of the Department of Environmental 

Quality and shall be consistent with Title 49 (Section 49-101 et seq.). 

Unless exempted by A.R.S. 36-495.02, no person may operate or maintain an environmental 

laboratory without a license issued by the ADHS pursuant to A.R.S. 36-495.03 through 36-

495.14. 

4.3 THE ROLE OF THE ADEQ QA/QC UNIT IN THE PROCUREMENT PROCESS 

ADEQ’s QA/QC Unit will assist the Procurement Section in the development of the Request for 

Proposal (RFP), or Invitation for Bid (IFB), for the General Laboratory Services Contract which 

will occur approximately every 3-5 years. The QA/QC unit will provide input on minimum 

Quality Control requirements for Contract Laboratories as well as items to be included in 

submittal for QA/QC evaluation. 

ADEQ’s QA/QC Unit will advise the Drinking Water section on minimum QA/QC standards for 

laboratories contracted for the Monitoring Assistance Program. 

When appropriate, ADEQ’s QA/QC Unit or its delegate should review a laboratory’s Quality 

Assurance Manual, or its equivalent, before the formal execution of any agreement or related 

action with the organization. 

The QA/QC Unit will confer with ADHS on the good standing of laboratories that are contracted 

with, or submitting compliance data to, ADEQ. 

4.4 THE ROLE OF ADEQ PROJECT/CASE MANAGERS IN THE PROCUREMENT 

PROCESS 

ADEQ Program Personnel should define the quality of performance and specifications required 

of services, instruments, and reagents. 

The responsibility for monitoring contract performance within ADEQ’s Quality Management 

System lies with the Programs and ADEQ’s Procurement Section. All contracts are managed in 

accordance with the State procurement code. 

4.5 AGREEMENTS WITH GOVERNMENTAL ENTITIES 

ADEQ also utilizes governmental agreements with EPA and other Federal, State, and local 

agencies. A.R.S. 41-2501 exempts governmental agreements from the Arizona Procurement 

Code. Agreements between ADEQ and other state agencies, or universities, to provide or 

receive a service are authorized under A.R.S. 35-148. Agreements between ADEQ and another 
29 

State Agency, political sub-division, or other governments to share joint authority (authority 

possessed by both parties) are authorized by A.R.S. 11-951 through 11-952. 

In the event that a governmental agreement scope of work would include environmentally related 

measurements or data generation, the ADEQ QA/QC Steering Committee’s role would be 

substantially the same as it is for the General Laboratory Services Contract. Procurement’s role 

would include coordination with the ADEQ QA/QC Unit Manager or his or her designee, the 

ADEQ Project/Case Manager, and the outside political subdivision, and then final negotiation of 

the governmental agreement. 

 4.5.1 ADHS and State Laboratory Services (SLS) 

The ADHS provides support for ADEQ as necessary for laboratory services, method 

development, risk assessments, development of some regulatory limits, and expert testimony. 
30 

CHAPTER 5 DOCUMENTATION AND RECORDS 

MANAGEMENT 

Maintaining important quality assurance (QA) documents and records is a continuous process at 

ADEQ. This process serves as a vehicle for identifying quality-related documents and records 

requiring management control. Moreover, this process serves to assure that QA documents and 

records are accessible, and protected from damage and deterioration during storage. Finally, 

ADEQ’s Records Management Process ensures compliance with all statutory and contractual 

requirements for records involving environmental Programs. ADEQ Records Management 

System also provides adequate preservation of key records necessary to support the mission of 

ADEQ. 

5.1 DEFINITION OF PUBLIC RECORDS 

"Records" as defined in ARS § 41-1350, “means all books, papers, maps, photographs or other 

documentary materials, regardless of physical form or characteristics, including prints or copies 

of such items produced or reproduced on film or electronic media, made or received by any 

governmental agency in pursuance of law or in connection with the transaction of public 

business and preserved or appropriate for preservation by the agency or its legitimate successor 

as evidence of the organization, functions, policies, decisions, procedures, operations or other 

activities of the government, or because of the informational and historical value of data 

contained therein. Library or museum material made or acquired solely for reference or 

exhibition purposes, extra copies of documents preserved only for convenience of reference and 

stocks of publications or documents intended for sale or distribution to interested persons are not 

included within the definition of records as used in this chapter.” 

5.2 EXCLUSIONS FROM THE DEFINITION OF PUBLIC RECORDS 

ARS § 49-205 indicates that: 

A. Any records, reports or information obtained from any person under this chapter, including 

records, reports or information obtained or prepared by the Director or a department employee, 

shall be available to the public, except that: 

1. Income tax returns are confidential; 

2. Drinking water system security vulnerability assessments that are submitted to the 

United States Environmental Protection Agency, pursuant to Public Law 107-188, 

are exempt from disclosure under this chapter and Title 39, Chapter 1; 

3. Other information, or a particular part of the information, shall be considered 

confidential on either: 

 (a) A showing, satisfactory to the Director, by any person that the information, or a particular 

part of the information, if made public, would divulge the trade secrets of the person. 
31 

(b) A determination by the Attorney General that disclosure of the information or a particular 

part of the information would be detrimental to an ongoing criminal investigation or to an 

ongoing or contemplated civil enforcement action under this chapter in superior court. 

B. Notwithstanding subsection A of this section, the following information shall be available to 

the public: 

1. The name and address of any permit applicant or permittee; 

2. The chemical constituents, concentrations and amounts of any pollutant 

discharge; 

3. The existence or level of a concentration of a pollutant in drinking water or in the 

environment. 

C. Notwithstanding subsection A of this section, and in addition to the information prescribed by 

subsection B of this section, the following information that is obtained by the department and 

that relates to discharges authorized by a permit issued under the Program adopted pursuant to 

section 49-203, subsection A, paragraph 2 shall be made available to the public by the 

department: 

1. Information required to be submitted in a permit application; 

2. The frequency of the discharge; 

3. The temperature and pH level of the discharge; 

4. Other water quality characteristics that are required to be reported under the 

permit. 

D. Notwithstanding subsection A of this section, the Director may disclose any records, reports 

or information obtained from any person under this chapter, including records, reports or 

information obtained by the Director or department employees, to: 

1. Other state employees concerned with administering this chapter or if the records, 

reports or information is relevant to any administrative or judicial proceeding 

under this chapter; 

2. Employees of the United States Environmental Protection Agency if such 

information is necessary or required to administer and implement or comply with 

the Clean Water Act, the Safe Drinking Water Act, Comprehensive 

Environmental Response Compensation and Liability Act (CERCLA) or 

provisions and regulations relating to those acts. 
32 

Materials excluded from the definition of public records include reference material, extra copies 

of articles, periodicals, reports, documents, blank forms, extra copies of documents preserved for 

convenience of reference, studies, vendor catalogs, and similar materials that are needed for 

convenience or reference, but are not part of the official file. Such items should be destroyed as 

soon as they are no longer needed and according to an approved retention schedule. 

Other materials excluded from the definition of public records, but maintained in confidential 

files, include draft documents, such as electronic and marked up copy drafts. 

5.3 CONFIDENTIAL DOCUMENTS 

Some documents collected, received, or generated may, by nature and content, be documents 

which require special handling procedures. Documents of this category may be, but are not 

limited to, enforcement sensitive/enforcement confidential, attorney client, or confidential 

business information (CBI). Confidential documents are handled in accordance with state law 

and ADEQ policy. Only ADEQ staff are allowed to see documents classified as enforcement 

confidential. Confidential documents shall be maintained separately from other QA documents. 

Only those ADEQ staff, and others, who have been trained and authorized can access CBI files. 

In most cases criminal sanctions exist for unauthorized disclosure of CBI. Nothing in the 

requirements put forward in this QMP shall be construed to supersede any existing requirements 

for handling enforcement sensitive or confidential documents. 

5.4 ROUTINE QUALITY ASSURANCE AND RECORDS MANAGEMENT 

The ADEQ Records Management Process addresses the system employed by the Agency for 

handling documents. This plan outlines the roles and responsibilities for management and staff 

concerning chain of custody procedures and records management. 

ADEQ document control procedures require that documents generated, or obtained, by Agency 

personnel be accounted for when a project is completed. ADEQ’s Records Management System 

dictates the procedures for checking-in and checking-out files for ADEQ staff, external clients, 

and the public. 

For reasons of file integrity, the files must be reviewed in the presence of the Custodian of 

Records or his or her designee. No file can be certified as an original copy if it is reviewed by 

anyone without a staff member from the Custodian of Records being present. The chain of 

custody for all Agency files must be carefully guarded in order to have the greatest degree of 

integrity regarding Agency files. 

ADEQ creates and maintains a unique identification code for each investigation or project. 

ADEQ Records Center is able to use the identification codes, and their cross referencing 

capabilities, to identify the contents and location of the investigation/project files. All custody 

tags, custody records, field notes, or analytical records are labeled with ADEQ generated 

identification codes. Each file is required to have an identification code, date, the Agency 

Project/Case Manager’s initials or signature, and where appropriate the ADEQ Index and PCA to 

indicate the source of the funding for the project. Data packages generated by laboratories which 
33 

are requested by Project/Case Managers, and submitted to the ADEQ QA/QC Unit Supervisor, 

will be maintained by the ADEQ QA/QC Unit. 

The QA/QC Unit is responsible for maintaining a directory of QA/QC documents within the 

Agency, this includes the QMP, QAPrPs, QAPjPs, FSPs, SAPs, SOPs, and other related QA/QC 

documents. Duplicates of many of these documents are stored electronically within the QA/QC 

Unit. Original QA documents are organized by project or site. These documents, along with 

other records generated, are stored in the applicable Program offices within ADEQ or in the 

Central Records Management Office. The records will be centrally managed via the records 

management system, but physically may reside in the Program files, project file, or in the records 

review area. Regardless of physical location of a file, records and documents associated with a 

given project are the responsibility of the Division Program that has primary responsibility for 

that project. Hard copies of site or project specific information such as sample field sheets, chain 

of custody records, laboratory notes, and instrument/equipment readings shall be maintained in 

the official project file. The ADEQ Project/Case Manager is responsible for assuring that all 

field and analytical identification codes referencing the project are maintained in the project file. 

Correspondence that is material to the project and is generated on the network shall be printed 

and maintained in the applicable project file. 

The ADEQ Director represents the final custodian of that information. Projects involving the 

generation of environmental data shall include, at a minimum, the Quality Assurance Project 

Plan (QAPjPs) and final laboratory reports. For projects not funded by EPA some project 

planning documents other than a QAPjP may be acceptable providing that the objectives are 

clear and the documentation is likely to produce data of known quality and appropriate for its 

intended use. QAPjPs submitted to ADEQ are peer reviewed by the respective Project/Case 

Manager, and approved by designated Program staff. The approval process is based upon 

guidelines set forth by the QA Steering Committee. The process for QAPjP review is spelled out 

in corresponding QA Program Plans. Approved copies, with the approving signatures, are 

retained by the Program’s Project/Case Manager and the ADEQ QA/QC Unit Supervisor, or his 

or her designee. The QAPjP and the final analytical reports will be stored together, thereby 

allowing a subsequent analyzer (the ADEQ QA/QC Unit Supervisor or designated Program 

staff), or investigator, to understand the full context of the data produced and the conclusions 

reached. 

The ADEQ QA/QC Steering Committee, in conjunction with EPA Region IX where appropriate, 

ensures that all Quality Management Plans and Quality Assurance Project Plans are current. 

Should one of these documents become outdated, the ADEQ QA/QC Unit Supervisor and EPA 

Region IX, in conjunction with the ADEQ Project/Case Manager, shall determine the status of 

the plan and initiate appropriate action. The Division Program and the ADEQ QA/QC Unit 

Supervisor shall be responsible for maintaining copies of ADEQ revised/approved QAPrPs and 

QAPjPs for five years after completion of the project. 

ADEQ management will assure that the objectives of the Records Management Process are 

achieved. These objectives include the following: 

 Prevent the creation of unnecessary records in any media; 
34 

 Promote the continuous development of filing systems and structures that allow 

for the efficient organization, maintenance, and retrieval of records; 

 Ensure that records of continuing value are preserved, but that valueless or noncurrent information is disposed of or transferred to storage in a timely manner in 

accordance with ADEQ and/or ADHS records retention requirements; 

 Ensure that the acquisition and use of all direct paper to microform systems and 

equipment, or electronic digital imaging, are technically feasible, cost-effective, 

and most importantly, satisfy Program needs; 

 Preserve and protect information that is vital to the essential functions or mission 

of the organization. Preserve and protect information that is essential to the legal 

rights and interests of individual citizens and the government. 

 5.5 IN-HOUSE QUALITY ASSURANCE GUIDANCE DOCUMENTS 

Quality guidance documents developed in-house are peer reviewed by ADEQ’s QA/QC Unit and 

the appropriate Divisional Program. Most of the in-house quality guidance documents are 

formatted as SOPs covering specific environmental monitoring activities such as field inspection, 

sample collection/handling, analytical protocols, and data evaluation as mentioned in section 

2.2.6. Also, the ADEQ QA/QC Unit maintains on ADEQ’s website, SOPs for the collection of 

water samples from Arizona public water systems that will be submitted to ADHS certified 

laboratories for analysis of volatile organic compounds (VOCs), synthetic organic compounds 

(SOCs), and inorganic compounds (IOCs). These SOPs have been peer reviewed and approved 

by EPA, and the ADHS State Laboratory, for ADEQ use. 

Other in-house quality assurance guidance documents include policies. The ADEQ QA/QC 

Steering Committee drafts quality assurance and analytical policies to express the Agency’s 

position when interpreting analytical data generated by laboratories using EPA methods which 

may have multiple procedural interpretations. One such Agency wide policy is ADEQ Policy # 

0154.000 Addressing Spikes and matrix effects. 

5.5.1 Requirements for Field Documentation 

Documentation of field activities establishes procedures, identifies written records, enhances and 

facilitates sample tracking, standardizes data entries, and identifies and establishes authenticity 

of the sample data collected. Proper documentation helps to ensure that all essential and required 

information is consistently acquired and preserved. Timely, correct, and complete 

documentation establishes the chain-of-custody, a requirement for data intended to provide 

evidence in court proceedings. Exact procedures vary from Program to Program and are detailed 

within individual Program documents. 

Field records shall be generated and stored as specified in project specific QAPjPs, SOPs, or 

guidance for handling field records. 

5.6 MAINTAINING DOCUMENT INTEGRITY 
35 

Following all required ADEQ documented policies and actions regarding Records Management, 

the file clerk, and all other ADEQ staff, with access to potentially sensitive documents and 

records (i.e., audit reports and performance evaluation reports) will take special care to preserve 

the integrity of these documents. If sensitive documents are to be used at a work station, due 

care will be used in order to maintain the integrity of the data. 
36 

CHAPTER 6 INFORMATION TECHNOLOGY (IT) AND DATA 

MANAGEMENT 

Data management serves a critical function in both preserving information and making that 

information available. Data management necessarily encompasses a variety of activities related 

to planning environmental monitoring, collecting samples from different media, laboratory and 

in-situ analysis of samples, organizing and storing resulting data, analyzing and interpreting data, 

disseminating data, and communicating the monitoring results and knowledge gained. 

The way ADEQ manages data has evolved substantially in the past decade primarily due to 

Internet availability (e.g., opportunities in electronic government), increased emphasis on 

enterprise architecture, and the need for better security of environmental data. Also, ADEQ 

strives to comply with all EPA standards and regulations, as appropriate, pertaining to hardware, 

software, database system development, and data reporting. 

This section summarizes the department’s information management practices and related 

information technology topics. Additional aspects of project management, such as planning, 

data gathering, and evaluation by ADEQ Programs, are addressed in the QAPrPs or other project 

planning documents as appropriate. 

6.1 MANAGEMENT PRACTICES FOR ENVIRONMENTAL DATA 

An important Agency goal is to continue to improve the way data are generated, compiled, 

stored, and disseminated across each of the ADEQ Divisions (Air, Waste, Water, and 

Administrative Services). The manner data are managed is governed by the Agency mission, 

Program business needs (e.g., permitting, compliance, assessments), and specific data collection 

project/Program objectives. Additional activities that influence data management approaches 

include EPA reporting requirements, quality assurance, cost control, and security. 

Information management systems are typically evaluated for return on investment, risk 

management, and total cost of ownership. This has led ADEQ to adopt an Oracle-based 

enterprise architecture that offers common services and consolidated purchases as a foundation 

for all our major database applications that include, but are not limited to, AZURITE (the 

Agency’s enterprise database application for managing data related to the functions of 

licensing/permitting, inspections, compliance, and remediation), Air Assessment Ambient 

Database (AAAD),Water Quality Database, Safe Drinking Water Information System (SDWIS), 

Surface Water Quality System, Groundwater Quality System, Drywell System, Water Permits 

and Certifications System, Engineering Review System, and Global Positioning System Data 

Post-processing. 

6.1.1 Database Development: 

Data models are employed when developing database systems to serve as a bridge between those 

collecting the data and the information processing systems that support those using the data. 

Data models are basically conceptual schemas that map data relationships, focusing on those 

relations that matter most to the business. ADEQ utilizes a standard System Development 

Lifecycle Methodology for information projects, and a rapid application development method, as 
37 

appropriate. Generally, the methods used include an analysis and documentation of user 

requirements, followed by system design specifications. ADEQ uses the Oracle Designer tool to 

document requirements and system design. ADEQ coding standards are published and 

implemented, ensuring consistency and maintainability of source code. A project team approach 

is utilized, which includes end user involvement throughout the project lifecycle. User 

documentation, including on-line help, is provided with each database system as resources 

permit. 

6.1.1.2 Systems development planning 

The State of Arizona utilizes a standard Information Technology (IT) project planning and 

justification process. The Government Information Technology Agency (GITA) reviews and 

approves Project Investment Justifications (PIJs) for IT projects with a combined developmental 

and infrastructure cost greater than $25,000. PIJ approval must be received before budget 

monies can be allocated to an IT project. The central IT organization works in unison with the 

Program IT specialists to plan, prioritize, and implement Agency IT projects. 

6.1.2 Data Quality and Data Integrity: 

Data integrity and data quality are related in the fact that both are needed to ensure that the data 

are sufficient for their intended use. For the purpose of this document data quality relates to the 

process used to collect, analyze, verify, and validate environmental results. Data integrity relates 

to the input, storage, maintenance, and retrieval of those results. 

6.1.2.1 Data Quality: 

Before environmental data are entered into any database, and released for production, producers 

of the data shall use a standard Quality Assurance procedure to verify that they meet the 

requirements of their intended use. QAPrPs will describe the level of QA/QC necessary for their 

Programs and should include references to how data quality is determined with regards to 

precision, accuracy, representativeness, comparability, completeness and sensitivity. 

Regardless of the data entry method, manual entry or electronic file transfer, data entry personnel 

should verify that the data meet the above criteria prior to input into the database. Questionable 

data may be entered and maintained in a database if they are appropriately documented, 

qualified, or flagged. 

6.1.2.2 Data Integrity: 

The data integrity process begins once the data are ready for input into the databases. Data 

integrity addresses the vulnerability of the system to unauthorized access, data manipulation, 

theft, and environmental damage. 

 

These threats are mitigated by implementing a strong internal database QA/QC process. This 

includes a security process, further detailed in Section 6.8, that recognizes database users through 

logons and assigned database roles. The process begins through ADEQ’s AZURITE database 

that maintains ADEQ’s centralized core data such as: 
38 

 PERSON (Individual users of the database, including tracking information); 

 PLACE (The sites and facilities that ADEQ regulates or tracks); 

 CUSTOMER (individuals, organizations, and businesses that ADEQ regulates or 

interacts with); 

 LTF (Licensing Time Frames). 

 

Daily verification is performed on PLACE, CUSTOMER, and LTF core data to assure that data 

entry standards are followed, that location information is provided, and that a duplicate record 

does not exist before validating a new record as part of ADEQ core data. Any record that is not 

complete, or does not meet data entry standards, will be returned to the originating Program for 

correction, and the use of that data will be restricted until corrected. 

Presenting data in an understandable and useful format is a key component in ensuring data 

integrity. Agency projects will be presented in a way that is suitable for the intended audience. 

The following guidelines are implemented by ADEQ, to the extent applicable, useful, and 

possible in designing effective approaches to Agency projects: 

1. Establish a context for presenting data using one or many of the following 

techniques: displaying data in a geographic context, combining the new data 

source with existing collections of monitored data, or aggregating the data 

collected to demonstrate a trend or ongoing view of the environmental conditions. 

ADEQ will present the data in ways that make that data relevant and useful; 

2. Format data for easy interpretation so data are portrayed with the intended 

message and not misused. ADEQ will make every effort to ensure that data will 

always be presented in a format that is easy to understand and not subject to 

misinterpretation. This includes not separating data from corresponding 

documentation, qualifiers, or flags that may indicate the usability of the data; 

3. Be responsive to the users of the data by staying abreast of changing user needs, 

Agency IT projects are designed to include ways for users to provide feedback on 

the projects. 

Metadata are additional information related to the primary results that are being presented, 

commonly known as data about the data. This supporting information can significantly impact 

the usability of the primary data and should always be considered. Specifically, metadata include 

positional/location data, field measurements, temperatures, quality control data, data qualifiers, 

meteorological data, facility information, and site conditions. The storage of metadata is specific 

to each of the databases maintained at ADEQ. Each database, and the Programs associated with 

the database, are delineated in relevant Program documents and detailed in the Program’s 

QAPrP. It is important to note that metadata often provide substantial information relating to 

environmental results and should not be separated from those results if it changes the meaning, 

or usability, of the data in any way. 
39 

Audits and Testing are required for all databases and systems. All IT projects involving 

development of systems for tracking of environmental data will be thoroughly tested to ensure 

that they meet the requirements in the written functional specifications. Independent audits of 

these systems will be conducted by the QA/QC Unit. The central IT organization has a test 

server environment that is in place, and is utilized regularly to test Agency applications prior to 

being released into production. 

6.1.3 Establishing back up and archiving procedures: 

Department Programs will coordinate with the Office of Information and Technology to establish 

standard procedures for data backup and archiving, system failure, and recovery. Data sets will 

be archived to provide a historical record of data over the lifetime of the project. Current 

procedures involve daily full or incremental backups of all critical Agency data that are stored on 

site at ADEQ. Weekly and monthly back up of all critical data are kept in perpetuity and stored 

off site at ADEQ’s Disaster Recovery location in Tucson. Should a catastrophic event occur that 

renders our Phoenix computer equipment unusable; ADEQ will be able to operate using the 

equipment and data located in Tucson. 

6.2 INFORMATION MANAGEMENT PLAN 

ADEQ has an information management plan that documents its approach to data collection, 

storage, retrieval, delivery, and communication. ADEQ also has procedures for data quality 

control and security, which may be incorporated, as appropriate, into QAPrPs. 

The information management plan includes the following elements: 

 Data Owners Data are owned by the Programs. This information plan 

provides the primary contact information of the individual and Program that has 

overall information management responsibility and authority for Agency IT 

projects; 

 Description of the Data Flow Process The plan explains the key points in the 

information data flow and collection process. This can be illustrated by a flow 

chart, or diagram, depicting key information components; 

 Description of the Data Collection Methods The plan summarizes data 

measurement and collection methods. It also describes any emerging 

measurement technologies used, and/or how existing systems of environmental 

monitoring will be augmented/up-graded to provide the proposed data; 

 Description of the Data Storage and Retrieval System ADEQ’s standard 

relational database platform is Oracle. ADEQ utilizes Oracle tools, including 

Designer and Developer, for application development. ADEQ also uses 

Microsoft Project for planning and tracking projects to completion. The plan 

describes the hardware and software technologies that will be used for data 

management and processing systems. It specifies the components of the project 

architecture and also describes the archival components or storage requirements. 

The plan addresses data management responsibilities among stakeholders and 
40 

contractors to ensure data documentation and data standardization. 

6.3 ELECTRONIC DATA INTERCHANGE (EDI) AND NODE 

Arizona Department of Environmental Quality (ADEQ) collects and manages compliance, 

measurement, and statistical data for a number of environmental Programs within the State of 

Arizona. The data are managed and reported both internally and externally to other state and 

federal agencies. Typically, the electronic data interchange (EDI) is performed using rigid data 

formats that are difficult to maintain and managed using proprietary methods. The rigidity and 

closed nature of the interchange make it very difficult to add new data formats, communicate 

with new data partners, or improve the overall process. The purpose of ADEQ’s Node is to 

eliminate the proprietary exchange formats and more easily facilitate the exchange of 

information between the Environmental Protection Agency (EPA), and other participating 

organizations, by developing a Web Service based gateway that supports the EPA XML message 

formats. ADEQ currently has a fully compliant production Node, and has successfully 

exchanged data with EPA's Facility Registry System. Additional data flows are planned to 

exchange data with EPA's RCRA Info and AQS systems. In addition, the Node can be used 

internally and for non-EPA partner exchanges. 

6.4 LEVELS OF DOCUMENTATION FOR ENVIRONMENTAL PROJECTS 

Documentation is important because it helps users make informed decisions regarding the use of 

environmental data, provides consistency and IT project memory over time, and allows the data 

to be shared and used for a variety of purposes and in a variety of computing environments. 

ADEQ has developed the following four kinds of documentation requirements for environmental 

IT project data systems: 

1. Data System Documentation: Documents critical information about the IT 

project, including project purpose and scope, user requirements, IT PIJ, and the 

IT project plan; 

2. Data Set Documentation: Provides clear information about what data are 

collected and how to access and use them; 

3. Data Element Documentation: Provides full definitions and specifications for 

each element collected and maintained in a data set; 

4. Database System Documentation: Describes electronic and hard copy 

documentation of system design and implementation. 

6.5 COMPUTER HARDWARE/SOFTWARE REQUIREMENTS 

ADEQ managers and staff will comply with all ADEQ hardware and software standards, which 

are maintained by the Office of Information and Technology. These standards address 

compatibility, hardware, operating systems, communication, database management, user and 

printer interface, application development, and applications. 
41 

ADEQ will procure hardware and software that conforms to Agency wide and EPA information 

management architecture. In some cases, ADEQ will procure and configure hardware, or 

develop application software through vendors that are not on the statewide contract. All such 

purchases will be evaluated to ensure that they comply with ADEQ standards as outlined in the 

Agency’s software and hardware standards. Prior to any purchases, ADEQ’s Chief Information 

Officer, or designee, will evaluate software and hardware to determine their performance 

capabilities, impact of implementation upon ADEQ, and its compatibility with EPA reporting 

requirements. 

6.6 SYSTEM DEVELOPMENT 

All ADEQ system development, enhancement, and modernization efforts will comply with 

Agency standards. The standards include a systematic and comprehensive dialogue between the 

data providers, data/system users, and system developers. The majority of the dialogue occurs 

prior to the design of the system in order to ensure extensive and successful user participation, 

and a systematic approach to the design. Systems will be designed and built to integrate with 

core Agency data in such a manner that re-use of code, and its associated cost savings, is 

maximized. 

All software systems shall be operated and maintained in accordance with written specifications 

and/or the owner’s manual. All software systems will be subjected to acceptance testing by end 

users prior to being placed into a production environment. 

For the proper implementation and maintenance of the technology infrastructure, ADEQ’s Office 

of Information and Technology: 

 Maintains an inventory of the computer system(s) hardware and written operating 

procedures for routine maintenance operations; 

 Documents data management systems in use, including functional and design 

specifications and requirements; 

 Maintains Standard Operating Procedures which describe routine operation, 

maintenance, and testing to ensure that both the hardware and software in use are 

accurately performing their intended functions. 

These documents will be readily available in the areas where these procedures will be performed. 

Changes in any part of the operating procedures shall be properly authorized, reviewed, and 

accepted in writing by the designated responsible person. 

6.7 DATA STANDARDS 

To take full advantage of both ADEQ’s and EPA’s growing technology, data standards, and 

resources, there must be an increased emphasis on improving the compatibility of data among 

computer systems. In addition to the policies and standards contained in the CFR, federal data 

policies and standards that are currently followed, including those which ADEQ is attempting to 

implement, include: 
42 

 Chemical Abstract Service Registry Number Data Standard, EPA Order 2180.1, 

June 26, 1987; 

 Data Standards for the Electronic Transmission of Laboratory Measurement 

Results, EPA Order 2180.2, December 10, 1987; 

 The Minimum Set of Data Elements for Ground Water Quality, Policy Order 

74500.IA, September 11, 1989; 

 Facility Identification Data Standard, U.S. EPA Office of Administration and 

Resources Management, Information Management and Services Division, April 9, 

1990. 

 Policy on Electronic Reporting, U.S. EPA Office of Administration and 

Resources Management, July 30, 1990; 

 Site Location Identification Policy and Responsibilities, Region III, Order 5361.5, 

September 14, 1988; 

 ADEQ Locational Data Policy, 0034.001 (see Appendix J); 

 Locational Data Policy, IRM Policy Manual, Chapter 13, April 1991; and 

 Locational Data Policy Implementation Guidance- Guide to the Policy, U.S. EPA 

Office of Information and Resources Management, March, 1992. 

 Cross Media Electronic Reporting, Final Rule, October 13, 2005. 

6.8 INFORMATION SECURITY 

It is important that ADEQ information resources are protected from potential loss and misuse 

from a variety of accidental and deliberate causes. Failure to adequately protect database 

systems can affect the integrity of data, privacy of data sources, availability of data for use (e.g., 

for legal and enforcement purposes), and the very existence of data. ADEQ utilizes the 

following security procedures and protocols: 

 Network Operating Systems use log-in and password controls; 

 Internal rights to Agency data are granted by local management for their 

employees; 

 Maintaining a “chain-of-custody” for any data value created or changed in a 

database; 

 A firewall security system for Internet usage; 

 Remote access controls for employees and third parties include the use of log-in 

and password protection; 

 All UNIX, NetWare, and Remote Access Operating Systems comply with DOD 

C2 security standards; 

 The main computer room is physically secured to limit access to only critical IT 

personnel. 
43 

CHAPTER 7 PLANNING 

A primary goal of ADEQ’s Quality Management System is to promote effective planning for the 

collection, analyses, and processing of environmental data. Quality planning must occur at three 

levels to ensure that such data meet ADEQ’s programmatic quality goals. The three levels are: 

 Agency wide Requirements; 

 Program Specific Requirements; 

 Project Level Requirements. 

7.1 AGENCYWIDE PLANNING 

7.1.1 Internal Strategic Planning 

The ADEQ Strategic Plan is the foundation upon which all Programmatic priorities, and 

corresponding environmentally related data collection and use activities, are based. Using the 

projected annual budget for ADEQ from the various funding sources including EPA and the 

State of Arizona, ADEQ’s Director and senior managers meet each fiscal year to discuss and set 

ADEQ priorities. These priorities are then reflected in ADEQ’s Strategic Planning process, 

which establishes overall goals, direction, resource utilization, policies, and budget allocations. 

Yearly action plans, developed by each ADEQ Division, are tied to ADEQ’s Strategic Plan and 

budget allocation process. Action plans further specify the types of environmentally-related data 

generation activities that will occur. The yearly action plans also delineate what decisions they 

are designed to support and the corresponding requirements for quality assurance and quality 

control procedures. 

7.1.2 Eternal Strategic Planning 

Close coordination and planning across organizations is essential to ensure that data are of 

sufficient quality to support decision-makers, or otherwise meet their intended use. Data Quality 

Objectives (DQOs) and other planning tools can be shared across Programs sites and 

governmental agencies, and private organizations, where appropriate. 

7.1.3 External Data Coordination 

Once the data have been collected, ADEQ must also coordinate the use of environmentally 

related data across numerous government agencies, academic, and private organizations. ADEQ 

encourages data sharing whenever possible. However, data sharing is only done when adequate 

data quality indicators (DQIs) are available so that the quality of data is sufficiently known to 

support the applicable decision(s). 
44 

7.2 PROGRAM-SPECIFIC PLANNING 

ADEQ Programs are functional areas of work authorized by Statutory reference (e.g., National 

Ambient Air Quality Standards (NAAQS)or Drinking Water Program) or by Agency direction 

(e.g. the Voluntary Remediation Program). Any of ADEQ’s environmental Programs which 

generate environmental data are covered by the QMP, though it is acknowledged that not every 

Program or project requires the same level of quality assurance. Generally, Program managers 

(their grades and titles vary by Division) are responsible for Program level planning, which 

includes the responsibility to ensure that there is agreement between the customer and the data 

supplier as to expected data quality. 

Establishing Data Quality Objectives (DQOs) when initiating a new project, or incorporating 

major statutory changes, is a mandatory component of the ADEQ Quality Management System. 

The EPA Quality Assurance Division guidance document, Guidance for the Data Quality 

Objectives Process, EPA QA/G-4 is available to assist users in developing these objectives, as 

are other resources within the ADEQ QA/QC Unit when the formal DQO processes is necessary. 

Predetermined DQO’s based on regulatory criteria and action levels within similar Programs are 

often available, and thus a formal DQO process is not necessary. DQOs at the project level may 

address sources of error (i.e., sampling design and site variability) that will accumulate and affect 

the interpretation of data for status and trends. Program-level DQOs have the ability to meet 

Division Program objectives. Data Quality Objectives are also used as performance criteria for 

assessments of data quality for their adequacy in determining status and trends. 

It is critical to consider the QMP during the planning process when modifying existing, or 

designing new, Programs. Although the QMP outlines the minimum QA requirements for 

ADEQ, it is likely that most of the Programs covered by the QMP will need more QA specificity 

when implementing their Programs. In these cases, supplemental QA components and 

procedures are developed and described by the Program. If requested, the ADEQ QA/QC Unit 

will serve as technical advisors in the development of these components and procedures. All 

Programs covered by the QMP should review their programmatic requirements each year to 

determine if the QMP adequately covers their QA needs, and if not, incorporate supplemental 

procedures into the Program Plans 

7.3 PROJECT-LEVEL PLANNING 

A project is an organized set of activities within a Program. The Quality Assurance Project Plan 

(QAPjP) is the primary vehicle for ensuring that there is adequate data quality at the project level 

(see Chapter 2, Section 2.2 for a more complete discussion of the QAPjP development and 

review process.) The ADEQ QMP refers to QA activities as a well-defined component of any 

project plan involving the collection or use of environmental data. 

The key to good quality planning at this level is to link the data collection, or analyses, to be 

performed directly to the environmental decision to be made. This is essential so that ADEQ 

does not collect mounds of data for which there is no purpose. Achieving this key component 

requires dialogue between the decision maker, contractor, and the data supplier. Again, the EPA 
45 

Quality Assurance Division (QAD) document EPA QA/G-4, Guidance for the Data Quality 

Objective Process March, 2006, as well as resources within the ADEQ QA/QC Unit, can be 

invaluable in establishing the desired data certainty requirements based on the decision to be 

made. The use of statistical methods to quantify data acceptability measures is highly 

recommended. Members of the QA Team in EPA Region IX can provide assistance with 

statistical applications. The ADEQ QA/QC Unit can assist ADEQ Programs by providing the 

appropriate references. 

Planning documentation identifies ADEQ’s personnel responsible for ensuring that all 

components of a QAPjP are addressed appropriately. Project/Case Managers will normally be 

responsible for the development of these QA components, which will adhere to the requirements 

of EPA QA/R-5, EPA Requirements for QA Project Plans. March, 2001. QAPjPs are reviewed 

to ensure that all the required EPA and ADEQ elements are appropriately addressed. The review 

process is conducted by the Division QA Representative, or appropriate designee, and must be 

approved by appropriate delegated autonomous Division personnel or by the QA/QC Unit. 

When initiating a site-specific project, a preliminary plan is developed for accomplishing the 

required work. Through this process, specific individuals are made accountable for different 

aspects of the investigation. 

The ADEQ planning process considerations include:

 Identifying the regulations involved; 

 Defining the forensic requirements of the regulations; 

 Defining DQOs 

 Defining MQOs 

 Structuring communication between all the parties involved in the project; 

 Defining the scope of the project to meet enforcement objectives; 

 Identifying and scheduling activities; 

 Identifying resources needed; 

 Identifying health and safety issues; 

 Questioning the validity of scientific models and methods proposed for use. 

7.3.1 On-Site Monitoring 

The determination to use on-site monitoring, and the specific type of monitoring to be conducted, 

is based upon the project objectives as defined by the QAPjP. Field screening information, 

combined with statistics, can be used to define the number and type of samples needed to meet 

the project objectives. 

Monitoring for personal protection may include using a specific instrument to screen the work 

area to determine the appropriate level of personal protection needed. These instruments can 

also be used for continuous monitoring while work is being performed. 
46 

Quality control indicators used in on-site monitoring depend on the applicable regulations, the 

type of equipment, the nature of the materials monitored, and the monitoring objectives. Quality 

control parameters such as blanks, blank spikes, matrix spikes, field duplicates, surrogates, and 

calibration curve data (all QC parameters as they apply) shall be documented. 

7.3.2 Sampling Events 

The sampling activity shall be focused toward meeting the regulatory, technical, and analytical 

requirements defined during the planning phase. ADEQ sample collection activities are 

designed to answer questions such as: 

 How do the media compare to a regulatory threshold? 

 How do the media compare to other site media? 

 Is a specific component or condition present? 

 Are there trends or hot spots? 

The sampling activity requires: 

 Coordinating field activities with laboratory activities; 

 Maintaining sample integrity; 

 Focusing on regulatory and Agency defined data quality requirements. 

7.3.2.1 Sample Scheduling 

Communication with the laboratory prior to sampling is critical in achieving the stated Data 

Quality Objectives. Some sample events are unique and one time events, while others are 

routine and ongoing. Regardless, all laboratory sample scheduling events need to be coordinated 

with the laboratories, at a minimum, several days prior to sampling. Communications should 

include, time frames, methods, matrix types, required detection limits, and where appropriate, the 

purpose for testing to ensure the requirements of Federal or State statutes under which ADEQ 

intends to regulate are fulfilled. The QA/QC Unit can facilitate finding appropriate laboratories, 

ensuring that DQOs and MQOs can be met, and that the laboratory meet minimum ADEQ 

Quality Control requirements. 

7.4 ANALYTICAL REQUIREMENTS 

Analysis involves the characterization of samples based on chemical and/or physical properties. 

Analyses result in generating raw data from either instrumental analysis, chemical analysis, or 

physical testing. The analytical methods used will be specific, sensitive enough to answer the 

question posed by the Program objectives, and meet the data quality goals associated with those 

objectives. 
47 

Measurement Quality Objectives (MQOs) are the project or program QC criteria defined for 

various Data Quality Indicators (DQIs). During the planning phase, these set pre-determined 

limits on the acceptability of the data in regards to accuracy /bias, and precision, completeness 

and sensitivity. 

ADEQ Project/Case Managers may consult with the ADEQ QA/QC Unit, or research a variety 

of published or written materials, to aid them in selecting or developing measurement 

technologies. The ADEQ QA/QC Unit shall maintain a file of in-house procedures and practices 

used in the measurement process. Data Quality Objectives (DQOs), and ADEQ QA/QC Unit’s 

professional knowledge, are used to identify appropriate analytical procedures. 

DQI’s, as defined by EPA involve precision, accuracy, representativeness, completeness, 

comparability, and sensitivity, also known as “PARCC” parameters. It is expected that these 

indicators be used in data evaluation, but in general, the criteria by which DQIs are evaluated are 

based on project data quality needs, ie, the MQOs.. The extent to which theses indicators will be 

utilized should be provided in a Program’s QAPrP. The extent to which program or project QC 

results meets MQOs determines whether data are acceptable for the intended use. 

7.5 DATA TRANSLATION 

Data translation involves translating raw data into useable information which can include 

qualitative identifications, quantitative determinations, and/or statements of condition. This 

process can include arithmetic calculations, and/or statistical evaluations, of results from a 

sample or collection of samples. 

7.6 DATA INTERPRETATION 

The ADEQ Project/Case Manager will attempt to use sample data to form an opinion about the 

characteristics of a data set. The ADEQ Project/Case Manager will use quality control 

information to support conclusions or to identify limitations of the data. The ADEQ QA/QC 

Unit will be available to assist the ADEQ Project/Case Manager in assessing QC data when 

actions have regulatory implications. For compliance testing, the acceptable data (ie, data that 

meets the MQOs) will define the characteristics of the data set that will then be compared to 

regulatory requirements to determine compliance. 

7.7 HEALTH AND SAFETY 

Health and safety are an integral part of the ADEQ Quality Management System, because the 

management philosophy is that a safe workplace is essential for the long term success of the 

Quality Management System. ADEQ Management, with the assistance of the ADEQ Health and 

Safety Committee, has developed policies and procedures focused toward a safe working 

environment, and developed a Program that is adequate to protect the health and safety of ADEQ 

staff. The ADEQ Health and Safety procedures implement applicable EPA and Office of Safety 

and Health Administration regulations. The ADEQ Safety Committee conducts or contracts for 

specialized training Programs to meet the safety needs of ADEQ measurement activities. 
48 

The ADEQ Health and Safety Environmental Management Program is the mechanism which 

ensures that appropriate issues are considered prior to the initiation of measurement activities. 

The ADEQ Health and Safety Environmental Management Program includes the following three 

key elements: 

1. Training - Includes field and laboratory safety, first aid and CPR, supervisory 

safety, hazardous waste, and other pertinent training; 

2. Audits, Inspections, Investigations, and Hazard Control - Includes planning 

reviews, associated reporting, and record keeping to identify, prevent, and/or 

abate health and safety problems; 

3. Occupational Medical Monitoring - Includes medical monitoring of staff who 

may be exposed to chemical, biological, radiological, or other agents, or who may 

experience physical stress during their work. 
49 

CHAPTER 8 IMPLEMENTATION OF QUALITY ASSURANCE 

WORK PROCESSES 

This Chapter of the QMP describes the processes used at ADEQ for facilitating the effective 

implementation of QA plans and procedures which comprise ADEQ’s Quality System. Any 

changes to the QMP will be documented in revisions and will receive, at least, Agency Director 

level approval. As with the QA planning described in Chapter 7, implementation of QA 

procedures takes place at the Agency, Program, and project levels. 

8.1 AGENCYWIDE IMPLEMENTATION 

ADEQ utilizes a tiered approach to ensure that environmental data are of sufficient quantity, and 

quality, for their intended purpose. Any revisions to the QMP will be processed in the same 

manner as was the original document. QMP revisions will be drafted by the ADEQ QA/QC 

Unit, and submitted to the QA/QC Steering Committee for comment, with final approval by 

ADEQ’s Leadership Team. The ADEQ QA/QC Unit Supervisor, teamed with the QA/QC 

Steering Committee, will provide general oversight of implementation of the ADEQ Quality 

Management System and identify needs for revisions to the QMP. The ADEQ Programs will 

provide technical oversight for implementing environmental data operations through the 

development of Quality Assurance Program Plans (QAPrPs). 

8.1.1 Divisional Quality Assurance Program Plans

QAPrPs will be developed within the individual Programs. When requested, ADEQ’s QA/QC 

Unit will assist in development and implementation of environmental data operations according 

to approved planning documents. Additionally, each QAPrP needs to identify those specific 

activities that will ensure the generation of quality data by: 

 Defining commonalities in operations, methods, and procedures used throughout 

the Program; 

 Covering elements of Program management, data generation and acquisition, 

assessment and oversight, and data validation and usability; 

 Describing the level or degree of the Program quality system, and the different 

types of QA documents used by the Program, focusing on those elements that are 

not time or site specific; 

 Identifying those responsible and describing the procedures for Program QA 

document preparation, review, and approval; 

 Discussing data quality objectives including the identification of Program wide 

technical or regulatory criteria; 

 Attaching reference and supporting documents used throughout the Program, such 

as SOPs and regulatory lists. 

Each ADEQ QAPrP should be reviewed on an annual basis, and at minimum, revised every five 

years or when significant changes in the business operation occur, to ensure that the plans 
50 

accurately reflect how business within the Program is conducted. It is essential that the 

workflow outlined in the QAPrP is consistent with actual business conducted. The Programs 

will provide a copy of their QAPrP to the QA/QC Unit and also to EPA Region IX for EPA 

Funded programs, for approval, general oversight, and management of the Agency wide Quality 

System. 

8.2 PROGRAM LEVEL IMPLEMENTATION 

8.2.1 Operating Policies and Procedures 

Any ADEQ Program which generates, or uses, environmental data will document its QA policies 

and procedures, and will develop and/or use appropriate policy and procedure manuals for its 

Programs. The ADEQ QA/QC Unit will provide support and oversight in the generation of such 

documents. The EPA Quality Staff issues documents to provide information on satisfying 

Federal Regulations, for example, Guidance for Preparing Standard Operating Procedures, 

March, 2001 (QA-G6), this document should be referenced by ADEQ Programs when 

developing procedure manuals for administrative and technical QA operations. Implementation 

of these procedures will enable Program personnel to gain and document procedural knowledge 

about their operations, and will also serve as a training guide for new staff members. 

The ADEQ QA/QC Unit Supervisor will work with the ADEQ Programs to ensure that 

operational QA policies and procedures developed by the Programs are consistent with the 

ADEQ QMP. This responsibility includes defining procedures for appropriate routine, 

standardized, special, or critical operations, including the policies and procedures that address, 

but are not limited to: 

 The identification of operations needing standardized procedures; 

 The process for preparation of procedures, including form, content, and 

applicability; 

 Determination of SOP adequacy, and consequent review and approval. 

Any QA procedure manuals developed by the ADEQ QA/QC Unit will be made available to all 

personnel involved in Program implementation. If implementation of the Program is delegated 

or outsourced, these QA procedural manuals will be referenced in the Task/Work Assignment, 

Task/Delivery Order, or similar document consistent with the ADEQ Procurement process. A 

Program using data generated by external sources must develop criteria and a process by which 

to evaluate the acceptability of the data supplied. The data quality assessment process described 

in Chapter 9.4 can be useful here. 

8.3 PROJECT LEVEL IMPLEMENTATION 

8.3.1 Quality Assurance Project Plan Implementation 

All environmental data operations will be implemented in accordance with an approved QAPjP 

or QAPrP. The ADEQ Project/Case Manager should include identifiable QA milestones, and 
51 

target dates, in the project timeline so that progress and completion of QA and QC activities can 

be effectively tracked. Any changes to the QAPjP will be documented as soon as possible in 

writing with an amendment to the QAPjP. Amendments will be reviewed and approved by the 

ADEQ Project/Case Manager. It is critical to have a quick and efficient system for any QAPjP 

changes so the plan can be accurately used for its intended purpose, as a reference and guide 

throughout the project. 

8.3.2 Standard Operating Procedures (SOPs) 

Many repetitive procedures that are routinely used can be standardized and documented in 

writing as SOPs. SOPs can be prepared for routinely conducted sampling, analytical, and quality 

control procedures. Once established, the SOPs can be cited in the QAPjPs, contract proposals, 

grant agreements, and other similar documents, thus saving time and paper by avoiding the need 

to write out the specific procedures in each document. ADEQ SOPs relating to QA shall be 

maintained by the appropriate Program office with technical support provided by the QA/QC 

Unit, as appropriate. SOPs common to Programs can be found as attachments with URLs to their 

corresponding QAPrP. Tasks or functions that may be effectively addressed within a SOP 

include: 

 Sampling network design; 

 Sampling site selection; 

 Sampling and analytical procedures; 

 Sample collection methods and devices, containers, preservatives, holding times, 

handling and transportation methods; 

 Documentation and chain-of-custody procedures; 

 Calibration and maintenance of instruments and equipment; 

 Quality control procedures; 

 Data review, reduction, and validation; 

 Safety procedures; 

 Inspection and audit procedures. 

ADEQ has established the following policies, procedures, and/or guidance for sample collection 

and analytical techniques. These procedures, where relevant, apply to all analytical data being 

generated for use by ADEQ. These procedures should be followed unless special exceptions 

have been requested and approved, and/or deviations are outlined in a Program’s QAPrP. These 

documents can be found in their entirety as attachments to this QMP. 

 ADEQ Temperature/Preservation Guidance Policy; 

 Substantive Policy 0154 Addressing Spike And Surrogate Recovery As They 

Relate To Matrix Effects In Water, Air, Sludge And Soil Matrices Policy; 

 Substantive Policy 0170 Implementation Of EPA Method 5035 - Soil Preparation 

For EPA Method 8015B, 8021B and 8260B; 
52 

 Arizona Data Qualifiers. 

The Arizona Data Qualifiers are revised periodically with the consensus of the Arizona 

Environmental Laboratory Advisory Committee (ELAC). The most up to date version should be 

used when applying qualifiers to data and can be found on the ADHS and ADEQ websites. 
53 

CHAPTER 9 QUALITY ASSESSMENT AND RESPONSE 

This Chapter of the QMP describes how ADEQ will assess the effectiveness of its Quality 

Management System. ADEQ will use a variety of internal management and technical reviews, 

performance evaluations, and QA audits to ensure that the procedures in this QMP are 

implemented successfully. ADEQ will also utilize, as needed, independent reviews of the 

systems and procedures described in ADEQ’s QMP by personnel from the EPA Region IX 

Quality Assurance Office. This chapter will also describe ADEQ’s commitment to using the 

results of these evaluations to make any necessary operational adjustments to ADEQ’s data 

collection and analytical procedures, as well as to other aspects of the Quality Management 

System. 

9.1 ANNUAL REVIEW OF THE QUALITY MANAGEMENT PLAN 

The QA practices and procedures described in the QMP will be assessed annually, and revised or 

updated by October 1 of each year by the ADEQ QA Steering Committee. As an integral part of 

the QA Steering Committee, ADEQ’s QA/QC Unit Supervisor is responsible for coordinating 

this assessment, arranging meetings of the QA Steering Committee to assist with the review, and 

for incorporating any recommended changes into the QMP. Minor changes in the QMP 

proposed by the ADEQ Programs should be submitted in writing to the ADEQ QA/QC Unit 

Supervisor by June 30th of each year. After approval by the QA/QC Steering committee, the 

QMP will be turned over to the Leadership Team for updated signatures. A copy, for record 

keeping, will be sent to EPA Region IX. 

A major rewrite will take place every five years with approvals needed by ADEQ’s QA/QC 

Steering Committee, ADEQ’s Leadership Team, and final approval by EPA Region IX. 

9.2 QUALITY AUDITS 

ADEQ employs several QA assessment tools designed to provide a better understanding of the 

components of, and basis for improving, the ADEQ Quality Management System. Internal 

(programmatic) and External QA audits are one of the principal tools for determining the 

effectiveness of the ADEQ QA/QC components. QA audit frequency and scheduling will vary 

with the type of review conducted. Specifics of frequency and type of review will be outlined in 

the individual Program QAPrPs. The following is a description of some of the evaluation tools: 

9.2.1 Management System Reviews (MSRs) 

An MSR is an independent assessment of a Program’s QA management practices and data 

collection procedures, and is generally performed by the ADEQ QA/QC Unit with oversight 

privileges from the QA Steering Committee. The MSR will qualitatively assess a Program to 

determine if the ADEQ Quality Management System is adequate to ensure the quality of the 

Program’s data. MSRs address the effectiveness of management controls in achieving and 

assuring data quality, the adequacy of resources and personnel devoted to QA functions, the 

effectiveness of training and assessments, and the applicability of data quality requirements. 
54 

While MSRs can identify significant QA concerns and areas of needed improvement, they also 

point out noteworthy accomplishments. 

ADEQ Program MSRs are generally conducted by an external party (typically the ADEQ 

QA/QC Unit) and focus on the Program's adherence to the approved Agency QMP, its Quality 

Assurance Program Plan, as well as the implementation of QA practices within a single Program 

area. The ADEQ QA/QC Unit will attempt to conduct an MSR for every major Agency Program 

(including the Northern and Southern Regional Offices) once every four years. The ADEQ 

QA/QC Unit’s MSRs focus on the overall structure and procedures for accomplishing the QA 

Program. 

Most MSRs will examine the following elements: 

 An assessment of the overall effectiveness of the QA management system, as 

measured by its adherence to the approved QMP; 

 Procedures for developing Data Quality Objectives (DQOs); 

 Procedures for developing and approving QAPrPs and QAPjPs; 

 The effectiveness of existing QAPrP guidance and QAPjPs; 

 Procedures for developing and approving SOPs; 

 Procedures, criteria, and schedules for conducting QA audits; 

 Tracking systems for assuring that the QA Program is operating effectively, and 

that corrective actions disclosed by QA audits have been taken; 

 Responsibilities and authorities of various line managers, and QA personnel, for 

implementing the QA Program; 

 The degree of management support; 

 The level of financial and other resources committed to implementing the QA 

Program. 

MSRs performed or arranged by the ADEQ QA/QC Unit will be conducted in accordance with 

the Guidance on Assessing Quality Systems, March, 2003, EPA QA/G-3. ADEQ may also make 

occasional use of independent, outside reviews of its quality assurance practices. When electing 

to use an outside source, the ADEQ QA/QC Unit Supervisor, in consultation with the QA 

Steering Committee and Division Director, will make arrangements for such a review by 

selecting an appropriate team of qualified reviewers (e.g. EPA Region IX). The goals and 

objectives of this type of review will be the same as if the assessment were conducted internally. 

EPA QA Office has the authority and may, from time to time, audit ADEQ’s Quality System as 

part of its oversight responsibilities. 

All MSRs will result in the production of a written report. A draft of this report is due within 30 

days of the completion of the observation phase of the audit. The draft will be sent for 

comments to the Program’s senior management. Comments must be supplied by the Program’s 
55 

senior management within 30 days of the receipt of the draft. Final reports are to be completed 

within 30 days of receipt of comments by the Program’s senior management 

9.2.1.1 Review ADEQ Quality Assurance Programs 

ADEQ’s QA/QC Unit, with oversight privileges from the QA Steering Committee, will conduct 

internal assessments of the individual ADEQ Quality Assurance Programs as described in the 

Agency QMP. All major data generating Programs within ADEQ will be reviewed every four 

years. These Programs include those listed in Chapter 1 of this document. These reviews will be 

authorized by the ADEQ Director and the results of the evaluations will be transmitted to the 

ADEQ Division Director, in a written memorandum, from the ADEQ QA Steering Committee. 

The reviews are intended to accomplish the following objectives: 

 Identify any data quality problems; 

 Identify benchmark practices that could be used in other Agency Programs; 

 Propose recommendations for resolving quality problems; 

 Confirm implementation and effectiveness of any recommended corrective 

actions. 

The reviewed Program will have 30 days to prepare a written response to the reviewer’s 

memorandum. If the evaluation report recommends corrective actions, the reviewed Program 

should address these recommendations and include a schedule for making any appropriate 

changes in its quality assurance procedures. These reviews will be used by the ADEQ 

Leadership team to gauge the effectiveness of the Agency QMP and of the Programs’ approaches 

to data quality management. 

9.2.2 Technical Systems Audits (TSAs) 

A Technical Systems Audit is conducted to assess the sampling and analytical quality control 

procedures used to generate environmental data. The ADEQ QA/QC Unit with oversight 

privileges from the QA Steering Committee will use TSAs to evaluate laboratory and field 

procedures used by EPA, state personnel, and contractors. TSAs entail a comprehensive, on-site 

evaluation of the field equipment; sampling and analyses procedures; documentation; data 

validation; and training procedures for collecting or processing environmental data. 

TSAs may be routinely planned by ADEQ’s QA/QC Unit, specifically requested by ADEQ’s 

Project/Case Manager, or result from the findings of another audit or review. ADEQ’s QA/QC 

Unit Supervisor is responsible for assembling the audit team. Results will be reported to the 

audited organization in the form of a written report within 14 calendar days of the completion of 

the audit, or a mutually agreed upon alternative. Written comments by ADEQ’s Project/Case 

Manager must be supplied to ADEQ’s QA/QC Unit within 14 calendar days of receipt of the 

audit findings, or a mutually agreed upon alternative. Copies of the TSA Audit Final Report will 

be stored in the project file and also with the ADEQ’s QA/QC Unit. Additional copies will be 

distributed as appropriate. 

Both laboratory and field TSAs may be performed. 
56 

9.2.2.1 Laboratory TSAs 

TSAs will be conducted on the Arizona Department of Health Services State Laboratory, ADEQ 

contract laboratories, and contract laboratories of consultants and contractors who submit 

analytical data to ADEQ. TSAs may be conducted on other Federal agency laboratories that 

perform sample analysis under Interagency Agreements with ADEQ. The primary goals of 

TSAs will be to review the laboratory organization, operation, and capabilities; determine the 

reliability of data; and note corrective action for any apparent deficiencies. Auditors for TSAs 

will be selected by the ADEQ QA Steering Committee based on their technical proficiency in the 

subject area. The designated auditors will be responsible for planning and conducting the audit, 

and reporting the findings to the laboratory manager and to the ADEQ QA Steering Committee. 

9.2.2.2 Field TSAs 

Oversight of field operations is an important part of the quality assurance process, and the ADEQ 

QA/QC Unit, with oversight privileges from the QA Steering Committee, will conduct QA 

audits of field sampling activities, both for its own field operations, and on those contractors and 

other federal agencies that collect samples for Programs sponsored by EPA. ADEQ will specify 

frequency and procedures for conducting field TSAs within specific Program areas. When 

QAPjPs are reviewed, and also during any MSRs or other QA audits, the ADEQ QA/QC Unit 

Supervisor will determine the necessity of field TSAs. 

9.3 PERFORMANCE EVALUATIONS 

Performance Evaluations (PEs) Samples are used to assess the ability of a laboratory, or field 

measurement system, to provide reliable data. PEs samples will be considered for laboratories 

providing analytical services, directly or indirectly, for ADEQ and will be traceable, whenever 

possible, through the National Institute of Standards and Technology (NIST). The evaluation 

consists of providing a reference, "blind" or “double blind” sample, to the laboratory for analysis. 

A PE sample contains known concentrations of chemical constituents, or pollutants, of interest 

and will normally be in the appropriate media (e.g., soil, water, air). The analytical results 

obtained by the laboratory are compared to the known concentrations of the chemical 

constituents contained in the PE sample(s), as a means of determining if the laboratory 

demonstrated its ability to properly identify, and quantify, pollutants within established, or 

calculated, control limits. 

PE samples will be scheduled at a frequency specified by Program requirements, or on an asneeded basis depending on the laboratory and Program involved. Some national Programs, such 

as the Public Water Supply Supervision (PWSS) and National Pollutant Discharge Elimination 

System (NPDES) Programs, have regularly-scheduled PE studies in which participation is 

mandatory for designated laboratories. For the PWSS Program, PE evaluations are required 

twice a year for all laboratories who wish to be certified for drinking water analysis. In addition, 

PE samples of specific parameters may be obtained from the appropriate EPA Office of Research 

Development laboratory or prepared commercially. 
57 

All PE studies performed for ADEQ, whether required on a regular basis or performed on a one 

time basis, will be coordinated through or requested from the ADEQ QA/QC Unit or designee. 

For external projects requiring PEs, the Task/Work Assignment, Task/Delivery Order, or similar 

document needs to outline the specific details of the Performance Evaluation so the associated 

costs can be included in the contractor proposal. The results of PEs provide a means for 

assessing overall data integrity, and may be used as criteria for selecting candidates for on-site 

evaluations. 

9.4 DATA QUALITY EVALUATIONS 

Data quality requirements and evaluation methods are addressed in the ADEQ QMP and also in 

specific QAPjPs. The QMP describes the methods by which data quality evaluations will be 

conducted and utilized, and how these evaluations relate to Data Quality Objectives. 

9.4.1 Data Quality Assessments (DQAs) 

A Data Quality Assessment (DQA) refers to the process used to determine whether the quality of 

a given data set is adequate for its intended use. DQAs can be performed on all, or selected 

projects and/or data generation processes. The purpose of this type of evaluation is to determine 

whether the data collected are acceptable to the decision-maker or end user. Assessments 

generally take place at one of two points in the data generation process. First, as data are 

generated, aspects of the project such as surveillance of field and laboratory operations, 

consistency of the data with MQOs, successfully completing performance evaluation sample 

studies, and so forth, can be used to arrive as an assessment of whether the data are valid and 

acceptable. Rejected or questionable data cannot be used by ADEQ in its decision making, 

except in limited circumstances, such as a rough site screening. 

Once data have been examined and assessed, and they are found to be of known and acceptable 

quality, then the results can be evaluated in the context of the Data Quality Objectives for the 

project. In some, but all, cases, this may involve a statistical evaluation such as null hypothesis 

testing. In others in may involve a comparison to regulatory action levels. An assessment must 

also be made as to whether there is a sufficient quantity of data to support program or project 

decisions, and whether the original sampling design was appropriate. In some cases, the data 

may suggest that additional data are required to achieve a higher statistical confidence level. 

This could be because too many data points were invalidated, that samples were not collected 

over a long enough time period, or that a vital sampling area not previously considered 

important, was missed. In other cases, an assessment might show that data of a different type are 

required, or that the sensitivity of the instrument used in the measurement was not adequate to 

meet project objectives. Thus, both types of assessments are vital to the successful completion 

of a project. 

If necessary, ADEQ’s QA/QC Unit can review data generated by the ADHS State Laboratory, 

and by contract laboratories, for the various ADEQ Programs. These data review activities use 

checklists, standard operating procedures, and standardized qualification codes to indicate data 

quality. The use of checklists and SOPs help standardize the data review process. The extent 
58 

and level of verification for individual data sets should clearly be defined in the Program’s 

QAPrP and/or QAPjP. 

9.4.2 Data Quality Audits 

A related evaluation tool involving data review and assessment is the data quality audit which is 

used to evaluate the documentation of the quality of data generated for a given project. This 

assessment primarily involves an evaluation of the completeness of the documentation of field 

and analytical procedures and quality control results, and usually involves tracing the paper trail 

accompanying the data from sample collection and custody to analytical results and entry into a 

database. This technique is commonly used to verify the process involved in entering data 

residing in large regulatory databases. 

Results of both DQAs and data quality audits can be used in a number of ways. First, they can 

be used in making recommendations for changes in the design and performance of data 

collection efforts, and in the use and documentation of QC procedures. Secondly, they can be 

used as a guide for the planning and acquisition of supplemental data for the project and 

potentially for other related projects. Problems identified through DQAs may trigger the need 

for an MSR to determine management deficiencies, or a TSA to identify technical problems. 
59 

CHAPTER 10 QUALITY IMPROVEMENT 

The ADEQ Leadership Team actively supports quality improvement by encouraging the ADEQ 

staff to: 

 Continually evaluate the effectiveness of current policies, procedures, and 

practices via discussions of the QA/QC Steering committee and subsequent 

leadership review; 

 Apply innovative approaches while maintaining integrity and accuracy. Conduct 

regular management reviews to define and celebrate success while recognizing 

and eliminating undesirable processes or results. 

The above goals are achieved by continually committing resources to the Agency’s quality 

management efforts. Peer review and performance audits will enable the constant evaluation of 

ADEQ Programs, projects, and individual staff performance. The ADEQ Quality Management 

System is designed to identify opportunities for improving the measurement process. 

Improvement can take the form of preventing quality problems from occurring by adjusting 

current work processes, or by seeking out better ways to do the work. The ADEQ Integrated 

Quality Management process seeks to prevent quality problems from occurring, recognize 

challenges early, and celebrate success. 

Continual improvement is achieved through consistent evaluations of Program, project, and 

individual performances. Regular oversight allows ADEQ to reshape Program protocols to 

reflect changing methods or procedures. 

10.1 PROGRAM REVIEWS 

It is the responsibility of line management to assure staff participation in all Program reviews 

and to review annually all QA activities of their staff, to determine that SOPs are in place and to 

revise them if necessary, to ensure that QAPrPs are written and approved in advance of project 

start-up, and to ensure that data quality assessments are made. All deviations and discrepancies 

noted during any independent or self-assessment review will be corrected promptly. 

Recommendations for modifications to the QMP will be forwarded in writing to the ADEQ 

QA/QC Steering Committee for implementation and inclusion during regular review sessions, as 

described in section 9.2.1. 
60 

10.2 PROJECT REVIEWS 

It is the responsibility of Project/Case Managers to request project reviews and/or QA audits and 

to identify where improvements can be made. This process is started during the determination of 

data quality objectives and is finalized during the assessment of data quality. All corrective 

actions required during the life cycle of the project are to be filed in the official project file or 

with the project’s final report. Project team debriefing is a regular component of project closeout. 

All data collection and testing procedures are to be scrutinized for consistency within industry 

best practices. 

The evaluation can include the findings resulting from scientific scrutiny (new technologies) or 

analytical measurements. The team will prepare a written report of its findings, for Division 

Management and the Agency Leadership Team, along with recommendations for improvement. 

The Leadership Team may choose to solicit other recommendations for improvement from 

persons not directly involved with the project. The ADEQ Leadership Team will decide which 

recommendations to implement in future projects. 
61 

TERMS AND DEFINITIONS 

Acceptable Quality Level - a limit above which quality is considered satisfactory and below 

which it is not. In sampling inspection, the maximum percentage of defects or failures that can be 

considered satisfactory as an average. 

Accuracy - the degree of agreement between an observed value and an accepted reference value; 

a data quality indicator. 

Activity - an all-inclusive term describing a specific set of operations or related tasks to be 

performed, either serially or in parallel (e.g., research and development, field sampling, 

analytical operations, equipment fabrication), that in total result in a product or service. 

Assessment - the evaluation process used to measure the performance or effectiveness of a 

system and its elements. In this document, assessment is an all-inclusive term used to denote any 

of the following: audit, performance evaluation, management systems review, peer review, 

inspection or surveillance. 

Audit - a planned and documented investigative evaluation of an item or process to determine 

the adequacy and effectiveness, as well as compliance with established procedures, instructions, 

drawings, quality assurance project plans, and other applicable documents. 

Audit of Data Quality - a qualitative and quantitative evaluation of the documentation and 

procedures associated with environmental measurements to verify that the resulting data are of 

acceptable quality. 

Bias - the systematic or persistent distortion of a measurement process which causes errors in 

one direction; a data quality indicator. 

Characteristic - any property or attribute of a datum, item, process, or service that is distinct, 

describable, and measurable. 

Comparability - the degree to which different methods, data sets and/or decisions agree or can 

be represented as similar; a data quality indicator 

Completeness - the amount of valid data obtained compared to the planned amount, and usually 

expressed as a percentage; a data quality indicator. 

Computer Program - a sequence of instructions suitable for processing by a computer. 

Processing may include the use of an assembler, a compiler, an interpreter, or a translator to 

prepare the program for execution. A computer program may be stored on magnetic media, and 

be referred to as "software", or may be stored permanently on computer chips, and be referred to 

as "firmware". Computer programs covered by this document are those used for design analysis, 
62 

data acquisition, data reduction, data storage (data bases), operation or control, and data base or 

document control registers when used as the controlled source of quality information. 

Contractor - any organization or individual that contracts to furnish services or items or 

perform work. 

Corrective Action - measures taken to rectify conditions adverse to quality and, where 

necessary, to preclude their recurrence. 

Criteria - a standard on which judgment is based. 

Customer - any individual or organization for whom items or services are furnished or work 

performed in response to defined requirements and expectations. 

Data - facts or figures from which conclusions can be inferred. 

Data Base - a collection of integrated data that can be used for a variety of applications. 

Data of Known Quality - data are of known quality when the qualitative and quantitative 

components associated with their derivation are documented appropriately for their intended use 

and such documentation is verifiable and defensible. 

Data Quality Assessment (DQA) - a process for performing statistical analysis to determine 

whether the quality of a data set is adequate for its intended use. 

Data Quality Indicators - qualitative statistics and quantitative descriptors that are used to 

interpret the degree of acceptability or utility of data to the user. The principal data quality 

indicators are bias, precision, accuracy, comparability, completeness, representativeness, and 

sensitivity. 

Data Quality Objectives (DQOs) - qualitative and quantitative statements of the overall level of 

uncertainty that a decision-maker is willing to accept in results or decisions derived from 

environmental data. DQOs provide the statistical framework for planning and managing 

environmental data operations consistent with the data user's needs. 

Data Usability - the process of ensuring or determining whether the quality of the data produced 

meets the intended use of the data. 

Defensible - the ability to withstand any reasonable challenge related to the veracity of integrity 

of laboratory documents and derived data. 

Design Review - a documented evaluation by a team, including personnel other than the original 

designers, the responsible designers, the customer for the work or product being designed, and a 

quality assurance representative to determine if a proposed design will meet the established 

design criteria and perform as expected when implemented. 
63 

Electronic Data Deliverable (EDD) – an electronic file containing data sorted into specific 

fields for different data constituents. Designed to be uploaded into data bases for overall data 

management without additional manual input of data. 

Engineered Environmental Systems - an all-inclusive term used to describe pollution control 

devices and systems, waste treatment processes and storage facilities, and site remediation 

technologies and their components that may be utilized to remove pollutants or contaminants 

from the environment. Examples include wet scrubbers (air), soil washing (soil), granulated 

activated carbon unit (water), and filtration (air, water). Usually, this term will apply to 

hardware-based systems; however, it will also apply to methods or techniques used for pollutant 

reduction or containment of contamination to prevent further movement of the contaminants, 

such as capping, solidification or vitrification, and biological treatment. 

Environmental Conditions - the description of a physical medium (e.g., air, water, soil, 

sediment) or biological system expressed in terms of its physical, chemical, or biological 

characteristics. 

Environmental Data - any information or measurements resulting from field data collection 

activity, laboratory analyses or modeling involving the assessment of chemical, physical, or 

biological factors related to the environment, and that describe environmental processes or 

conditions, or the performance of engineered environmental systems. 

Environmental Data Operations - work performed to obtain, use, or report information 

pertaining to environmental processes and conditions. 

Environmental Monitoring - the process of measuring or collecting environmental data. 

Environmental Processes - manufactured or natural processes that produce discharges to or 

impact the ambient environment. 

Environmental Programs - generally considered a regulatory activity that results from the 

implementation of an act of Congress or other legislative body (e.g., a state). The duration of a 

Program is usually legally seven years, (subject to renewal by the legislative body at various 

intervals), and is effectively continuous. Measurements are usually the same from year to year 

and take place on a recurring basis, e.g., quarterly monitoring for water or air pollutants, site 

assessments for Superfund, etc. Although the locations, parameters, and nature of measurements 

may change, the overall goal, which is to compare data to a regulatory standard, is generally 

constant. The Clean Water Act, Resource Conservation and Recovery Act, Clean Air Act, etc. 

are examples of Programs, although not all data generation activities funded under these laws 

would necessarily be considered Program data if they fall into the project category (see below). 

A Program requires a QMP, describing its QA System, and usually a Program QAPP (QA 

Program Plan) to describe in detail the process by which Program data are obtained. In this 

document, an environmental Program also refers to functional areas of work performed by 

groups or teams of people within the ADEQ organization. 
64 

Environmental Project - is defined as a data gathering activity that usually is of a finite length. 

Project data quality objectives are established during the planning phase and an assessment is 

made at the completion to determine whether the data quality objectives were met. Projects may 

include monitoring, but the data collected are frequently not intended for the use in enforcement 

of a regulatory standard. A trial burn, testing a new technology, a one-time ecosystem assesment 

and a habitat inventory are but a few examples of environmental projects. An environmental 

project requires a Quality Assurance Project Plan (QAPjP). 

Environmentally Related Measurements - any measurement or information that describes 

environmental processes or conditions, or the performance of engineered environmental systems. 

Thus, environmental data include all chemical, physical, or biological measurements relating to 

the environment; however, it does not include demographic or financial data. In addition, 

environmental data includes both direct measurements of environmental conditions and data 

collected from other sources such as literature, industry surveys, computerized databases, 

historical data, and mathematical models. Data from such sources are often called secondary 

data. 

External Oversight - a term used to convey related activities performed for EPA by ADEQ; 

usually performed under contracts, grants, or cooperative agreements. Used in reference to 

Quality Assurance Project Plans and the Quality Management Plan. 

Financial Assistance - the process by which funds are provided by one organization (usually 

government) to another organization for the purpose of performing work or furnishing services 

or items. Financial assistance mechanisms include grants, cooperative agreements, and 

government interagency agreements. 

Graded Approach - the process of basing the level of application of managerial controls applied 

to an item or work according to the intended use of results and the degree of confidence needed 

in the quality of the results. 

Hazardous Waste - any waste material that satisfies the definition of "hazardous waste" as 

given in 40 CFR Part 261, "Identification and Listing of Hazardous Waste". 

Independent Assessment - an assessment performed by a qualified individual, group, or 

organization that is not a part of the organization directly performing and accountable for the 

work being assessed. 

Inspection - an examination or measurement of an item or activity to verify conformance to 

specific requirements. 

Internal Activities - a term used to describe the activities performed by ADEQ employees; 

usually used in relationship to Quality Assurance Project Plans, the QMP, contracts, or grants. 

Item - an all-inclusive term used in place of the following: appurtenance, facility, sample 

assembly, component, equipment, material, module, part, product, structure, subassembly, 

subsystem, system, unit, documented concepts, or data. 
65 

Leadership Team - that group of ADEQ Management assembled and under the direction of the 

ADEQ Director. The Leadership Team consists of the following members: ADEQ Director; 

ADEQ Deputy Director; Waste, Water, Air and Administrative Directors; Northern and Southern 

Regional Directors; Communications Officer; and ADEQ Administrative Council. 

Management - those individuals directly responsible and accountable for planning, 

implementing, and assessing work. 

Management System - a structured non-technical system describing the policies, objectives, 

principles, organizational authority, responsibilities, accountability, and implementation plan of 

an organization for conducting work and producing items and services. 

Management System Review (MSR) - the qualitative assessment of a data collection operation 

and/or organization(s) to establish whether the prevailing quality management structure, policies, 

practices, and procedures are adequate for ensuring that the type and quality of data needed are 

obtained. 

Measurement Quality Objectives (MQOs) - Performance or acceptance criteria for individual 

data quality indicators, usually including precision, bias, sensitivity, completeness, comparability, 

and representativeness. 

Method - a body of procedures and techniques for performing an activity (e.g., sampling, 

chemical analysis, quantification) systematically presented in the order in which they are to be 

executed. 

Mixed Waste - hazardous waste material, as defined by 40 CFR part 261 (RCRA), mixed with 

radioactive constituents. 

Peer Review - a documented critical review of work characterized by the existence of potential 

uncertainty. The peer review is conducted by qualified individuals (or organization) who are 

independent of those who performed the work, but are collectively equivalent in technical 

expertise (i.e., peers) to those who performed the original work. The peer review is conducted to 

ensure that activities are technically adequate, competently performed, properly documented, and 

satisfy established technical and quality requirements. The peer review is an in-depth assessment 

of the assumptions, calculations, extrapolations, alternate interpretations, methodology, 

acceptance criteria, and conclusions pertaining to specific work and of the documentation that 

supports them. Peer reviews provide an evaluation of a subject where quantitative methods of 

analysis or measures of success are unavailable or undefined, such as in research and 

development. 

Performance Evaluation Audit - a type of audit in which the quantitative data generated in a 

measurement system are obtained independently and compared with routinely obtained data to 

evaluate the proficiency of an analyst or laboratory. 
66 

Performance Evaluation Sample - (PE) a sample, the composition of which is unknown to the 

analyst, is provided to test whether the analyst/laboratory can produce analytical results within 

the specified performance limits. 

Procedure - a documented set of steps or actions that systematically specifies or describes how 

an activity is to be performed. 

Process - an orderly system of actions that are intended to achieve a desired end or result. 

Examples of processes include analysis, design, data collection, operation, fabrication, and 

calculation. 

Qualified Data - any data that have been reviewed and assessed as part of data validation, or 

data verification, operations. 

Quality - the sum of features and properties/characteristics of a process, item, or service that 

bears on its ability to meet the stated needs and expectations of the user. 

Quality Assurance (QA) - an integrated system of management activities involving planning, 

implementation, assessment, reporting, and quality improvement to ensure that a process, item, 

or service is of the type and quality needed and expected by the customer. 

Quality Staff - the EPA Headquarters office within the Office of Environmental Information 

that establishes and promulgates Quality Assurance Policy for the Agency. Formerly the Quality 

Assurance Management Staff (QAMS). 

Quality Assurance Project Plan (QAPjP) - a formal document describing in comprehensive 

detail the necessary QA, QC, and other managerial and technical activities that must be 

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

(data quality) objectives. 

Quality Assurance Program Plan (QAPrP) – a formal document that describes the QA system 

for environmental Programs such as the Clean Water Act or Clean Air Act that is usually based 

on environmental regulations. It contains details like a QA Project Plan, but at a organization 

wide or Program level and can function as a QA Project Plan or it may contain broader spectrum 

procedures that require additional QA Project Plans with more specific details. 

Quality Control (QC) - the overall system of technical activities that measures the attributes and 

performance of a process, item, or service against defined standards to verify that they meet the 

stated requirements established by the customer. 

Quality Improvement - a management Program for improving the quality of operations. Such 

management Programs generally entail a formal mechanism for encouraging worker 

recommendations with timely management evaluation and feedback or implementation 

Quality Management - that aspect of the overall management system of the organization that 

determines and implements the quality policy. Quality management includes strategic planning, 
67 

allocation of resources, and other systematic activities (e.g., planning, implementation, and 

assessment) pertaining to the quality system. 

Quality Management Plan (QMP) - a formal document that describes the quality system in 

terms of the organizational structure, functional responsibilities of management and staff, lines of 

authority, and required interfaces for those planning, implementing, and assessing all QA 

activities conducted. 

Quality System - a structured and documented management system describing the policies, 

objectives, principles, organizational authority, responsibilities, accountability, and 

implementation plan of an organization for ensuring quality in its work processes, products 

(items), and services. The quality system provides the framework for planning, implementing, 

and assessing work performed by the organization and for carrying out required QA and QC 

procedures. 

Readiness Review - a systematic, documented review of the readiness for the startup or 

continued use of a facility, process, or activity. Readiness reviews are typically conducted before 

proceeding beyond project milestones and prior to initiation of a major phase of work. 

Remediation - the process of reducing the concentration of a contaminant (or contaminants) in 

air, water, or soil media to a level that poses an acceptable risk to human health. 

Self-Assessment - an assessment of work conducted by individuals, groups, or organizations 

directly responsible for overseeing and/or performing the work. 

Sensitivity - - The capability of the measuring instrument to discriminate between the analytical 

response (e.g., absorbance, volume, meter reading) and background. In a specialized sense, it has the 

same meaning as the detection limit.

Service - the category of economic activity that does not produce manufactured items. In 

environmental data operations or engineering projects, such activities include design, inspection, 

laboratory and/or field analysis, repair, and installation. 

Significant Condition - any state, status, incident, or situation of an environmental process or 

condition of an engineered environmental system in which the work being performed will be 

adversely affected in a manner sufficiently serious to require corrective action to satisfy quality 

objectives or specifications and safety requirements. 

Software Life Cycle - the period of time that starts when a software product is conceived and 

ends when the software product is no longer available for routine use. The software life cycle 

typically includes a requirements phase, a design phase, an implementation phase, a test phase, 

an installation and check-out phase, an operation and maintenance phase, and sometimes a 

retirement phase. 

Standard Operating Procedure (SOP) - a written document that details the method for an 

operation, analysis, or action with thoroughly prescribed techniques and steps, and that is 

officially approved as the method for performing certain routine or repetitive tasks. 
68 

Supplier - any individual or organization furnishing items or services or performing work 

according to a procurement document or financial assistance agreement. This is an all-inclusive 

term used in place of any of the following: vendor, seller, contractor, subcontractor, fabricator, or 

consultant. 

Surveillance - the act of monitoring or observing a process or activity to verify conformance to 

specified requirements. 

Technical Review - a documented critical review of work that has been performed. The review 

is accomplished by one or more qualified reviewers who are independent of those who 

performed the work, but are collectively equivalent in technical expertise to those who 

performed the original work. The reviews are an in-depth analysis and evaluation of documents, 

activities, material, data, or items that require technical verification or validation for 

applicability, correctness, adequacy, completeness, and assurance that established requirements 

are satisfied. 

Technical Systems Audit (TSA) - a thorough, systematic, on-site qualitative audit of facilities, 

equipment, personnel, training procedures, record keeping, data validation, data management, 

and reporting aspects of a system. 

Validation - an activity that demonstrates or confirms that a process, item, data set, or service 

satisfies the requirements defined by the user. 

Verification - the act of authenticating or formally asserting the truth that a process, item, data 

set, or service is, in fact, that which is claimed. 
69 

APPENDICES 

ADEQ Temperature/Preservation Guidance Policy 

ADEQ Policy 0154 - Addressing Spike and Surrogate Recovery As They Relate to Matrix 

Effects in Water, Air, Sludge, and Soil Matrices 

ADEQ Policy 0170 – Implementation of EPA Method 5035 - Soil Preparation for EPA 

Methods 8015B, 8021B, and 8260B 

Arizona Data Qualifiers – Revision 3 (0 9/20/2007) 
Attachment J 

PCWRL Quality Manual