SAP 5 Handling Collusion, Falsification or Participant Failures – 2023 Page 1 of 2

This publication is available free of charge from: Link to be provided when approved for publication.

SAP 5

OWM PT Standard Administrative Procedure 

for 

Handling Collusion, Falsification, and PT Participant Operational Failures

1 Introduction

Purpose of the Procedure 

The purpose of this procedure is to formalize and standardize OWM 

Laboratory Metrology Program communications to PT program participants 

when collusion, falsification, or participant failures occur that impact the 

quality and integrity of the PT program or violate expressly stated policies and 

procedures. 

Scope

The scope of this procedure is applicable to the OWM Laboratory Metrology 

Program PT activities related to collusion, falsification of data, and 

operational failures committed by PT participants. It does NOT cover pass/fail 

PT analyses. 

Applicable Documentary References

NISTIR 7214, PT Program Quality Manual and NISTIR 7082, PT Program 

Policies and Plan specify that PT participants shall not share data amongst 

participants to gain inappropriate measurement results prior to performing 

calibrations (collusion) and shall not falsify measurement results, 

uncertainties, or other data that are reported as part of the PT. Policies also 

specify that participants shall follow the PT plan with respect to care and 

handling, use of specific procedures, schedules, and confidentiality with 

exceptions specified. Failures that impact the quality or condition of the PT 

standard artifacts or resulting PT analysis are covered under this procedure. 

Responsibility and Authority 

OWM Laboratory Metrology Program staff are assigned responsibility 

and authority for documenting and communicated suspected violations 

of the policies and procedures identified under this scope and for 

alerting the Program Leader for appropriate action(s). 

OWM Laboratory Metrology Program, Program Leader is responsible 

for investigating, communicating, and resolving suspected violations of 

this policy and taking appropriate action. 
SAP 5 Handling Collusion, Falsification or Participant Failures – 2023 Page 2 of 2

This publication is available free of charge from: Link to be provided when approved for publication.

2 Methodology

Staff may obtain suspected information (complaints) from the regional 

PT Coordinators, PT Coordinators, or PT Analysts or through direct 

observations. The receiving staff member shall complete Form 1: OWM 

PT Feedback and Inquiry and Complaint Form through the section on 

OWM Evaluation and Resolution. 

The Laboratory Metrology Program, Program Leader is responsible for 

completing the Form 1 as noted in 1.4.2. 

Action Items arising from the investigation may be handled with SAP 

2, Handling PT-Related Action Items and Form 4, OWM PT Action 

Form.

Offending PT participants (and any complainants) will be notified of the 

final resolution in writing. Affected participants and laboratories have 

the right to appeal OWM decisions if they provide additional supporting 

evidence or acknowledgment. Appeals are handled with SAP 2. 

2.1.4.1 Resolution may be any one or all of the following depending on 

the intent or extent of the observations.

• Warning letter;

• Requirement for additional training and oversight;

• One-year or two-year limit on PT participation; or

• Permanently banning PT participation from the staff 

member or laboratory (which may be appealed in writing to 

the Laboratory Metrology Program, Program Leader when 

providing additional explanations or justifications or 

apologies). 

3 Records

Applicable Form 1 and Form 2 are retained with the PT Records for the specific 

PT in question and duplicated in the PT Complaint directory. Any completed 

Form 2 is identified in the Action Item Log as well.

Official communications related to the investigation, communication, and 

resolution of the Complaint is retained as part of the PT Complaint directory.