How can one determine when a non-required method is appropriate to use for compliance with RCRA in relation to the Methods Innovation Rule?
If the analysis that you wish to perform is not for one of the Method Defined Parameters (MDPs) listed in 40 CFR §260.11, then you must determine whether a method (whether SW-846 or not) is appropriate for the analytical purpose. The Agency has written the following guidance in the MIR for determining method appropriateness:
An appropriate method might be one published by:
• EPA in a different manual or regulation;
• Another government agency;
• A voluntary standards setting organization; or
• Other well-known source.
Appropriate methods are reliable and accepted as such in the scientific community. These methods might include those published by the Agency or other government entities using techniques that have documented reliability (e.g., ASTM).
Appropriate methods generate effective data, known and of appropriate quality for project-specific decisions.
When selecting an appropriate method to use, you must be able to demonstrate and document that you are able to see the analyte of concern, in the matrix of concern, at the level of concern.
In addition, before selecting an alternative method other than SW-846 for RCRA-related testing and monitoring activities, we recommend that you discuss your plans with your regulating authority and the project managers.
Other Category: MIR & MDPs, PBMS & Flexible Approach