What is EPA doing to implement PBMS?
Assuring the quality of environmental measurements is essential to implementation of EPA's environmental programs, both regulatory and voluntary. In a 1997 Notice of Intent, the Agency outlined a "Performance Based Measurement System (PBMS)" concept that was intended to "improve data quality and encourage advancement of analytical technologies.”
As part of EPA's effort to implement the PBMS approach, the following actions were taken:
Incorporating the PBMS philosophy into new regulations.
Establishing data quality and performance requirements for RCRA-required monitoring and including the requirements in the RCRA regulations, as necessary, to assist the regulated community in method selection and help assure successful PBMS implementation.
Developing new sampling and testing methodologies which are compatible with the PBMS approach and encouraging use of those methods.
Fostering training and guidance to educate regulators and the regulated community regarding the flexibility of PBMS, the inherent flexibility of SW-846, and application of PBMS during RCRA-related monitoring.
Removing some of the required uses for SW-846 methods from RCRA regulations, where the Agency believes these requirements are not necessary (in order to facilitate PBMS implementation), and thus removing regulatory barriers to the use of new and innovative technologies for RCRA-related monitoring.
In 2008, EPA gauged its progress towards achieving the goals of PBMS, and redefined the steps needed to ensure continued progress. As a result of this analysis, the Agency now believes that while it may be possible to specify performance criteria in a manner that is independent of methods, techniques, or instruments, the development of a single protocol for the validation of all current and future measurements, including measurements made with techniques yet to be invented, is simply not possible. Accordingly, in February 2008 EPA introduced flexible approaches for environmental measurement which capture the Agency's experience of the past ten years and set the stage for future progress.