CRE Receives Comment Offering Different Perspective on Data Quality

CRE and others interested in Data Quality have primarily focused on the need for accurate information to serve as the basis for federal regulation. However, in a comment submitted by Cargill Fertilizer, Inc., it was pointed out that data can sometimes be generated solely for the purpose of determining whether a regulatory limit has been reached. In such cases, achieving greater accuracy would be an unnecessary and costly exercise.

While CRE agrees that pinpoint accuracy of scientific values in every situation may be unwarranted, Data Quality in the context of current congressional legislation focuses on federal agencies' information use and dissemination. The onus to correct inaccuracies would be on the agencies and would only be triggered where an interested party brings a petition, thereby presumably limiting instances of Data Quality challenge for mere academic benefit. However, CRE values this important perspective which should surely be kept in mind.

Text of Comment by Cargill Fertilizer, Inc.

Regarding the issue of data quality, it should be recognized that there may be significant costs associated with increasing the accuracy and decreasing the bias for environmental samples.

There has been a trend toward increasing quality assurance requirements for environmental samples. These can include multiple sampling personnel, rinsing equipment with pure water, etc. All with the intent of assuring that the laboratory result is absolutely correct.

However, it should be recognized that regulated facilities are not necessarily interested in obtaining the absolute value. The only purpose of most samples is to determine if the result is greater or less than a regulatory limit. If a sample is contaminated but still demonstrates compliance, it should be sufficient. Even if it is not suitable for other regulatory purposes.