Perspective of the Environmental Monitoring Coalition Task GroupPlenary Session
Oral Presentation
Prepared by D. Friedman
Friedman Consulting LLC, 10817 Rippon Lodge Drive, Fairfax, Virginia, 220322931, United States
Contact Information: [email protected]; 703-389-3821
ABSTRACT
In August 2025, the Environmental Monitoring Coalition initiated an effort to reduce the amount of methylene chloride used in test methods for environmental testing. During this process, it became obvious that the primary barrier to implementing effective changes is the current EPA method approval process in the drinking water and wastewater programs. As a result, the EMC established a Task Group to develop recommendations to EPA on what needs to be done to remove these barriers.
The Task Group has developed the following language to the appropriate parts of 40 CFR Parts 60, 136, and 141.
(a) When analyzing samples to determine or demonstrate regulatory compliance, in addition to those methods described in Part 136.3(a) of this regulation, any method that has been validated for the particular matrix and analyte and issued by an EPA regulatory or scientific program may be employed as long as the method is sufficiently sensitive, accurate, and precise enough to demonstrate compliance with the requirements of the particular monitoring application (e.g., determination of permit or regulatory compliance).
(b) In addition, fully validated methods that have been published by Voluntary Consensus Standards Bodies, as defined in Section 2e of OMB Circular A-119, may be employed in the analysis without preapproval, as long as the method meets the accuracy, precision, and sensitivity needs of the analysis.
This talk will discuss the problems that have led to this effort, the progress made to date by the EMC, the benefits that adoption of these recommendations will have, potential downsides to the changes, and attempt to clear up some misconceptions as to what the change will mean for laboratories and analysts.
