Subcontracting—Nothing to Fear
The words “subcontracting” or “subcontractor” may cause many clients to cringe, but I’m here to set the record straight. If you are squeamish at the thought of subcontracting, then I have a statement that will help eliminate that uneasy feeling: Subcontracting is vital to the accuracy, growth and survival of testing laboratories. Granted, choosing a subcontractor is not as easy as looking in the telephone book or searching on the Internet, but there are a few ways to ensure a subcontractor is reputable.
The Water Quality Association (WQA) Laboratory performs testing and analytical sample analysis to the NSF/ANSI Drinking Water Treatment Unit (DWTU) and NSF/ANSI Drinking Water Additives (DWA) standards. In addition, the WQA has established a Recognized Testing Laboratory program, which includes both product testing laboratories (testing DWTUs) and analytical laboratories (analyzing DWTU and DWA water samples).
Testing laboratories are governed by the international standard ISO/IEC 17025 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC 17025 defines all aspects of a laboratory’s quality system, from management requirements and document control, to sampling of products and creating test reports. ISO/IEC 17025 also provides specific guidance for subcontracting. The international standard provides the following four requirements:
1) The subcontractor chosen meets the requirements of ISO/IEC 17025.
2) The laboratory must inform the customer and gain their approval for subcontracting.
3) The laboratory is responsible for the subcontractor’s work.
4) The laboratory must maintain a register of all the subcontractors it uses for testing and record evidence of compliance with ISO/IEC 17025.
Proof of Compliance
Proof of subcontractor compliance to ISO/IEC 17025 can be demonstrated through accreditation from accreditation bodies such as the American Association for Laboratory Accreditation according to ISO/IEC 17025 or by conducting an audit of the potential subcontractor. Conducting an audit of the potential subcontractor is always a good idea. The audit allows a hands-on evaluation of the laboratory’s competence in the areas in which work will be subcontracted to them.
Analytical laboratories are also subject to meeting the requirements of ISO/IEC 17025 if they are to be used as subcontractors. Analytical laboratory compliance is typically established through a facility audit. Analytical laboratories, however, have additional means of verifying competence for the analyses they conduct.
The National Environmental Laboratory Accreditation Program (NELAP) is a program in which state and federal agencies serve as accrediting authorities with guidance from the U.S. EPA to ensure that laboratories generate data of known and acceptable quality on which to base public health and environmental management decisions. Currently, 12 states are NELAP-approved accrediting authorities: California, Florida, Illinois, Kansas, Louisiana, New Hampshire, New Jersey, New York, Oregon, Pennsylvania, Texas and Utah. Based on the reciprocity of NELAP, accreditation from one of these states represents acceptance in all 12 states included in the program. Individual state accreditations can also be obtained for those who do not participate in NELAP. Accreditation is based on the analytical laboratory’s ability to analyze samples using recognized EPA methods and successfully participate in Proficiency Testing studies (blind sample analysis).
Why subcontract? There are many reasons, but the most important one is to meet the client’s expectations for price and turnaround time. There are many factors that could prevent a product-testing laboratory from meeting the expectations of the client, but using competent subcontractors by maintaining a subcontractor program can help eliminate these factors.
The first reason testing laboratories should maintain subcontractor programs is for situations in which excessive workload or temporary incapacity occurs. Whether a laboratory is bursting at the seams with work, or testing instruments and/or test benches are not operating properly and are in need of repair, there are times when a client cannot afford to wait. In those situations, testing can be performed in a timely manner by utilizing a reputable subcontractor.
The second reason why testing laboratories can benefit from maintaining subcontractor programs is in situations in which the requested testing is beyond the scope or expertise of a testing laboratory. For example, if a client requests specialized testing, such as microbiological testing, a laboratory that specializes in microbiological testing would be subcontracted to perform the requested test. Developing the resources (material, personnel, etc.) needed to conduct this type of testing would lead to excessive costs and extended completion timelines.
Perhaps the most convincing reason testing laboratories should maintain subcontractor programs is to monitor laboratories’ work. Performing testing in two different laboratories provides an excellent opportunity to monitor the results of the approved subcontractors. Comparison testing can also be performed by the laboratory requesting the subcontracting and a laboratory that is an approved subcontractor to ensure the work the laboratory requesting subcontracting performs is accurate. All parties involved with this process benefit because any discrepancies between the results will be addressed and resolved.
If properly maintained, an approved subcontractor program can offer a laboratory unlimited testing capacity and quick turnaround times—maybe subcontracting isn’t so bad after all.