In 1995, Eureka Laboratories, Inc. was fined $1.8 million and two chemists who worked at Eureka were convicted of federal fraud charges related to the manipulation of lab results for federal contracts. The convictions came after the federal government suspended Eureka from contracting because of allegations of fraudulent practices. The Eureka case, although one of the most prominent, is only one of many cases of laboratory fraud which have been uncovered nationwide. Although the Eureka incident has passed, several efforts are underway to prevent future similar occurrences. The U.S. Environmental Protection Agency Office of Inspector General issued a report¹ which was critical of quality oversight at the military facilities in Region 9; a major issue was the impact of lab fraud. Subsequent audits in other EPA Regions have led to similar conclusions on data quality, and EPA is expected to develop a national response to the issues raised by the OIG. Concurrently, the California Military Environmental Coordination Committee (CMECC) is developing guidelines for the prevention of laboratory fraud at military facilities. The techniques which are being considered include the following:

Double-blind (disguised) Proficiency Test Samples: These are samples submitted along with field samples in a way that the lab is unlikely to know that they are proficiency samples. A number of companies offer certified samples; the certification may be based on ISO 9001 certification, a federal contract, or self-certification. Submitting disguised samples requires the participation of field staff so that they appear to be environmental samples. Disguised samples are regarded as much more powerful tools than announced proficiency test samples.

Audits: Although audits of laboratories are required by lab certification programs, as well as by many clients, few of the audits involve actually reviewing raw data and the process used to generate a final lab report. These performance audits may be a cost-effective tool for discovering poor practice or fraudulent practice.

Data Validation: Data validation involves a review of either a hard copy lab package, with supporting documentation, or electronic review of the lab package in an electronic format. The U.S. EPA Contract Lab Program uses electronic reporting and electronic data validation using the CADRE program. Although data validation is a relatively expensive tool, it will be required on some projects, typically on 10-20% of the lab reports.

Electronic Record Audits: A powerful technique which has been used successfully in fraud investigations is the review of magnetic media records and an independent analysis of the data by an experienced chemist. Results of gas chromatography/mass spectroscopy (GC/MS) tape audits were used to prove the fraud allegations in the Eureka case.

The CMECC lab fraud guidelines are scheduled for completion in early 1997. In addition, a Cal/EPA Environmental Data Quality Team is preparing recommendations to Cal/EPA on data quality issues, including lab fraud prevention. The increased use of lab fraud detection and prevention techniques will have an impact on all those who are involved in the collection of environmental data; their effectiveness and cost will likely be a major issue for the future of environmental measurement.

¹ "Environmental Data Quality at DOD Superfund Sites in Region 9," U.S. E.P.A. Office of Inspector General, E1SKF5-09-0031-5100505, September, 1995.

Bart Simmons, Ph.D., is the Acting Chief, Hazardous Material Laboratory, Department of Toxic Substances Control, Berkeley, CA.