Web Introduction to FAQ
The Analytical Laboratory Accreditation Criteria Committee (ALACC) has been called upon by the users of the “AOAC INTERNATIONAL Guidelines for Laboratories Performing Microbiological and Chemical Analyses of Food and Pharmaceuticals” (ALACC Guide) to clarify requirements. Now that many laboratories have implemented the ALACC Guide in their operations, laboratory managers are asking questions about the requirements. ALACC has instituted a system to improve the posting of ALACC Frequently Asked Questions (FAQ) questions and answers. When new questions and answers are posted, they are now organized by section corresponding to the appropriate section in ISO/IEC 17025: 2005. Each section will have the most recent questions first. New questions will be posted in red so that it will be clear when new information has been added. The date the FAQ is finalized will be included.
The addition to the FAQ of the date when the FAQ is finalized and the posting of additions in red will make it easier for users to determine when FAQ are added to the list. It is suggested that users review the FAQ regularly to look for additions and thus keep up to date with ALACC requirements.
The process of revising the ALACC Guide has just begun. If you are a member of AOAC and the Technical Division for Laboratory Management (TDLM), you are encouraged to participate in the revision process by joining one of the following subcommittees:
Chemistry, Microbiology, and Pharmaceutical
Please contact afox@aoac.org for membership on a subcommittee.
FAQ #1
ALACC Section:
5.9
Question:
AOAC has added language to ISO 17025:2005 section 5.9 stating, "Statistical process control charts shall be prepared for the QCS sample analyses and for the duplicate analyses, if duplicates are used. Corrective action shall be taken for all control samples that are outside of the acceptance criteria of the control chart." However, for some analytical procedures (e.g. pesticide residues in foods, metals by ICPMS, etc.) there may be a large number of analytes spiked into the laboratory's QC sample(s). As the number of such analytes increases it becomes statistically likely that a few will be outside control limits. This may not indicate that the analytical system is out of control. How is the laboratory to interpret the AOAC requirement for applying control chart acceptance criteria to "all control samples"?
Answer:
The laboratory shall clearly define in a procedure and state the criteria for evaluating the results of laboratory control samples for single and multi-analyte methods.
With multi-analyte methods the probability exists or is statistically likely that at least one test result in each run will be out of limits. Thus, an out of limit test result does not necessarily mean there is an error and assignable cause for the result.
The laboratory's approach should be balanced: avoiding unproductive corrective actions for statistically random events, yet not so broad as to ignore correctible, non-random errors. The laboratory's approach may take into consideration the fact that for some multi-analyte methods, some analytes behave better than others (i.e. exhibiting less variance and/or higher mean recovery) and that an analyte's variance may increase as the concentration of the analyte decreases.
The approach should also include an examination to assure that analytes react independently, meaning that the analyte chemistry is independent. For example in metals, the results of some metals are dependent on the interference component of other metals, like iron interferes with certain metals.
The approach should also group analytes with similar chemical structure that react similarly in the chemical processing. An example of this is low molecular weight ketones that tend to be lost in the sample preparation process or organic acids that may be poor performers in certain extraction processes.
There are several approaches that could be taken to set limits and to take into account the probability of an out of control result in multi-analyte methods. One approach would be to assign the analytes to groups that have similar analytical characteristics. Then the quality control and control charting procedure can be designed to track each of these groups.
Another approach that could be taken is to set limits that take into the account the probability that an out of control result will be encountered, such as the approach set forth for environmental testing laboratories in the 2003 NELAC Standard (Appendix D, section D.1.1.2.1.e).
Appendix B Food Micro, section 2.1.1 states “records shall be kept to include…… date opened…” Does the date opened have to be kept as a record?
The date opened is included on the label and is not always stored in a lab notebook or electronic record. Thus, when the label is discarded, the record of the date opened is discarded. Does the date opened have to be maintained as a record?
Answer:
The date opened needs to be kept as a record and not recorded just on the label that will be discarded. The shelf life of a product could adversely be impacted once opened, so with that it is important to know when a container was opened. Its importance will depend on the type of media and how hydroscopic it is but it’s easy enough to record along with the other information.
How often must the temperature uniformity of freezers and refrigerators be verified? What is a practical approach to determining temperature uniformity?
Answer:
As stated in Table 2. Refrigerators and freezers must have the temperature verified daily.
As stated in Table 1, refrigerators and freezers must have the accuracy of the temperature sensing system, uniformity and stability of temperature calibrated at installation (or initial use) and annually.
Any device which minimizes errors from actions such as opening the door could be used. For example, thermocouples could by used. They can be placed in the refrigerator or freezer, the door closed with the leads protruding, and all of them checked by connecting each lead to the meter without opening the door until finished and they can be removed.
Appendix A: Equipment
Table 3 Maintenance of Equipment
Question:
The AOAC Appendix A (Equipment) Table 3 includes a requirement (nine occurrences) to sanitize equipment. In the pesticide residue field, many sanitizing agents cause interferences with the LC and GC instruments. Also, the equipment does not need to be sanitized as it does for microbiological work.
Table 2 includes multiple requirements to verify sterility and one to verify microbial density. These requirements are of importance only for micro labs and are not relevant to chemical tests.
Answer:
The following note is related to Appendix A: Equipment
In Tables 2 & 3 the requirements for sanitization and sterility are relevant for microbiological labs. The requirements may not apply to the chemistry tests, for example, the methods for testing pesticide residue. If the requirements are not relevant to a method, the lab must document the justification.
How to Meet ISO 17025 Requirements for Method Verification
Page 9
Measurement Uncertainty for Microbiology Measurement uncertainty is a parameter associated with the result of a measurement that characterizes the dispersion of the values that could reasonably be attributed to the measurand, in other words, the variance or standard deviation of the result or the degree of confidence in an analytical result. Calculation of MU is more reliable with a minimum of 30 observations in order to obtain the 95% confidence limits of the overall precision of the method. Therefore it is not unreasonable to expect that each of the required performance characteristics would also be based on 30 observations.
Question:
The requirements for microbiological methods imply that 30 data points is the minimum number acceptable, but it is not stated explicitly.
Is the minimum number 30, or do we have some latitude (e.g. 20 - 50)?
Answer:
The recommendation to use 30 data points is based on the specification for calculating Measurement Uncertainty and is applicable to quantitative methods. 30 data points should provide sufficient information on the variability of a quantitative method to permit a decision on method performance and its fitness for purpose.
The lab must document and justify its decisions as to how many data points to use. The use of fewer than 30 data points should not be routine but may be justified under special circumstances. In this case, as more data is collected the charts should be updated/recalculated to reflect a minimum of 30 points.
Fewer data points (10-15) would be appropriate for verifying qualitative methods. Again, the lab must document its justification for how many data points are used.
In Appendix B: Food Microbiology part 6. Standards for Laboratory Grade Water under Weekly testing (or with use): the Standard reads >1.0 megohoms-cm resistance at 25oC. The units for resistance are ohms however in the Standard the units are megohm-cm which are units of resistivity.
Does the >1.0 in the Standard refer to resistance or resistivity?
6. Standards for Laboratory Grade Water
Only water that has been treated to be free from traces of dissolved metal, bactericidal, and inhibitory compounds should be used to prepare culture media, reagents, and dilution blanks [reference: Standard Methods for the Examination of Dairy Products (SMEDP, 16th Ed.) and Standard Methods for the Examination of Water and Wastewater (SMEWW, 20th Ed.)]. Inhibitor-free water is referred to as microbiologically suitable (MS) water.
Question:
Topic: Standards for Laboratory Grade Water for Microbiological Testing
Question: Appendix B, 6.0 includes a requirement for annual testing for toxicity. The specifics of this requirement are unclear. Some labs have interpreted this to require acute water toxicity testing, which is not the intent. Please reference the section of the SMEDP and SMEWW that pertains to the toxicity requirement.
Answer:
The correct references for “Test for Toxicity” under “Annual Testing” are:
SMEDP, 17th edition, Section 4.041 Dilution Water Toxicity Test
SMEWW, 21st edition, Section 9020 B. Intralaboratory Quality Control Guidelines
Table 9020:II Quality of Reagent Water Used in Microbiology Testing
Are the requirements in Section 2.1.1 intended for tracking the disposal of empty bottles of used-up dehydrated media or just for tracking the disposal of expired or defective dehydrated media?
Answer:
All media shall be labeled with an identification scheme, preferably a number or alpha-numeric system, and dated. Dehydrated media records shall be kept to include media name or description, manufacturer's lot number, assigned laboratory number, date received, date opened, date prepared for Quality Control (QC), manufacturer's expiration date, discard date, and initials of responsible person. All dehydrated media shall be labeled with laboratory number, identification, and date approved. A part of the media, policies and procedures shall include handling the dispostion of expired media.
Appendix B, Section 4 states that all batches of media... shall be traceable to autoclave records which shall show.. time into autoclave, time at desired temperature and time out of autoclave
Question:
Original Question
Appendix B, Section 4 states that all batches of media... shall be traceable to autoclave records which shall show.. time into autoclave, time at desired temperature and time out of autoclave....
Thus, the question is that for those autoclaves (typically smaller table top sized units) which lack a tempscribe, (or other temperature recording device), other than noting the timer setting, what records can / must the laboratory produce in order to demonstrate that it is meeting the requirements of this particular clause?
Answer:
For those autoclaves (typically smaller table top sized units) which lack a tempscribe, (or other temperature recording device), the lab can use datatracers or other thermocouple type devices to record the temperature profile of the autoclave run in order to demonstrate that it is meeting the requirements.
Only water that has been treated to be free from traces of dissolved metal, bactericidal, and inhibitory compounds should be used to prepare culture media, reagents, and dilution blanks [reference: Standard Methods for the Examination of Dairy Products (SMEDP, 16th Ed.) and Standard Methods for the Examination of Water and Wastewater (SMEWW, 20th Ed.)]. Inhibitor-free water is referred to as microbiologically suitable (MS) water.
The following tests are to be performed on the water source to ensure that the water is inhibitor-free. Documentation of the following tests shall be recorded.
Weekly testing (or with use):
>1.0 megohms-cm resistance at 25°C
Monthly testing:
Total residual chlorine shall be <0.1 mg/L
Aerobic plate count shall be <1,000 colony forming units (CFU) per mL
Annual testing:
Heavy metals (Cd, Cr, Cu, Ni, Pb, and Zn-single) shall be <0.05 mg/L
Heavy metals (total) shall be <0.1 mg/L
Test for toxicity
Question:
The AOAC guidelines set specific criteria for "microbiologically suitable" water. Those criteria are not the same as the criteria set forth in the official Compendia of the United States or Europe for pharmaceutical testing.
Does AOAC (and ALACC) accept water meeting USP and Ph. Eur. monographs as "microbiologically suitable" or must the specific tests for residual chlorine and individual heavy metals be performed?
Answer:
Purified Water as defined by USP and EP would be appropriate as “Microbiologically Suitable Water”.
Quality of reagent water suitable for use in microbiological methods is defined in SMEWW Table 9020:II. This is what was referred to as “microbiologically suitable water” by the ALACC guide.
The water used in the laboratory needs to be fit for use and there are various documents that define this, such as USP, EP and SMEWW Table 9020:II. The lab must define the use of the water and ensure the water is fit for that use.
The AOAC guidelines set specific criteria for "microbiologically suitable" water. Those criteria are not the same as the crit
Does ALACC section 5.9 require the laboratory to take the same Quality Control Sample through all steps in quantitative and qualitative analyses, or is an appropriate step-specific QCS allowed even if it is not the same one all the way through the analysis?
Answer:
Although it is ideal to take the same Quality Control Sample through all steps, ALACC does recognize that for some methods this may not be possible.
In such cases, the lab is expected to explain the reason the same sample can not be used and do the best it can do. The lab must clearly identify the steps in the method that differ between the control sample and routine sample and have written justification/explanation how the lab knows and is able to verify the process is in control. It is imperative that the lab does have controls in all the steps so that the entire analytical process is monitored.
During the method validation or verification, a suitable sample, such as a Reference Material or Reference Standard, or Reference Culture, as well as Sample Duplicates, if possible, should have been presented to the entire method. In addition, the lab should on a predefined basis, yearly may be adequate, challenge the entire method with the same sample to verify the “step wise” approach to the Quality Control Monitoring is still valid.
The AOAC guidelines set specific criteria for "microbiologically suitable" water. Those criteria are not the same as the crit
Topic: Method verification of a category 3 limit test.
Should Table 4 include LOQ in the performance requirements that need to be verified for a Category 3 limit test?
The Table requires that both LOD and LOQ be verified. However, for validation, as listed in Table 1, only LOD is required.
Answer:
No, LOQ is not required for the verification of a category 3 limit test.
Also, the wording on page 2 for the description of a category 3 limit test should refer to LOD and not LOQ.
Question:
The batch size is, defined in the document for quantitative methods as "usually 20 samples or less", is that a maximum number that the lab must meet or alternatively can the size of the batch be determined as appropriate for the type of testing activity the laboratory is conducting?
ALACC 5.9 states:
For quantitative methods, accuracy and precision should be demonstrated to be acceptable; at a minimum, the laboratory shall run a quality control sample (QCS) with each batch of samples (usually of 20 samples or less). If a QCS is not available the lab must choose an alternate control sample such as a sample duplicate or reference material with each batch of samples (usually of 20 samples or less). For qualitative tests controls, such as QCS's, should be included to demonstrate that the test worked. The suitability of the controls used should be justified by the lab.
Answer:
The ALACC guide in section 5.9 does not intend to define the size of a batch. The intent of this statement was to explain that in a batch, of whatever number of samples, Quality Control Samples (QCS) shall be included at a frequency defined, documented and justified by the lab. For many test methods, the QCS is included every 20 samples.
The lab must determine for itself the maximum number of samples that can be analyzed in one batch, or run contiguously between QCSs. The lab must document and justify its decision.
Labs use different terminology to define the number of samples that are either analyzed together in a group, such as samples on an ELISA plate or are run contiguously, such as liquid samples presented to an instrument. Some labs use the term batches, other labs use the term lots. Any term is acceptable; but, the lab must define the term unambiguously.
Question:
For qualitative tests, is it imperative that "controls such as the QCS...be included" or can it be left up to the lab to decide what is appropriate for a given test and whether controls are necessary?
Answer: Controls are necessary for qualitative tests. It is up to the lab to decide what is appropriate for a given test. This decision must be documented and justified. If no Quality Control Samples exist, the lab must do the best it can do.
Section 5.10.8 "Format of Rand Certificates" should state 5.10.8 "Format of Reports and Certificates."
4.13.2.1 Previously the section for Technical Records (formerly 4.12.2) stated that "All records shall be traceable to the analysis performed on a particular sample...". The new revision states that "the chain of custody for all records shall be unbroken from the time a laboratory takes responsibility for the sample until the result is reported to the customer..." The question thus concerns the intent of this clause and whether this is meant to be referring to all records or just to those records that pertain to the sample?
This section, 4.13.2 deals with Technical Records, and the ISO 17025 wording is "The records for each test or calibration shall contain sufficient information to facilitate, if possible, identification of factors affecting the uncertainty and to enable the test or calibration to be repeated under conditions as close as possible to the original.", so 4.13.2 deals with the records of the test. Section 4.13.1 deals with General Records. Therefore, 4.13.2.1 is meant to refer to those records that pertain to the sample.
Also in Section 5.9: For determining the accuracy and precision associated with quantitative methods, paragraph two states that a QCS must be run if one is available or that an alternate control sample (such as a sample duplicate or Reference Material) if one is not. Going on, paragraph four states that replicate tests shall be used if suitable Reference Material is available, and the sixth paragraph states that statistical process control charts shall be prepared for the QCS sample analyses and for the duplicate analyses if duplicates are used. Does this mean that both a QCS and a duplicate sample or a Reference Material replicate be run with each batch of samples or is a single QCS or RM acceptable?
If possible both a QCS and a duplicate sample should be run with a batch of samples because the QCS does not capture the variability unique to the sample(s). If either a QCS or sample duplicates are not available, the lab must explain this, demonstrate they tried their best to obtain/develop a suitable QCS or use sample duplicates and explain what they are doing instead.
Table 1 Since temperature holding equipment, in particular incubators often differ greatly in volume, should there be a point below which, where the volume of the unit is sufficiently small that it becomes irrelevant to require that they undergo temperature uniformity and stability studies? Similarly, for most uses of freezers, should there also be a lower limit at which their volume renders the determination of uniformity of temperature irrelevant?"
The last note in Table 1 addresses this point.
Due to size, use or design, some refrigerators and freezers may not need to be temperature and stability calibrated annually and may not need the demonstration of temperature uniformity and stability. In these cases the laboratory should justify the reason for an alternate frequency of calibration or for not demonstrating temperature uniformity and stability"
Yes, due to size, a point below which, where the volume of the unit is sufficiently small, the lab does not need to demonstrate temperature uniformity and stability. It is up to the lab to determine this size and justify not performing the temperature uniformity and stability studies.
ISO 17025 Section 5.2.1, first paragraph, second sentence reads, "When using staff who are undergoing training, appropriate supervision shall be provided." and ALACC states "Personnel shall have demonstrated their competency prior to working on customer samples."
Can actual samples be used in training or when demonstrating competency?
In the ALACC statement, the phrase "working on" means the analyst performs the analysis of customer samples independently with the intention of reporting the results. Ideally, during the training and demonstration of competency no customer samples would be used; however, in some cases customer samples may be used. Whenever a trainee is performing tasks on customer samples, the trainee must do so under the supervision of a trained analyst and it is the trained analyst who takes responsibility for these tasks. The lab must be able to defend to an auditor that the trainee performing the tasks does not impact the analysis. Examples of cases where a trainee may perform tasks on customer samples Simple tasks such as pureeing plant material such as lettuce; the task has a distinct endpoint that the trained analyst can observe and ensure the trainee has performed correctly. Entering sample sets into a computer, the trained analyst can verify the information is correct and entered correctly before the analysis takes place.