February 22, 2000

The US Environmental Protection Agency (EPA) Office of Solid Waste (OSW) is submitting comments against the proposed closure and transfer of functions of NTIS.

Background

OSW currently is responsible for developing and publishing "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods" (EPA publication SW-846), a compendium of all analytical test methods used in support of the Resource Conservation and Recovery Act (RCRA) program. By periodically updating SW-846, OSW promotes cost effectiveness and allows the regulated community flexibility in choosing analytical test methods.

However, SW-846 contains over 3,000 pages of methods and it was becoming increasingly difficult for the regulated community to search for a particular analyte, chapter, method number or section. OSW, therefore, set up an Interagency Agreement (IAG) with NTIS to have them put SW-846 on CD-ROM so that the regulatory and regulated communities could have the capabilities to search on various parameters and to download material for developing their own standard operating procedures (SOPs). Version 1.0 of the CD-ROM came out in May, 1996.

Since SW-846 is a living document that is periodically updated to include the latest in analytical methodologies, OSW decided to continue the IAG to update the CD-ROM to include the methods contained in the latest finalized update to the manual. Version 2.0 came out in December, 1997. Over 1000 copies of Version 2.0, including LAN versions, have been disseminated so far. We also asked NTIS to develop a separate CD-ROM containing proposed Update IVA methods, which came out in March 1999; in addition we expect to develop another CD-ROM of proposed methods, Update IVB, sometime this fall. Customer response to all of the CD-ROMs has been very favorable, especially concerning the products utility and high quality.

Comments

OSW has been very happy with the service provided by NTIS. They put together a highly competent team of individuals who handled the cost estimates and premastering specifications for the CD-ROMs, as well as the marketing of the products through publications, web sites and demonstrations at various national meetings, including the Waste Testing and Quality Assurance (WTQA) symposia, and the Pittsburgh Conference (PittCon). They also listened to our needs as to what we wanted the product to do and chose software based on those needs instead of trying to force fit out-of-date software just because it was on the shelf.

Over the years, OSW has developed a close working relationship with NTIS. If NTIS closes and it's functions are transferred to another organization like the Library of Congress (LOC), it will adversely affect the creation, production and distribution of current and future editions of the SW-846 CD-ROM. It's important to keep updating the CD-ROM so that the methods can be used by those individuals who do not have access to the Web or do not have the capability of downloading and printing large or complex documents such as SW-846 (especially the international community). Our customers (e.g., laboratories, quality assurance officers, bench chemists) are impressed with the CD-ROMs in that they are searchable and contain both the pdf files and the WordPerfect files for developing their own SOPs. We are leery about the LOC being able to provide the same high quality of service that NTIS now provides. We feel that the service NTIS provides should be kept operational and that they be given the chance to keep going.

If you have any questions, please contact us:

US Environmental Protection Agency
Office of Solid Waste (5307W)
Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460

Phone: 703-308-8855
Fax: 703-308-0509