AASHTO re:source Q & A Podcast
AASHTO re:source Q & A Podcast
Understanding Changes to the AASHTO Accreditation Program Procedures Manual
Brian and Kim discuss the newly redesigned AAP Procedures Manual. It presents the requirements of the AASHTO Accreditation Program in a new format that is easier to read and understand. This new version integrates the old procedures manual with the newer policy and guidance documents that AASHTO re:source had been issuing on its website. It also includes helpful links that can take the reader to other documents or websites to learn more.
There are also additions to the procedures manual that are the result of AASHTO re:source Administrative Task Group (ATG) precedents that are not being stated directly in this document to promote transparency such as more specific language about the minimum acceptable situations for approval of situations in which management is provided to more than one facility and other shared personnel situations.
Due to the release of this new version, a few of the policy and guidance documents were retired and others revised because the content was incorporated into the main body of the procedures manual. There will still be policy and guidance documents that explain some of the requirements in greater detail, but the intent is to incorporate the requirements into the procedures manual where possible.
The organization of the procedures manual is intended to present some of the essential information that everyone needs to know up front, and then starting in Section 7, it takes the reader through the accreditation process.
Starting in Section 14, the procedures manual starts to describe other situations that could be of interest like ISO/IEC 17025 accreditation, project laboratories, and mobile laboratories.
Finally, there are other important topics explained like confidentiality, external complaints, refusal of service, and information about certificates of accreditation, accreditation directory listings and how to properly promote laboratory accreditation.
Have questions, comments, or want to be a guest on an upcoming episode? Email podcast@aashtoresource.org.
Related information on this and other episodes can be found at aashtoresource.org.
Welcome to Ashto Resource QA. We're taking time to discuss construction materials, testing, and inspection with people in the know. From exploring testing problems and solutions to laboratory best practices and quality management. We're covering topics important to you.
SPEAKER_00:Welcome to Ashto Resource QA. I'm Brian Johnson.
SPEAKER_01:And I'm Kim Swanson. And we are here today to talk about the App Procedures Manual. I know it's everyone's favorite subject, right?
SPEAKER_00:It is. People love the App Procedures Manual. Uh they they can't get enough. So we are we're gonna give you plenty of information about that today. Uh and I'm happy this is our first recording where it's just me and Kim this season.
SPEAKER_01:Yep.
SPEAKER_00:Previous seasons we had a lot of these, not so much this season. Uh, but it's a special occasion because this is big news that we have to tell you about. And and I I did want to say that we already did email all of our customers about this and specifiers so that they're aware of these changes. But sometimes it's good to hear about these changes uh instead of going to read through this 18-page document on your own. So we're gonna hit the highlights in this episode. So so listen up.
SPEAKER_01:So, first off, where do people find the app procedures manual?
SPEAKER_00:Well, I'm so glad you asked. That is another change that we made.
SPEAKER_01:Well, a tweak. I wouldn't say it's a change, it's a tweak.
SPEAKER_00:It's a tweak, it's an adjustment. So, right now you can go to our document library on our website, re-university page to find it, or you can go through the accreditation page and find it there. But once you're there, you're gonna see a reorganization of the documents. There are several subcategories. You've got uh policies and document uh policy and guidance documents listed by topic instead of by title. Uh, so what this allows you to do is find what you're looking for a little easier than it used to be. Uh, so starting with the app procedures manual as the top document. Uh you know, it's sort of like when you're you want your business to be found first, you call it like triple A something. Uh well, we've got AA uh ASHO, accreditation program, procedures manual as the top document, followed by assessment documents, uh calibration information, confidentiality, and it'll take you all the way down through the alphabet until you get to training and competency evaluation, which is the bottom one. Then you get policy and guidance documents by standards. So that's where any standard-specific policies are in play. You will find those there. Then we've got our forms after that, assessment prep lists that helps you get prepared for your assessment. Uh, and then just random informational documents after that. They'd cover all kinds of different uh topics that didn't quite fit in anywhere else. And then you've got the R18 examples, and that is that's another new thing. So I will tell you about that briefly. That stemmed from a ballot on Ashto R18, which is another very popular document that we maintain or help maintain through the Ashto Committee on Materials and Pavements. We made a huge change. Well, it's in the works. Uh a huge ballot that uh changes the way R18 is uh identifies a lot of the requirements. Uh, but one of the big changes is we removed all of the kind of outdated and and not that effective examples that were in the back of R18. So that ballot to remove those examples passed. So in exchange for removing those examples, we are hosting some useful, more useful and up-to-date examples on our website for people to use. So if you are new to the program, those would be very useful for you to say, okay, what would one of these documents look like? I can go now to our website and find them, uh, at least a few examples. Plus, we have some uh more complicated examples uh that were created for situations where people get confused about how to determine uh a result. Uh the one example that comes to mind is sieving sufficiency for aggregate testing. There are multiple different requirements, and this table that we put in our examples uh encapsulates all of them. So you can record your results and see if they if you passed on several different standards.
SPEAKER_01:Yeah, so our document library has a bunch of stuff on it. I will say you can also get to the app procedures manual uh by going to the accreditation, astro accreditation link on our homepage. And then in the left hand side at the bottom, it just says procedures manual and it'll take you right there. So there are a couple of different ways to get there. You could also search for it on our website if that's easier. But so we covered where the changes of where it's at, not really changes, the tweaks to where it's at. Um, but if people are unaware, the procedures manual is part of the requirement, you have to follow that to be ASHTO accredited. So you have to follow R18, like the minimum requirements for Astro accreditation are you meet the standards of R18 and you follow the app procedures manual. That's the bare minimum that you have to do. Is there anything else about that that we should talk about before we dive into what the big changes were?
SPEAKER_00:Yeah, I I think it's good to talk about the importance of that document and and why these changes were made. Uh so this this has been kind of hanging in over my head for years that this document had references to old information, old terminology. Uh, it was not organized the best way. Uh and it and it wasn't that easy to find what you need. And it also didn't make any connections between our policy and guidance documents and the the overarching uh overarching procedures manual. Uh so what I tried to do in this ballot was give you some background on ASHTO accreditation in the beginning, then get into some of the essential requirements, and then take you through the process of getting accredited. Uh so that this procedures manual, as it's written, is a lot easier to follow for a new laboratory, which that's typically who the audience is going to be for a lot of this is somebody who doesn't know that much about the accreditation program. They want to learn more, they want to see what they need to do uh to be able to qualify for accreditation. And it's also use uh usable for any specifying agencies who are considering requiring ASHTO accreditation. So this will more clearly differentiate uh what requirements exist in our program that are not just in the standards uh that are listed uh on somebody's accreditation directory uh uh list of test methods.
SPEAKER_01:And so you mentioned that the changes to R18 were balloted. And I want to explain that process a little bit for people that we can't just make changes or you can't just make changes to the Astro Accreditation Procedures Manual, willy-nilly. It goes through a formal process where you ballot those changes. And is it the ATG, the administrative task group for Astro Resource? Do are they the only ones that have to approve it, or does it go to all of the uh committee on materials?
SPEAKER_00:So the app procedures manual, because of the importance of the document, it has to get balloted to the full ASHTO committee on materials and pavements. So the ATG, our oversight committee, that's sort of like the subcommittee that handles it. So that's like the first stage uh for the changes to be run through and then it goes to the full committee. Now, this because there are so many changes to this, uh, this version, and and really a lot of it is just editorial changes. But because it was going to be such a big change, I asked for permission to ballot it concurrently to get all of the opinions of everybody on the committee of materials and pavements uh to weigh in on these changes. Uh, so then I could have one big change uh to take all of their comments, apply them, work through some of them. Because sometimes when you ballot something to a big group, you'll get conflicting negatives. So, like one person says, I don't like it, it should say this. And someone who says, Well, I don't like it, but I think it should say this other thing that's also not what the other person said. So then you have to kind of work through with those voters to figure out what you're gonna do. And and we we did uh actually this one went pretty smoothly compared to R18. Uh R18 had had been a bigger uh challenge, especially uh getting through the uh the the voters' negatives because of those conflicts of expectations. Uh, but this one was a little bit easier, I think, because everybody is already adhering to the requirements and they were just kind of reframed in in this version. Although there are there are a few new wrinkles that we'll talk about today. But the ultimate goal of this was to make it easier to use and more transparent. Uh so that the transparency came with trying to uh link to the policy and guidance documents that are uh more explanatory for people and also to embed some ATG precedents that have kind of uh evolved over time with various ATG chairs uh and try to put those right in the requirements document so that people don't have to guess uh if a situation is acceptable or not.
SPEAKER_01:Yeah, I think it's an important clarification that only a few things have actually changed or been added, and mostly it was just a restructure and organize of the document. But I would love for you to tell our listeners more about what the difference is or why we even have the policy and guidance documents and why those aren't just part of the procedures manual or the standard that they're about. Why is there separate policy and guidance documents?
SPEAKER_00:Yeah, so the policy and guidance documents evolved because there are often um there's often a need to explain why things are the way they are, um, so that people have some context for the decisions that our program has made over the years. Uh, and and I think this really helps to educate the customers and and the specifiers about what you know the these requirements exist, this is why they exist, and and this is how you apply these requirements. So one good example is the policy and guidance document on how we handle proficiency sample suspensions. Uh so the procedures manual might just say, well, if you get consecutive low ratings or or or no data for uh a sample round, then you would get a suspension. And to resolve it, they can generally tell you how that is. Uh, but we get so many questions about, okay, well, what about if I get this number and this number, but then this one is this other number? So like they they always want to know, okay, what about this scenario? What about this scenario? So, what a policy and guidance document enables us to do is get into really get into the weeds about all the like this is something that looks bad, but it won't result in a suspension, and this is something that looks bad and will result in a suspension, and this is why, and then this is what you'd have to do to resolve it, and this is how this process works. So we can also explain more of our procedures rather than just laying out the requirements, and and and that's very helpful to kind of put the customers at ease about what to expect if they do get a suspension uh or or if they do get a low rating on a proficiency sample. So we have a lot of those kind of explanations in our policies and guidance documents.
SPEAKER_01:And are those documents um do they need to be reviewed and validated or no? Are those separate from the process?
SPEAKER_00:So those those are separate from the process, but uh what what we've done is up to I'd say up to this year, we had been kind of putting them out uh and basing them on ATG decisions, but not having the text reviewed. But but since this change to the app procedures manual, uh we are now passing them through at least the ATG level so that even though these are based on or just completely uh copying what the ATG decisions were and just making them something that's easier to digest, uh, I did want to get ATG approval on the wording just to make sure that they agree with it before we put it out in the public space. Uh so one thing that happened when the App Procedures Manual was issued, the the newest one, I went through with our group uh here at Ashto Resource and I had a uh a meeting with everyone and went over some of the changes. And I received quite a few questions on on two of the topics that were addressed. It's kind of funny, it's very hard. I think people underestimate how difficult transparency can be, because it it seems like something that would be obvious. Oh, you just say what it is. Uh, but what's hard is once you start saying all of the exceptions, people come up with other exceptions that didn't happen or or haven't happened yet or may never happen. And you think, oh boy, well, I guess I should address some of those in case they do happen. Uh, and then the document gets very long when you're trying to explain it. And and you do have to be like reasonable about it. You can't put all sorts of crazy, uh, like uh off the wall ideas, but you do like if you run into situation or you you you think about plausible situations that could occur and you try to identify those. So the two topics that I'm addressing right now are on uh personnel situations. So what that's intended to do is cover uh all of the different types of personnel arrangements that could exist or we have found to exist, and which ones are okay and which ones are not in the context of a laboratory maintaining ash to accreditation. Uh, that went from a one-page document to a full two-page documents with all the scenarios. Uh, but it now it is at the ATG for review. And on Friday, so we're recording this today on October 7th and 2025. And on Friday, that's the deadline for the ATG to get me their comments, and then I'll take those comments. And as long as there are no big issues, I'll publish it the following week. Uh, so that's one of them. The other one is on equipment ownership. So it's assumed that a laboratory is this is the kind of strange thing that will sound strange to some people, is you would just assume that a laboratory is like, okay, it's a business, they employ engineers and technicians, and they own equipment and they use that equipment. But people are always trying to invent ways to make money without doing work. So it's really you have to account for all of these scenarios where a a middleman situation is created, and and if that situation exists, how does that get resolved in the context of a laboratory or a testing firm maintaining accreditation? So we try to define these things and like okay, can I rent all the equipment? Do I have to own it? Do I have to have a building? Do I have to actually do the testing? Those are things that you wouldn't think rationally you'd have to worry about. But those scenarios do present themselves in real life. So we so we do have to address them. So the the second document is on equipment ownership and what needs to be owned and what can be rented and what where could it be maintained or how can it be maintained and who can maintain it. It gets very messy, as you can imagine.
SPEAKER_01:I can I can imagine that getting very complicated when people are not doing things maybe the traditional way or what has historically happened. Um, yeah, I can see that being very challenging. So thank you for describing and talking about what's about to come out, those two new policy and guidance documents, but also talking about the difference between the policy um and guidance documents and the procedures manual. So let's dive into some of the changes in the procedures manual. That was a lot of groundwork to get to the meat of this uh episode.
SPEAKER_00:It is, yeah, that was a big, big preamble. Uh but but but yeah, let's get into the people should be used to that by now if they listen to our podcast.
SPEAKER_01:If this is not your first episode, I'm generally used to it.
SPEAKER_00:Yeah, I'm I'm generally like uh 40% build up to what I'm gonna talk about in any episode. Okay, so if you're looking at the app procedures manual, the first thing I want to draw your attention to is that if you open up the tabs on the side, you can navigate to all the different sections very easily. Uh but the but like I already said kind of how it's laid out, but in the introduction, it kind of tells you about the CFR, which is the requirement that specified ashtode accreditation in the first place. Uh, we take you through the application process, scope, and limitations of the program. So under scope, it expands into okay, well, what standards are relevant to ASHTO accreditation? Uh, what type of facilities are appropriate for ASHTO accreditation? What personnel or equipment are involved in the assessment for ASHTO accreditation? Um, and then what, and then it goes into a deep dive into those personnel uh qualifications. So that's where we get into this offshoot that is going to be this other policy and guidance document about okay, who needs to work there or what arrangements can exist. Um right now, the only uh the only person it says has to be a full-time uh employee of the laboratory is the technical director or manager. But the the typical scenario is that all the people that work there actually work there. Uh, but but you'll get into more details. And and it this will require uh before I said no changes take place without going through some approval process. I am going to have to link to that new policy and guidance document. So a change like that, I'm not gonna run through anybody uh because all it is is connecting the dots between these two documents, and I'm considering that to be an editorial change. But but now we're gonna get into something that got really specific.
SPEAKER_01:Okay, good.
SPEAKER_00:And this this was in the spirit, completely in the spirit of transparency. And I know some people are gonna say, okay, that makes sense. And some people are gonna be like, this is outrageous. How how dare you, how dare you tell me what I can and can't do? Uh, but but keep in mind this is for Ashto accreditation. This is not saying that every company in the world has to operate this way. This is just saying if you're gonna get accredited through us, this applies to you. Okay, so a lot of times people have multi-site personnel. Uh and those situations have to be reviewed and approved for Ashto accreditation to be uh maintained. Uh now, one thing we run into sometimes is that uh I'm not gonna say it's a shortage of PEs because I don't think it's truly a shortage of PEs out there, but it is a shortage of people wanting to employ PEs as full-time managers at different locations. Uh so often you will have uh a PE technical director that is a PE is a professional engineer uh that is overseeing or directing uh more than one facility. Okay. Uh, and we do have a form, we make them fill out and it gets evaluated, and we figure out okay, is this is this plausible that they could provide effective technical direction being spread this thin? Um what we've learned over time is there are certainly limits to how many facilities one person can manage without things falling apart. And what we've done is we've identified uh no more than five facilities in the astral accreditation program. Uh, five is even a lot. I think that's kind of pushing it. Uh, but we have found situations with small scope laboratories where that's doable. Um if you're a large scope laboratory, you're probably not going to be very effective uh in trying to maintain or manage that many facilities with one person. So I would not recommend it. And uh there is a everything, well, everything is kind of based on it, does it work or not? So there is a limit, but then it says that uh, you know, these situations are all based on how effective this situation is. And if it's found to be not effective, then the approval can be removed.
SPEAKER_01:And just for if those following along, this is in uh section 4.9.2 is where this is specifically in in the Ash Ashto accreditation procedures manual. Um, so the off-site and multi-site personnel is section 4.9, but 4.9.2 gets into what uh we're talking about right now.
SPEAKER_00:Right. Thank you. And the other one on there in 492 that is different is it it's a supervising supervisory and testing personnel may be approved to perform testing in multiple accredited laboratory locations if those laboratories are less than 100 miles apart. Now, is 100 miles arbitrary? Somewhat. I'm not gonna lie. There had to be, we're trying to figure out what's a reasonable distance for somebody to travel to work. Uh, and I know that there are exceptions for certain situations. I know that the country is very big and situations can be different. So if you are in a situation that is different than that, you would have to uh send us an explanation and we'd have to review it. But this is saying, okay, these situations may be approved. Um, it also says, though, this is a very important caveat testing personnel shall not perform the same practice or test method during an on-site assessment for more than one location of an accredited laboratory during the same assessment tour. So, what that says is we can't have one person go around the like, let's say you have this great technician, and you're gonna say, well, we don't want our real technicians running the test there because they're not as good as this technician. So we're gonna have this technician go around all the sites and get them all approved, and then we're gonna go back to business as usual. So we don't allow that to happen.
SPEAKER_01:So you can't have a ringer of sorts.
SPEAKER_00:I cannot have a ringer. That's right. Gotcha.
SPEAKER_01:Now, what if they actually do work at multiple laboratories, though?
SPEAKER_00:We do have that situation. So uh this is very common in the world of hot mix asphalt plants, where they'll have multiple plants in the in a in a region, and they'll have the same crew kind of go uh to from plant to plant and run tests whenever there's a project active and that plant's firing up to be operating. Uh, so what we do in those situations is we'll say, okay, that that's that's what you've got going on. Uh just mix it up during the onset assessment. So have this technician run these tests, have the this technician run these other tests, and just don't have them do the same ones during a tour. That that's worked out really well. Uh so that that has that has proven to be a uh possibility.
SPEAKER_01:So it's running the same exact test. Yeah, not that general. Okay, okay. That makes sense.
SPEAKER_00:And it's really to avoid a ringer situation.
SPEAKER_01:So if you only have one one person, one technician, that's your laboratory. And that one position goes. Is that a thing? Why am I making this more complicated?
SPEAKER_00:This is how this is why it's hard to write a policy. It is because you have to think about all these different scenarios. And really, if there is not it, let's say we run into that situation, yeah, uh, then we'll have to update our policy and guidance document and address it based on whatever the decision is from the ATG. But you know, we we have um we we also have to address situations like seasonal laboratories uh that certainly exist in places like Alaska and the the more northern climates where you don't really have a construction season in the winter. Uh so in the policy and guidance document on personnel, we try to address that.
SPEAKER_01:But the changes currently made currently that have been made, are there any currently accredited or astro-accredited laboratories that are not following the change, like they're not following the changes and that they are gonna lose their accreditation because of these changes, or is it just incorporating what's already into practice and providing clarity and transparency around that?
SPEAKER_00:Uh the latter is is what the intent is. So I'm not gonna say, I can't say with 100% certainty that there is not a laboratory out there that is violating these things, these requirements, without our recognition of that deviation from the policy as written. So as we run into those scenarios, we will have to address them. So the way we'll address them is one of two ways, right? Uh we'll present the situation to the ATG. If the ATG says, well, that should have never been approved, then we'll say, okay, well, guess what? Uh, you're gonna have to change the way you're operating if you want to stay accredited. Uh, however, if the situation is presented to the ATG and they say, Oh, yeah, that's that's fine, that should be approved, then we'll have to address that in our policy and guidance document to make it stated so that that is permissible.
SPEAKER_01:So there's is there ever, I guess, just a one-off exception that it is just for one specific laboratory and it will never be applied to anywhere else, that you don't necessarily need to make a change. Or once you make it for one laboratory, then that has to be available to all laboratories.
SPEAKER_00:That you know, that's the spirit of of transparency is to not have one-offs anymore, right?
SPEAKER_02:Okay.
SPEAKER_00:Is like what our objective is in being this transparent is to say, hey, this situation was approved in this case. If your situation is similar, it can be approved in your case too. Um, but without presenting that, so like I I think as we as we uh develop these policy and guidance documents to describe all these scenarios, uh, they're gonna get pretty specific, right? Because not not all situations are going to be exactly the same, even if the basic requirements or the let's say the basic uh arrangement without asking too many questions appear to be the same. But then you find out, oh, well, in this scenario, this specific scenario, this is reasonable, but in this other specific scenario, that is not reasonable. So, like the I think that the policy and guidance document is going to be very long in a year compared to what it is now, because once we start uh encountering scenarios that we didn't define, uh our intention is to define them. A lot of times people Are very nervous, not just because it's hard to do, but then they feel like, oh, now I'm on the hook for all these arguments that people are going to make about, well, why not this and why not this? And and is it a pain? Yes, it is a pain, but I think the fairness is more important than the hassle that that you get from adjudicating all these different scenarios. At least that's that's our intention with this. So I don't know. We'll we'll see how it goes. Uh whoever, whoever comes after me may say, this guy is an idiot. Why did he get this specific about everything? We need to peel it back.
SPEAKER_01:Yeah.
SPEAKER_00:And go back to just general requirements and then just have a bunch of uh exceptions to the rules, which I I'm not a big fan of exceptions to rules. And yeah, and I'm not a fan of grandfathering. You know, you were asking about that question earlier. I am a very uh I am very much opposed to the concept of grandfathering. When you when you make a policy change, uh you should assume that people can adjust to whatever that change is, uh, because these are not things, these are not uh uh these testing firms are not monuments. And and and really our program is not a monument either. Like we can we can change with the times and we can make adjustments with the times. Uh and and it's I think it's just really important to do that and to be able to adjust uh uh with the with the change in the the operational climate that you're in. We're not doing this to save time because it's not gonna save time. Um, but I I think it's just helpful for everybody to know what the rules are going in uh and to have them be clear and unambiguous, at least as much as possible. I mean, there's always gonna be weird scenarios out there that we haven't accounted for, but um we we tried. I guess that's that's all I could say is we tried we tried our best, yeah. We tried our best, and and if it's not good enough, we'll we'll try to make some adjustments. Um okay, so the last complication with this is terminology. So when I balloted the um the personnel uh policy and guidance document, there are all kinds of terms like contractor, subcontractor, consultant. Uh some people consider everybody, like if you talk to DOT people, a lot of times like everybody who's not them is a consultant. Whether they're on a contract or they're a subcontractor or they're an actual consultant, they're all put in the consultant bucket. But I differentiate those. So I think what I'm gonna have to do is put a terminology section to define those terms so that we can even have more clarity.
SPEAKER_01:Yeah, I think that that is definitely an option uh improvement opportunity because it I yeah, I can see that getting really muddled and people not using and not even using the right term, just consistently using the terms when talking about those different situations in regards to Ashto accreditation. Right. So is that right or wrong, just consistently labeling them? I think it will be helpful.
SPEAKER_00:Yeah, and and just for those of you who are out there who who may not like what I'm saying, just just know that we are very reasonable over here and we're always up for making changes and improvements to to improve things. So uh or to to be more clear or uh be more transparent or be more fair or um whatever, whatever you're looking for, let us know, and we can tell you if it's uh reasonable and can be considered to be acceptable or not. Next thing I want to talk about is laboratory identification and ownership. Uh this this has been expanded over the years, and uh a lot of it is because there's been so much consolidation going on with a lot of the materials testing firms. Uh so we've learned a lot about ownership and and naming conventions. So we tried to explain those in more detail. Uh, and we have a lengthy policy and guidance document that's linked in there as well. One, oh, you know what I forgot to talk about?
SPEAKER_01:What?
SPEAKER_00:This is another big thing. So I know a lot of times when when there are changes made, people think, oh God, what are you gonna do to us now? What what new requirements are you levying on our laboratories? Well, I have good news for you. Sometimes we actually remove requirements. Yeah, and this is one of those situations. So years ago, uh there was a requirement for room temperature added to the app procedures manual, and this requirement had been uh met with either cheers or boos, depending on where you live and uh what kind of facility you have. Uh, but we were pretty strict about the requirements, and now the wording is a little different and it allows more uh consideration for different laboratory situations. So uh what it says now is that the laboratory temperature is to be maintained at a uh consistent temperature that allows for proper performance of testing uh based on all the standards that you're accredited for. Uh and and that temperature range is still uh 60 to 85 Fahrenheit. Uh but it it's written in such a way that it it tells you that the evaluation or judgment of conformance is based on how much it impacts the testing. And that can be indicated quite a few different ways, like sometimes during the assessment. Uh, but sometimes it's through uh poor results on proficiency samples, or maybe it's from complaints, or it it could be it could be a number of ways that we find out that there are problems at that facility. But there is, I guess, a little bit more allowance for different types of facilities. Uh, there is even a very specific allowance for deviation for uh sulfur capping stations, which a lot of people have kind of moved away from. But when they do have to cap, they put it on a cart and they'll put it in an uh outside area. Uh uh sometimes large mechanical shakers and LA abrasion machines, uh, which are very loud, uh, are put in uh containers outside of the normal laboratory operating area because of the noise problems and the dust that they create. Uh so there are specific allowances for deviations for those as well.
SPEAKER_01:And what section is that in if people are following along?
SPEAKER_00:You will find that in section 3.4.5. Now, the one question I know we're gonna get is so does that mean that we don't have to care about that anymore? Um, that it is not what that means. Uh, you really should be operating within these uh these parameters as a testing laboratory because you are gonna run into problems with maintaining bath temperatures, oven temperatures, uh competency of your technicians operating in extreme cold or extreme heat. Uh and really it is based on uh their the quality of testing. This is not a uh Ashto trying to dip their toes into OSHA space. Uh and I know that's that's been an accusation that that we've gotten with this requirement. It's just assumed that you're a normal uh business that has a operating temperature that facilitates the proper performance of these tests. Uh that's that's really what what we're after with those requirements. But you can read uh section 3.4.5 and see how that impacts your laboratory.
SPEAKER_01:All right. Thank you for being specific on that because I was trying to skim very quickly and couldn't find it. So when I was looking at the document.
SPEAKER_00:I skipped over that one earlier, and and that it is an important one to pay attention to because I know some laboratories have really struggled with that. Uh there are some laboratories that really are not even trying, though, and and I think it's it'll it'll be revealing in their their test results. So I I don't I don't think it is smart to just ignore that completely. Uh other other things, uh, we get into proficiency testing requirements. I talked before about not having a ringer for laboratory assessments. You also can't have a ringer for proficiency samples. So we specifically have that written into the requirements that you cannot have the same person uh performing proficiency samples and and reporting the results for multiple locations. So uh that that would be another one, you know, you asked about potentially, okay, well, what if there's only one person? Well, we'll have to we'll have to cross that bridge when we get to it. I'm not sure if we have any of those situations currently in the program. I know years ago we did. I'm not sure if they exist, but if they do exist, they'll have to uh reach out to us and and we'll have to get that reviewed. But that is one of those really tricky ones where if I were to put that in the policy and guidance document, it'll have to be very specific about why that was allowed. Um, because if we just say, oh yeah, yeah, it's no problem, then we're gonna have uh, you know, one company with 50 locations submitting one round of PSP data for the entire organization, which would not be allowed. Other things we get into corrective actions for proficiency samples, assessments, accreditation decisions.
SPEAKER_01:Those were all in there before, though, right?
SPEAKER_00:They were all in there before. It's just laid out in a more logical order now. It talks about you know suspension, revocation, temporary facilities, mobile laboratories, confidentiality, um, refusal of service, and how do you advertise your accreditation? What's a certificate look like? Where's a you know a link to the directory, which is a nice thing to have? Uh so that so that that's pretty much it. That's that takes you through the whole manual.
SPEAKER_01:The whole manual. Now, did anybody specify or local government this something say section? You have like reference the old numbering system of the procedures manual where they will then have to update it based on the new one. Or is that not a thing?
SPEAKER_00:No, that's probably a thing. That's probably a thing. Okay. Uh that is that is probably something that people will be doing.
SPEAKER_02:Okay.
SPEAKER_00:Is if they're referring specifically to sections, they will have to update those references. Now, I'm not really aware of too much of that.
SPEAKER_02:Yeah.
SPEAKER_00:Uh, however, for R18, that definitely is a thing.
SPEAKER_02:Yeah.
SPEAKER_00:So, like people have designed their entire quality management systems around the numbering in R18. So that was that was another thing that was difficult. I was trying very hard not to change the sections too drastically because I know how much heartache that will bring to people who have to deal with the changes on the back end.
SPEAKER_01:Yeah.
SPEAKER_00:So we do think about those things when we when we ballot. Trying to be somewhat thoughtful.
SPEAKER_01:So if your organization did reference the old app procedures manual prior to September 17th, 2025, um, any numbers or sections in that will be need to be update updated in whatever format is needed. I'm just gonna throw that out there then. Uh is there anything else that was new for this that's like brand new and not just the reorganization?
SPEAKER_00:There's a really great diagram that I made that shows what Ashto resource does and what CCRL does. I've presented I've presented with this diagram before, and I see all these uh acknowledgments in the audience, like, oh now I get it. And so I I said, okay, this needs to go in the procedures manual because it seems to it seems to make sense to people. And that's figure one in the uh procedures manual.
SPEAKER_01:Before we go, and uh I want to let everybody know uh that we are have recorded and this will be published this episode in October. So that means that if you're listening to it when it first comes out, you have time to register for the virtual technical exchange happening uh November 5th and 6th. And if you go to ashtoresource.org slash events and you will have information there. Also, there's information about the 2026 Ashto Resource Technical Exchange in person, and that will be March 9th through 12th in Louisville, Kentucky. Thanks for listening to Ashto Resource QA. If you'd like to be a guest or just submit a question, send us an email at podcast at ashto resource.org. Or call Brian at two four zero four three six four eight two oh. For other news and related content, check out Ashto Resources' social media accounts or go to Ashto Resource dot org.