AI summary of Chain of Custody from Duck Duck Go: "Chain of custody refers to the process of maintaining and documenting the handling of evidence in legal cases, ensuring that it remains untampered and authentic from collection to presentation in court. This documentation is crucial for the evidence to be accepted in legal proceedings, as any breaks in the chain can lead to questions about its integrity."

An interview with Mr. Derek Herb (Hawk Mountains Labs, Hazelton, Pennsylvania)
201 West Clay Avenue, Hazle Township, PA 18202;  Field Sampling for: Environmental (Soil & Water) • Solid Fuel/Coal • Materials/Concrete • Marcellus Shale/Natural Gas • Analysis and Testing • Residential Analysis and Testing for more information contact them at reportsdept@hawkmtnlabs.com or call  570-455-6011.  The responses to the questions listed are responses from Mr. Derek Herb and they are not AI generated or edited. 

Mr. Derek Herb

Hawk Mtn Labs

1. What is Chain of Custody?

 Chain of Custody (CoC) is the documented process that tracks a sample from bottle preparation, to collection, through transport, handling, storage, and analysis. It ensures the integrity, traceability, and legal defensibility of environmental compliance samples by documenting who handled the sample, when, and under what conditions.

2. Is chain of custody only related to collecting the water sample and delivering it to the laboratory?

Chain of custody covers the entire life cycle of the sample, which begins before the sample is even collected.  The bottles used need to have a certificate of analysis (COA) which documents that they are free of contaminants from the manufacturer.  The preservatives and reagents used during bottle preparation and analysis also have a similar COA on file.  Something as simple as 1:1 nitric acid for preservation of metals samples can be traced back to the date it was made in the lab, who made it, the manufacturer and lot number of the stock acid solution, and when it expires.  Bottles that are being used for bacteria analysis have additional requirements that include sterility checks and sodium thiosulfate efficacy on each lot that is received. 

In the field chain of custody can be much more than simple dates, times, and signatures.  For ground water sampling it becomes a log of field readings, water level, and flow rate to show that a well was purged to a steady state before a sample was collected.  For surface water it is used to document field readings and complex flow rate calculations which are required for calculating loading values for permit compliance.  For potable water sampling it is used for documenting field reading such as free & total chlorine, pH, and temperature which are commonly used for Safe Drinking Water Act compliance.

Note from the Know Your H20 Team - we commonly suggest other field monitoring, such as conductivity, temperature, and oxidation reduction potential.

Upon receipt at the lab the chain of custody becomes a record of who is completing temperature and preservation checks on the sample, as well as a “condition upon receipt” for each sample bottle.  It follows the sample through the entire analysis process, including reagents and standards used, quality control data for each method analyzed, to results being reviewed and entered for the creation of a final report.  To put it simply the chain of custody ensures accountability at every step, not just field collection. 

3. Who controls and establishes the Chain of Custody Process?

The laboratory is ultimately responsible for maintaining a proper chain of custody on all samples, as they are the ones accredited and audited by the Department of Environmental Protection. 

4. In Pennsylvania, who or what entities are required to use the chain of custody process?

Everyone!  Whether you are a homeowner collecting a sample of your well water for your own piece of mind or a certified operator running a drinking water treatment plant it is paramount that the chain of custody procedure be followed to ensure accurate and defensible data. 

5. In Pennsylvania, are there any certifications to be a water sampler for the chain of custody process?

There are no certifications per se, but certain compliance samples do require training/instruction from the accredited lab.  One example of this would be samples for volatile organic compound (VOC) analysis.  25 Pa. Code 109.303(d) states that “Compliance monitoring samples for VOCs shall be collected by a person properly trained by a laboratory accredited by the Department to conduct VOC analysis.”  All employees of our lab are trained and signed off on the proper collection procedures, but this also means that we are responsible for training/providing instructions on proper sample collection to anyone that is bringing VOC samples for compliance purposes to our laboratory.

Another example would be samples for NPDES compliance purposes, which requires that samples be collected “by a qualified individual trained in proper procedures.”

These are some very specific examples, but in most cases anyone can collect a sample and follow proper chain of custody procedures with some simple instruction and guidance by the laboratory.     

6. How do you maintain the Chain of Custody when samples are transported using different individuals and what happens if samples are held in a cooler between the sample collector, person transporting the sample, and ultimately the laboratory?

In general, the best practice is to limit the number of individuals possessing any one sample, however sometimes it is unavoidable.  Any time a sample is transferred from one person to another it must be documented on the physical chain of custody form with signatures, dates, and times from both the relinquishing person and the receiving person. 

If samples need to be held in a cooler or refrigerator for a period of time there are some specific requirements to ensure the chain of custody is maintained.  If the sample is not in your physical possession or in your sight it is only considered in your custody if it is secured and tamper-proofed or secured in an area restricted to authorized personnel.  The latter is preferred, but if that is not an option the cooler should be locked or have a tamper proof seal which can be verified upon receipt. 

7. How do you maintain the Chain of Custody when samples are shipped?

Shipping samples brings an additional set of challenges.  Samples should be shipped in a sealed cooler with custody seals.  The chain of custody form should be in a sealed waterproof bag inside the cooler, or inside of the sealed box if your cooler is contained in one.  Always ship using a reliable courier such as UPS, USPS, or FedEx, with tracking of the package.  The lab will confirm that custody seals are intact upon receipt from the shipper.

8. What are the biggest weaknesses in most chain of custody approaches?

One of the biggest issues that we see is incomplete chain of custody forms.  These are often missing signatures, dates, times, or necessary sample information.  This often leads to delays in analysis as we wait for the proper information, and in some cases will mean that we need to reject samples at the lab. 

Another issue that we see often is samples being left in easily accessible locations with no custody seals, with gaps in the custody timeline.  An example of this would be an industry leaving samples in a cooler outside of their facility, at a location that is easily accessible by the courier when they arrive to pick them up.  It’s certainly convenient from the courier’s point of view, but it means that the samples may sit for minutes or hours in the custody of no one. 

9. For certified testing, how long does the laboratory maintain an electronic or hardcopy record of the testing results, QC/QA, and chain of custody records?

Accredited labs in Pennsylvania are required to maintain CoC forms, QA/QC data, and analytical results for at least 5 years (as specified in 25 Pa. Code Chapter 252.)  The exception to this is copper & lead data for compliance samples, which must be kept for a minimum of 12 years. 

10. What is an example of a properly prepared chain of custody form?

A properly prepared chain of custody form should include: 

Unique sample ID, location, date, and time of collection
Sampler’s name and signature
Matrix (potable water, non-potable water, solid)
Requested analyses
 Size, type, and preservative of provided bottles
 Documentation of every custody transfer (signatures, dates, times)
 Cooler seal information (if used)

Samples for Safe Drinking Water Act compliance must also include the following information:

Designation that the sample is to be reported to DEP
PWS ID number and name of system
Name and contact number of the responsible official of the PWS
Sample Location ID number
Description of sample collection location

Sample Type (E, D, C, A, S, R, P, or K)

E – Entry Point (where finished water enters distribution system)
D – Distribution (used for routine distribution tap samples)
C – Check or Confirmation (follow up or confirmation samples taken after an MCL exceedance)
A – Annual Startup (For seasonal system)
S – Special (non-routine investigative sample, or for removal of boil water advisory)
R – Raw (untreated source water)
P – Plant Sample (Taken after treatment but before the entry point, or from a midpoint in the treatment system)
K - 5th liter sample that is associated with the Lead and Copper Rule Improvements (LCRI) and sample that attempts to be associated with the water from the service line for the home and not the faucet or internal plumbing of the home. 

11. What is an example of a poorly prepared chain of custody form and why does this create problems?

Poorly prepared chain of custody forms are often missing the sampler’s signature, sample dates and times, have incomplete transfer records, have wrong or unclear sample IDs, and have illegible handwriting.  All of these issues can potentially invalidate samples for the use of legal or compliance purposes.     

Contact info would be:

Mr. Derek Herb
dherb@hawkmtnlabs.com
reportsdept@hawkmtnlabs.com
570-582-6000

Resources and Related Topics:

Standard Guide for Sample Chain-of-Custody Procedures (ASTM) Designation: D4840 − 99 (Reapproved 2018)  (Go to ASTM Standard Search  and use search terms ASTM D4840-99(2018)e1).

Pennsylvania Drinking Water Noncommunity Water System Public Water Systems

CPSC Warns Consumers to Stop Using Certain Chinese-Made Faucets Sold on Amazon.com

NSF Standards for Point of Use, Point of Entry Water Treatment Systems, and Recreational Vehicles

 Lead Contamination of Public Water Systems (Training Course)

 Drinking Water Quality - Monitoring & Security (Training Course)

Basics of Water Resources: Groundwater Hydrology (Training Course)