AASHTO re:source Q & A Podcast
AASHTO re:source Q & A Podcast
Unlocking Section 3.5 of the AASHTO Accreditation Procedures Manual, Part 2
In the final part of this series, uncover the essential subsections of Section 3.5 of the AASHTO Accreditation Procedures Manual. Our exploration reveals the significance of independence of judgment, the importance of transparency in conflict scenarios, and how demonstrated job performance can outweigh formal education in personnel qualifications. Discover the historical context and evolution of temperature guidelines and learn how labs can navigate unexpected challenges, like seasonal shutdowns while maintaining accreditation. The conversation also spotlights the need for clear definitions and the role of standards development organizations in addressing ambiguities.
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 AASHTO Resource Q&A. 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 2:Welcome to AASHTO Resource Q&A. I'm Brian Johnson.
Speaker 1:And I'm Kim Swanson and we are continuing our discussion today in part two of the section 3.5 of the AASHTO Accreditation Program Manual. So if you didn't listen to the first part, I encourage you to go back, because you go through all the background of what the procedure manual is and how it's approved and all that fun stuff. But I think we're going to just dive right in to this next one. What do you think?
Speaker 2:I think that's a good idea, and I'm sure people just could not wait for part two. Oh, of course. So the wait is over. Yes, I know you have to continue the conversation.
Speaker 1:Unbated breath, I'm sure. So, yes, so picking up where we left off. If I recall correctly, we will be at, and I know this one has your favorite words in it, but it is section 3.5.8. And it says the laboratory shall be organized in such a way that confidence in its independence of judgment, integrity and impartiality is maintained at all times. And those are like all of your favorite words, brian.
Speaker 2:They are, they are. That sentence has it all. Confidence judgment, integrity, impartiality.
Speaker 1:Some of my favorite words, All of those things. So let's dive into like that what that actually means.
Speaker 2:Yeah, and this definitely falls under the category of. I want this one in my back pocket, because if we have an issue with integrity, falsification of records, I'd say there's also conflicts of interest. So we do have from time to time, issues where a laboratory may be have they may have some built in conflicts of interest. So like, let's say, it's a supposed to be an independent or third party testing lab, but they're owned by the company that produces the material that is supposed to have the impartial testing performed on it. That is a conflict of interest. Now, conflict of interest is inherently problematic, but it does have to be recognized and dealt with. So if there is a situation where a conflict of interest exists, laboratory has to be really careful to explain what that is, how they mitigate it, what is the situation that exists where the conflict of interest is remedied. And if they can't do that, then that's a problem. And that is also one of those things I'd want to bring to our oversight committee to see if they agree, before we just say, no, you can't be accredited.
Speaker 1:But we have had labs that we've refused accreditation because of conflicts of interest and integrity problems.
Speaker 2:Hopefully few and far between. Yeah, that would be great and I would love to have no more of those if we could, but I know that that's not possible. But we will deal with them as we find them. Next one personnel shall have necessary education, training, technical knowledge and experience for their assigned functions. Super subjective on that one as well. But I think the technical knowledge and experience, it is shown by performance right.
Speaker 1:Yeah, can you do your job?
Speaker 2:If you can do your job, then great. I think education has been a real tough one for us over the years because there are requirements for biographical sketches, for example in R18, to include educational experience. Some people don't really have a lot of education. That may be because of circumstances, that they're dealt with right.
Speaker 1:Yeah, formal education, you mean.
Speaker 2:Formal yes, formal education, and it doesn't necessarily indicate that their job performance is going to be impaired in any way. So I think that you know, if I were to be able to make a unilateral decision on that, they don't view that as something that doesn't make or break them. You know that doesn't define them, so they don't really want to put that on there, and I kind of agree with that If they're doing a good job. And I mean, what does it matter for accreditation if they put that on their biographical sketch or not?
Speaker 1:Yeah, I would say, in this scenario, education and training are kind of synonymous, where, because you're like, are you trained to do it, like, do you have the knowledge to do it? That's all we care about for the most part. Right, that's right. So I don't know, maybe it's just the definition of education as well.
Speaker 2:Yeah, that is true, because there's all kinds of education.
Speaker 1:Yes, there definitely is. So are we going in order of all of these? I didn't know if we were going in specific order we were.
Speaker 2:I was going to skip around, but we're kind of plowing through it.
Speaker 1:Yeah, okay, so we're at 3.5 points Okay.
Speaker 2:I think I'm going to jump over. Okay, good.
Speaker 2:I'm going to skip a couple Well, I'm not. One is about reporting results accurately, objectively and without bias. That's more of what we already talked about. A good laboratory has to have good organizational practices and have good housekeeping, so that's one of those. You know, if we go to a laboratory that's just trashed and not well maintained and it affects their testing, then that could be something we would write. Workload has to be consistent with their equipment. I think that has a couple aspects of it, some just about having appropriate equipment to handle the workload, which we wouldn't be able to tell. But also if they were trying to be accredited for something that they don't even have the equipment of. We wouldn't want that. So I think that would fall into that category, and just under the test method.
Speaker 1:Yeah, yeah, could they?
Speaker 2:you know, I said that you, yeah, yeah, you would think. They would say how could I get accredited for this?
Speaker 1:I don't even have the equipment and yet people try something well, I mean in my head it's like let them pay for that, to be assessed on that, but they're not going to get accredited without no, they won't, they won't so like why does it like anyway go?
Speaker 2:ahead. Great question. That's a great question.
Speaker 2:I wish I had the answer to it I think sometimes people, uh, they plan to have things before a certain date and they just don't show up on time and like that can be an impairment, but that's not really indicative of their problem. Yeah, it's just that they got ahead of themselves. But the fact remains we have to come back when you have it, because we can't really watch you do something with nothing. Yeah, we've also had people say can I just rent everything? And no, you can't, like we, you want to be accredited. You have to be an actual testing laboratory with equipment and personnel and all of that stuff.
Speaker 1:It would never even occur to me to ask if I could just rent the equipment.
Speaker 2:Yeah, some people, they have this idea that this is a real chicken egg problem. You know like I have to be accredited before I can do any work. You know like I have to be accredited before I can do any work. So can you just accredit me based on my intentions? And no, we cannot. So I mean, even if you have to do work that's not accredited, work until you get your feet wet.
Speaker 2:And in certain areas where I think that the specifying agencies really have to understand that you can't just automatically snap your fingers and get accredited, some of the airport authorities kind of struggle with this, where they'll have a contract and they might have like a multi-year contract to work on airport facilities and they'll say, okay, well, this person won the contract.
Speaker 2:We expect on day one for them to move in and be accredited. But it can't work that way. So while they're moving in, while they're transitioning staff, while they're doing all these things, they can't all, they can't have us there while that's all happening. So they have to get set up, kind of work out the bugs and make sure everything's operating properly. Then they can get their assessment and then it takes time for them to resolve issues and then they get accredited. So what would be appropriate for those agencies is to give a certain time frame in which the laboratory can obtain the accreditation once they take hold of that contract. Next one that we're going to talk about is labs have to pay all the fees for services. That's pretty obvious, but it is a requirement because we aren't going to just accredit without people paying for the services.
Speaker 2:And that is, does that include not just the accreditation invoices from AASHTO Resource? Or yeah, from AASHTO Resource, right? So whoever provides their assessments or proficiency samples, if it leads to AASHTO accreditation, they have to fulfill their obligation to pay those bills as well, Because if they can not continue to receive those services, then they can't maintain their accreditation.
Speaker 1:Going on. The next one I'm seeing has multiple parts. The other ones were pretty straightforward and so let's dive into 3.5.14.
Speaker 2:Okay, 3.5.14 is the last section in this, the last subsection in this section, and it says for those test methods for which the laboratory is seeking accreditation, laboratory has to maintain facilities for proper control of the laboratory environment. Laboratory has to maintain facilities for storage, handling and conditioning of test specimens and samples. Laboratory has to maintain necessary calibration equipment and reference standards. So that would be like if you standardize your own ovens and bath temperatures and thermometers, you'd have to have a reference thermometer, for example. Laboratory has to maintain facilities and equipment conforming to specification requirements necessary for testing. So that we're getting into a lot of like r18 app procedures manual crossover here that's what I was actually just thinking of.
Speaker 1:Why is this in the procedures manual and not in an actual standard?
Speaker 2:that is a good question and I think some of this stuff could get get removed, uh, from the app procedures manual, uh. The next one is the one that has created and this was kind of the cause of the disruption for this particular customer that kind of prompted this corrective action episode, and it is that the laboratory has to have test areas, energy sources, lighting, heating, cooling and ventilation necessary to facilitate performance of tests. And then it says the testing environment when workers are present in normally occupied spaces inside facilities fixed, mobile or temporary shall be maintained at 60 to 85 degrees Celsius.
Speaker 1:Question about that real quick.
Speaker 2:Yes.
Speaker 1:How was that range determined the 60 to 80 fahrenheit?
Speaker 2:so the original ballot for this item uh did include. So the original text had heating but not cooling in it. So that ballot item included cooling and then it also added this idea of what a reasonable laboratory temperature would be. The reason is because we have heating and cooling but really no parameters, so it's kind of hard to tell what you're even talking about there. Yeah, and I went back and looked at the actual valid item and it just vaguely said that this is recommended temperature range for a professional laboratory setting. That should be able.
Speaker 2:You know that that's kind of the end of the rationale, but the idea is that a laboratory that maintains this I mean this is a wide range, 60, 85c should be able to control temperatures for all the tests that are in our program. So like, let's say, they have a bath that maintains a certain temperature this is not going to be too high or too low from what's expected in there, whereby they couldn't achieve that temperature. But the thought is, if they start getting too far beyond like below 60 or above 85, starts getting harder to maintain those temperatures for tests, um, I would say materials might not act the way they're supposed to act, especially if you've got any sort of viscosity testing going on well, yeah, and temperature is such an important part of the testing, like in so many tests, like they require, like there's it's temperature specific of like.
Speaker 1:So it makes sense to me that the room should be, you know, not too far out of those. You know, like, make it possible to run those tests within those temperatures. But also, just selfishly, as a worker, I would not want to work in a building not too far out of those. You know, like, make it possible to run those tests within those temperatures. But also, just selfishly, as a worker, I would not want to work in a building that was only 60 degrees. I could be just my warm blood not wanting that cold air.
Speaker 1:But also 85, you know 85, I don't want to work in it. I'm going to say my, my dexterity is going to be different in all of those situations, at the extremes as well.
Speaker 2:So Absolutely so. So what I explained to this person is that equipment, materials and people are not necessarily going to operate according to the standard. Uh, when you start getting into extreme temperatures, and that's extreme heat and extreme cold, um, the dexterity thing I think takes it. It really shows that the temperatures that are cold oh yeah uh, and we've seen it.
Speaker 2:We have had laboratories try to get accredited.
Speaker 2:They do not have any temperature controls and it is just too cold, uh, and you and you see it, because they can't run the tests, yeah, but for for them to, let let's say, we didn't have any requirement like this and they somehow were able to cobble together things that one time for the two days and two to three years to be able to get the temperatures right, I don't have a lot of confidence if they don't really have any controls whatsoever.
Speaker 2:I don't have a lot of confidence, as the accreditation body, that they're going to keep up with this when we're not there on top of them. So we really need to make sure that, as the accrediting body, we have confidence that the laboratories are going to be able to keep up with everything you know, maintain all the tests, demonstrations or performance, the way that they're supposed to be carried out in standards, and it really, if we don't have the confidence in that, then the laboratory might not qualify for accreditation. So this laboratory temperature range, you know, while I would say it, you know, justly has some questions about. You know, like you're asking, like, where do these temperatures come from? Right, there wasn't an independent laboratory study to determine when dexterity starts to falter or when the material you know, every material that's in our program starts to
Speaker 2:change its viscosity or or or you know starts to fall apart. You know there was. There was not a study done like that, so I don't have any numbers for people on that and I. But I would also argue that at being in standards development this long, just about everything starts out as an arbitrary number. People pick a number and it works, and they go with it, and then other things build on that. They get years of data showing that, yes, that was the right temperature. Maybe it was wrong, so let's ballot a change. So that happens too.
Speaker 2:So I don't want people to get too bent out of shape about maybe 60 wasn't the right number for the low, maybe 60 wasn't the right number for the low, maybe 85 wasn't the right number for the high. But I will tell you one thing that the other question that comes out of this one that I think is a good one is why does it say when workers are present in normally occupied spaces? Is that? You know, one of the questions that we get is like why does ashto have like an osha requirement in here about workers? And I want to tell people where that came from. It is not an osha safety type requirement. The original ballot didn't have anything about that wording in it, it was just all the time should be those temperatures. Now one of the voters that submitted comments it was a negative on this said you know that there isn't always testing going on you know in evenings and weekends, holidays, there are times when there's no testing.
Speaker 2:So, you know, does it make sense to make laboratories expend the cost of maintaining those temperatures when nothing is going on? You know, presuming that cylinder curing is still maintained according to, you know, c511, m201 requirements, whatever other requirements for conditioning may exist, but if there's nothing going on, do they still have to maintain that? Might be better to allow that, you know, some allowance for that when there's no work going on. So that is where that when workers are present language came from. So I want to make that very clear that it is not a OSHA safety requirement.
Speaker 1:So is this one of the things, if we go back to the very beginning of the conversation in section 3.5.1, that if a laboratory's HVAC or heating and cooling capabilities go kaput, or that they are, you know their air conditioner breaks that they have to let their quality analysts know within 60 days.
Speaker 2:Yeah, I mean according to that section. Yes, they should notify us if there's any significant change in their capabilities of testing. Where this can be advantageous to the laboratory is if they run into a long-term problem. For example, we've had some institutional laboratories that have a hard time maintaining their working environment where they've had to basically go on a long pause and not be able to run tests at all for an extended period of time, and they wanted that to be identified because they were going to miss proficiency samples. They had to postpone an assessment and in this case we actually had to put their accreditation and suspension for a while while they got this all worked out, because it took a lot longer than the 60 day period and that actually allowed them a time to get things right and to be able to document that properly and say you know, we weren't doing work during this time because we were suspended and we asked for this allowance because we couldn't do the work because of our environmental conditions that we were dealing with, and and they were able to tell the agencies that they report to about this and have it all documented and kind of, I guess, make sure that they were shown to do things the right way, which adds to the confidence level of that agency that is overseeing them. So at the end of the day, it worked out for them to be able to do that.
Speaker 2:I know a lot of our laboratories can't just do that. They can't just say, oh, we're going to be out of business for three months and still actually be in business as a business. So I think it probably is less likely to be a long-term situation for a place like that. You know, small business, they usually jump on it right away and they don't have the complications that a large institution might have.
Speaker 1:I know there's a lot of, you know, seasonal fluctuation in temperatures where perhaps you know in winter that is not a problem with the maintaining those temperatures, but in summer it might be a real problem. And is there any allowance for that, or what do we do in those situations?
Speaker 2:There isn't. I mean, if they're operating, they're expected to adhere to these requirements. One thing I would say that we don't do and I think this is kind of what your question kind of triggered this thought in my head is that there are labs in the northern United States that just shut down in the winter, particularly if they're producing asphalt mixtures. There's no paving going on that time of year. Where they are, they're snowed in, people are laid off in some cases or they're doing other jobs during that time period and we have not required them to get suspended in those cases because they're not operating. And I'm torn on that because, while I think it might make sense, I think that it would have to be some other name for it other than suspension, like a seasonal shutdown.
Speaker 2:Yeah, because no one in that area is operating, so it's not really like competitors are really taking advantage of taking advantage of this at that point, like it doesn't really impact anything. But I also wouldn't want them to not be able to bid on contracts for the spring, when they are going to be operating, because they're just shut down and everybody's shut down. But I think it would be good if we could address that somehow. I don't know exactly what that would look like at this point, though.
Speaker 1:So is there anything else about that 3.5.14e that we want to talk about anymore, or should we go on? Because I know this section subsection of this section goes down to I, I believe, and we're at E.
Speaker 2:So what else it does. It does. They're just more about, you know, work environment. You know testing environment has to not adversely affect the test results. They have to monitor, control and record environmental conditions as appropriate. They have to demonstrate the capability of performing tests in accordance with the current version of the test specifications. That's kind of another one that I'm not sure needs to exist the way it does in here, while we do require that in other places.
Speaker 1:Yeah, isn't that in the literature? Is there not a literature part?
Speaker 2:Not specifically.
Speaker 1:I'm making stuff up, then never mind.
Speaker 2:Yeah, I think there are requirements all over the place about that. The laboratory shall demonstrate adequate care when recording and processing data and test results, and shall demonstrate proper techniques for selecting, identifying, handling, conditioning, storing and retaining test samples A lot there.
Speaker 1:There is, and I'm not going to help the conversation with this, but I'm still going to say it and maybe I'll keep it, maybe I'll delete it. But who's defining adequate, proper, those words Like what is adequate care and what are proper techniques? So I know proper techniques are listed in the standard, and wouldn't that then be the standard and not need a separate thing?
Speaker 2:Yeah, the hard part about some of this is we've got standard requirements. Not all test methods get into the details about selecting, identifying, sometimes handling, not always detailed enough. If there's conditioning, definitely. If there's storage, not usually Retention almost never are addressed. So there's a lot of things that just aren't addressed in test methods.
Speaker 2:And actually, excuse me, back to that laboratory temperature thing that's almost never defined in the test method and, as you know, I'm involved in ASTM and AASHTO standards development activities and when we were going through this this I did talk to other people in standards development. I said you know, one of the things that people are asking me is why doesn't it say it in the test method? Like why almost no test method says what the room temperature is supposed to be? And most of the answers I got were well, it's just assumed it's a laboratory and it's a controlled environment. I'm like that, that's what I thought.
Speaker 2:But that doesn't help because people are telling, like I have some people saying we have no business defining temperature controls and you're saying you don't need to define them because they're understood. But clearly they're not understood because somebody is disagreeing with 60 to 85 as being reasonable, because somebody's disagreeing with 60 to 85 as being reasonable. So I think that what would be good is if a lot of these standards development organizations, subcommittee members, would look at these things and say, well, if they do care about it, put it in there. But I don't think anybody is correct in saying the absence of a statement means that no one cares about it. It's just that it was an incorrect assumption, made collectively.
Speaker 2:I would say, by a lot of people.
Speaker 1:All right, well, this was a very long discussion, as you said, but do you think that we have met the corrective action? Do you think this is part, this part of it? Okay, so I did talk to our staff.
Speaker 2:Yeah, there's more to it. I think we have more more talking to do to other people on staff, to CCRL staff, and the last part of my corrective action is actually to take the recommendation from the complaint and go to our oversight committee with it. So what I want to do is present this in a fair, unbiased way. So I'm going to just take the information and I'm going to say, okay, we had a complaint about this. This person would like to see a change to the ad procedures manual. What do you think change the ad procedures manual? What do you think? And based on the result of that discussion, I will follow up and ballot. If there's a change needed, we'll ballot it and see where it goes. But you know I can't emphasize enough how important it is for us to be transparent and how much we actually do care about feedback and we do want to make changes where it is appropriate to make them, and that we will do it in an unbiased way. Does that sound good?
Speaker 1:That sounds good to me and I did want to put a plug in as we're preparing for our annual technical exchange that's coming up in March 17th through the 20th 2025 in Bellevue, washington, and I will say, as of the recording of this episode, there is a draft agenda on our website that is ashtoresourceorg slash events to check out that, and it has some registration information as well is now available.
Speaker 2:Sounds good. I hope we see you there.
Speaker 1:Thanks for listening to AASHTO Resource Q&A. If you'd like to be a guest or just submit a question, send us an email at podcast at aashtoresourceorg, or call Brian at 240-436-4820. For other news and related content, check out AASHTO Resources social media accounts or go to aashtoresourceorg.