Although Innovatech Labs doesn’t specialize in Fourier Transform Infrared Spectroscopy (FTIR) testing for emissions, this type of FTIR analysis has been getting quite a bit of news lately because state and federal emissions and air quality compliance rely on the results of FTIR testing to measure environmental air quality. While Fourier Transform Infrared (FTIR) technology is a powerful tool, it can involve a number of drawbacks. Obtaining air quality data that can withstand legal scrutiny requires significant expertise and an impeccable quality control system not unlike the chain of command for evidence held over in a criminal case.
Reasons for Compromised Data
You want to be certain the analytical lab you choose follows the EPA Test Method 320 and provides complete and thorough technical documentation. Common deficiencies that can compromise the validity of your source test may include:
- Misidentified spectral interferants
- Missing or incomplete EPA Method 301 validations
- Failure to apply systematic bias factors from 301 validations
- Failure to prove both transport and analysis of soluble and reactive compounds
- Lack of documented spectral backgrounds
- Improper or missing documentation of detector linearity, system noise and leak checks
- Lack of documentation of tracer gases or mass flow controllers used for dynamic spiking
If you represent a business which has been cited for emissions violations, then you’re going to need to defend those results in court. When you combine the law with science, however, you’ve just added a layer of complexity uncommon in most courtrooms.
You want analysts experienced with numerous source types, who can add meaning to the emissions measurements gathered.
Your legal team should include a chemist or chemists with experience in Stack Testing, FTIR Spectroscopy, CEMS Services, Industrial Hygiene Monitoring, Air Dispersion Modeling and/or Mercury Monitoring. More importantly, you need that person to be able to explain complex chemical concepts in terms that lay persons can understand.
Your vetted expert should be able to assess the strengths and weaknesses of evidence or the prosecution’s experts’ testimony. You want an expert opinion on the validity of the work performed. When lawyers defend microscopic measurements, you want a strong opinion on the validity of current work, whether the most appropriate method was used, potential sources of error and any other factors that might affect the suitability of data for use as evidence.
In other words, you want to be sure your expert testifies with confidence and precision, and that he’s more qualified than the other guy.
There’s no substitute for experience when providing FTIR-based emissions tests.