a

U.S. GEOLOGICAL SURVEY CIRCULAR 1138

Chain of Custody—Recommendations forAcceptance and Analysis of EvidentiaryGeochemical Samples

CIRC. 1138

Chain of Custody—Recommendations for Acceptance and Analysis of Evidentiary Geochemical Samples

By

Christine Murphy, Paul Briggs, Betty Adrian, Steve Wilson, Phil Hageman,

and

Pete Theodorakos

U.S. GEOLOGICAL SURVEY CIRCULAR 1138

Mineral Resource Survey Program Committee reportdetailing the guidelines for acceptance and handlingof evidentiary geochemical samples

UNITED STATES GOVERNMENT PRINTING OFFICE, WASHINGTON : 1997

a

M A R C H 3, 1849U

.S.

DE

PARTMENT OF THE

INTER

IOR

Free on application to U.S. Geological Survey, Information ServicesBox 25286, Federal Center

Denver, CO 80225

Any use of trade, product, or firm names in this publication is for descriptive purposes only anddoes not imply endorsement by the U.S. Government

Library of Congress Cataloging-in-Publication Data

U.S. DEPARTMENT OF THE INTERIOR

BRUCE BABBITT, Secretary

U.S. GEOLOGICAL SURVEY

Gordon P. Eaton, Director

Chain of Custody—recommendations for acceptance and analysis of evidentiary geochemical samples / by Christine Murphy . . . [et al.].

p. cm. — (Geological Survey circular ; 1138)Includes bibliographical references.1. Forensic geology—United States. 2. Chemistry, Forensic—United States.

3. Evidence, Real—United States. 4. Analytical geochemistry.I. Murphy, Christine M. II. Series.

KF8964.C46 1997347.73

′

64—dc21 96–36720CIP

CONTENTS

Executive Summary ivIntroduction 1Sample Control Routine Procedures 1

Acceptance of Samples 1 Policies Required Prior to Acceptance of Evidentiary Samples 5

Pre-assessment Meeting 5Sample Control Evidentiary Procedures 6

Acceptance of Samples 8Withdrawal of Samples 8

Sample Preparation of Chain-of-Custody Samples 10Chain-of-Custody Sample Laboratory Analysis 10Chain-of-Custody Sample Neutron Activation Analysis 11Sample Completion and Miscellaneous Information 12Personnel Policy Governing Chain-of-Custody Samples 14General Policies Governing Physical Security of Chain-of-Custody Samples 14

Federal Center Security 14Building Security 16Sample Control Security 16Sample Preparation Security 16Laboratory Security 16Backup Chain-of-Custody Sample Storage Devices 16Computer Security for Chain of Custody 17

References 17Appendix 1. Government Cost Estimate 18Appendix 2. Building 20 Map 19Appendix 3. Shortened Version of Chain-of-Custody Policies 20Acknowledgments 26

FIGURES

Figure 1. Request for analysis form 22. Self-adhesive labels 43. Sample control 3"x5" card 54. Pre-assessment form 75. Chain-of-Custody (COC) form 96. Deliveries to sample control memorandum 137. Low-level Au analysis form 15

iii

EXECUTIVE SUMMARY

This report details the procedure for handling samples submitted to the Mineral ResourceSurvey Program (MRSP), formerly the Branch of Geochemistry (BGC). In addition, there arerules required by law when the samples are used as evidence. This report covers both eviden-tiary and routine samples.

This report includes: • Sample control personnel procedures for routine handling of samples

• Designation of samples in need of special handling

• Submitter’s procedure for communicating the need for special handling

• Laboratory personnel procedures for handling evidentiary samples

• Personnel policies and responsibilities

• Security measures

iv

1

INTRODUCTION

Personnel from the Analytical Chemistry Services Group (ACSG), MineralResource Survey Program (MRSP), formed a team to determine the policies foracceptance and analysis of geochemical samples. This team contacted lawenforcement agencies that handle litigious samples, laboratories that work withsamples of a special nature, and the Solicitor General, Department of theInterior. Using the knowledge from these agencies as well as the expertise ofour personnel, the following policies have been enacted.

SAMPLE CONTROL ROUTINE PROCEDURES

Sample control personnel are responsible for maintaining the chain of cus-tody for all samples submitted to MRSP from submittal to eventual storage.Samples used in litigation are controlled by an even more rigorous set of guide-lines to ensure their security. Policies for both the routine chain of custody(COC) procedures and the evidentiary COC procedures are detailed below.

All samples submitted to MRSP must be accompanied by a completedrequest for analysis (RFA) form (figs. 1

A and 1B). The RFA accompanies thesamples through the entire system as the accountable record. All importantinformation, such as the evidentiary nature of a sample or high elemental con-centration in a sample, is noted on this form along with the requested analysis.All fields noted on the RFA as mandatory must be completed prior to accep-tance by sample control.

Acceptance of Samples (Nonevidentiary)

Samples accepted by sample control personnel are scanned for radioactiv-ity. If samples are above the safe levels defined by the MRSP safety officer,samples are placed in an alternate storage area, and the safety officer is notified.If the safety officer deems the samples unacceptable, the submitter is asked toretrieve them within 30 days. Other samples that might pose a threat to thesafety of personnel, such as hazardous waste material, are also referred to thesafety officer.

Samples are counted and checked against the RFA. Discrepancies areresolved prior to formal acceptance. The number of samples is recorded in asample control log book.

The samples are placed on numbered shelves in a holding area for unpre-pared samples. The shelf number is noted on the RFA and the RFA is forwardedfor data entry into the computer.

The information from the RFA is entered in a computer and a job number isissued to each batch. Individual sample numbers are also issued (laboratorynumbers). The job number and laboratory numbers are added to the RFA.

A computer printout of the requested analysis, the assigned job number, thelaboratory numbers, the submitter’s identifying numbers (usually the field

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4

numbers), and a list of the contact laboratory personnel is sent to the submitterfor verification. A photocopy of the RFA with the relevant information is sentwith the computer printout to the submitter. The original RFA, a computerprintout of the requested analysis, and self-adhesive labels (fig. 2) are placedwith the samples in the preparation holding area. Two labels are made for eachsample: one for the side of the sample container and the second for the top ofthe container. The samples and paperwork remain in a sample control holdingarea until requested by the sample preparation laboratory personnel.

A photocopy of the RFA and computer printout are placed in a loose leafnotebook filed by job number in the sample control area.

Three, 3

"x5" cards are typed and filed (fig. 3). One card is filed in job num-ber order and used for tracking routine samples. A second card is filed in alpha-betical order by submitter name and is used to record the date each analysis iscompleted. The final card is filed in order by lab number as a cross referencepermanent storage card.

Figure 2. Self-adhesive labels.

JOB NO. AA01LAB NO. D-000001FIELD NO. ABC001REQUESTOR SUBMITTER, J.

D-000001SUBMITTER

AA01

JOB NO. AA01LAB NO. D-000002FIELD NO. ABC002REQUESTOR SUBMITTER, J.

JOB NO. AA01LAB NO. D-000003FIELD NO. ABC003REQUESTOR SUBMITTER, J.

JOB NO. AA01LAB NO. D-000004FIELD NO. ABC004REQUESTOR SUBMITTER, J.

JOB NO. AA01LAB NO. D-000005FIELD NO. ABC005REQUESTOR SUBMITTER, J.

D-000002SUBMITTER

AA01

D-000003SUBMITTER

AA01

D-000004SUBMITTER

AA01

D-000005SUBMITTER

AA01

5

As laboratory personnel request work, sample control personnel note onthe tracking card the location and the date each job is moved. When the sam-ples are returned, the last entry is crossed out with a single line indicating thatthe samples have been returned to sample control. The samples are then filednumerically by job number on the sample control pending shelves.

The card filed by the submitter name is the record of the chain of analysis.As each requested analysis is completed, the date is noted on the card. Threemonths after all requested work for a job has been completed, the card is filedin the card permanent storage.

When all work on a job has been completed, sample control personnel fileall of the original paperwork in loose leaf computer notebooks by job number.Six months after the completion of analysis, samples of completed jobs aremoved to the permanent storage facility.

POLICIES REQUIRED PRIOR TO ACCEPTANCE OF EVIDENTIARY SAMPLES

Pre-Assessment Meeting

Prior to sample submittal the project leader(s) requiring strict chain of cus-tody (COC) must meet with all relevant laboratory personnel to discuss detailsof the project, including the handling, analysis, and final disposition of sam-ples. At this meeting, any concerns, such as the capability of the laboratory tomeet the submitters’ needs, are discussed and resolved.

The meeting should include representatives from sample control, computergroup, sample preparation laboratory, analytical laboratories, and quality assur-ance (QA). Items to be discussed include the following: the exact number ofsamples to be analyzed, the anticipated submittal dates, required data delivery

AA01 Joe Submitter 5 D-000001-000005

Rock Colorado Evidence

LAGD(5901)LAQS(5005)

Figure 3. 3"x5" sample control card.

6

date, necessary sample preparation, laboratory techniques, and a plan to notifythe MRSP when litigation is complete. The project leader should discuss thepossible hazardous nature of the samples when applicable and any special pre-cautions laboratory personnel should follow when handling the samples. Anydesired modifications of the laboratory’s established QA guidelines or datareporting protocols should be clarified. Any changes in the QA guidelinesrequire approval by the laboratory’s QA coordinator. Costs of the routine labo-ratory work and sample disposal are calculated by the MRSP and the projectleader and are presented at this meeting. All meeting information is reported onthe pre-assessment meeting form (fig. 4). If the project is a multi-phase ormulti-year study, pre-assessment meetings are convened prior to the submittalof samples for each phase or year of the study. The pre-assessment form mustbe signed by the chief scientist prior to acceptance of COC samples.

Pre-assessment meetings for all projects originating from other Federalagencies (OFA) are conducted by a representative from the requesting agencyand a designated MRSP liaison. If an MRSP liaison is the meeting leader, it ishis/her responsibility to provide all pertinent information, especially that whichrelates to the hazardous nature of the samples. The laboratory reserves the rightat any time to refuse any sample that exceeds laboratory safety guidelines.

If it is determined at the pre-assessment meeting that the numbers of sam-ples being submitted for COC analysis exceeds the current laboratory capacity,the meeting information is forwarded to a panel convened by the MRSP labo-ratory manager to resolve the problem. Project leaders and laboratory manage-ment incorporate panel recommendations in the final plan.

SAMPLE CONTROL EVIDENTIARY PROCEDURES

Samples that might involve litigation are handled as evidence. A specificset of COC procedures are maintained on all such samples. These samples aresubject to the following rules:

• The sample control custodian (SCC) is the designated custodian of evi-dentiary samples and maintains all COC samples, forms, and trackingcards. These are located in a specially designated, locked evidentiaryarea in the sample control area.

• The SCC is responsible for the primary keys for this area and keeps anextra set of keys locked in a cabinet in the sample control area. Thesample control area is entered using a key card; entry is monitored bythe Federal Protective Service (FPS). If the custodian is unavailable, asample control employee will be authorized to maintain custody andwill be given the keys. The security of this area is detailed later in thisdocument.

• If emergency personnel, janitorial personnel, or others require access tothe sample control area, a visitors log is signed with date, time, and rea-son for entry. Analysts withdrawing COC samples, who enter the sam-ple control office, also sign the visitors log.

7

Pre-assessment meeting information

Project meeting date__________________________ Project ID__________________

Est. Collection date________________________ Est. submittal date________________

Est. total number of COC samples______________________________

InitialsTechniques # COC # reg. of rep. Estimatedrequired samples samples present completion date

Hazardous material Yes_____ No_____

(If yes, identifysuspected hazardouscompounds or items)

Submitters Priority Yes_____No_____

Estimated Cost $_____________

Comments

Figure 4. Pre-Assessment Form.

8

Acceptance of Samples

While the submitter or designated agent of the submitter is present, samplecontrol personnel count and check the samples against the RFA. Any discrep-ancies are resolved prior to official acceptance of the samples. The SCC has theright to refuse samples as evidentiary, if the sample containers are improperlysealed, damaged, leaking, or the samples themselves are above the levels oftoxicity or radioactivity predetermined by the MRSP safety officer. Samplesthat arrive with incomplete or incorrect paperwork may also be refused. Theidentifying numbers are recorded on the sample control COC Form (fig. 5),which is maintained in a bound book. Information required includes the num-ber of samples, the type of sample media, the submitter name, and the date andtime of acceptance. Both the submitter and the receiver (or the receiver in thepresence of the submitter) sign this form. The submitter signs on the line indi-cating the release of samples; the SCC signs on the line indicating the accep-tance of samples. Special notes such as the condition of seals are added to theform prior to both parties signing.

Samples that require drying in an oven are placed in the oven secured withchains and a padlock. Samples that require refrigeration are placed in therefrigerator, which is located in a secured sample preparation laboratory.

Samples that require no refrigeration or drying are locked in the samplecontrol evidentiary holding area. Formally accepted samples are entered intothe system as described in the routine section above. The exceptions to the rou-tine procedures are that laboratory and job numbers are added to the COCform, and a fourth 3"x5" card is created. All four cards indicate that these sam-ples are evidentiary. Three of the cards are filed and kept as in the routine pro-cedure. The fourth card is filed in a small file that is kept in the COC area. Thiscard is identical to the other tracking card held in sample control except thatindividuals requesting custody of samples must sign the COC tracking cardwith name and date.

Withdrawal of Samples

Analysts authorized to work with COC samples must contact the SCC torequest withdrawal of COC samples prior to arriving in the sample controlarea. The analyst meets the SCC in the sample control area and signs the visi-tors log. The analyst inspects the evidence seals to check that the samples meetstandard evidence rules. Samples, either individually sealed or sealed in traysby job, are given to the analyst after the analyst signs the tracking card and thebottom section of the COC form with name, date, time, reason for withdrawal,amount to be used in analysis, and where the samples are to be moved.Samples may then be moved to another secured area. Samples must be returnedto sample control as soon as the amount required for analysis has beenremoved and weighed. Samples are never left unattended or unsecured. Theanalyst adds any additional notes, such as increased amount of sample with-drawn, to the COC form when the samples are returned to sample control.

9

Mineral Resource Survey ProgramChain-of-Custody Form

______ of ______Pages

Submitted By: Number of Samples:Received By: Sample Media:Date/Time Received: Job Number: Lab Numbers:

List Sample Identification Numbers

Custodial Locations

Received By:(Time and Date)

Returned To:(Time and Date)

Purpose: Location:

Figure 5. Chain-of-Custody (COC) Form.

10

If it is necessary to complete analysis in an area that has been secured witha padlock or dead bolt lock, the analyst signs the tracking card for both thesamples and the key for the secured lock. The SCC is the only other individualwho has a key to these locks. The analyst must return the key to the SCC assoon as the analysis is complete. When COC samples are in a laboratory, noother samples are permitted in that laboratory to eliminate any possibility ofcross-contamination with COC samples. Anyone entering a secured area whileCOC samples are present must sign a log book with name, date, time, and rea-son for entry.

SAMPLE PREPARATION OFCHAIN-OF-CUSTODY SAMPLES

COC sample preparation protocol only differs from the standard operatingprocedure for sample preparation by the additional security and documentation.Physical sample preparation of COC samples is performed in accordance withthe quality assurance manual for the Branch of Geochemistry (Arbogast, 1990).Any special preparation instructions, the amount of sample to be prepared, thedisposal of excess material and the cost for disposal of any hazardous materialsis agreed upon at the pre-assessment meeting.

If any excess sample is being returned to the submitter, a 3-oz unalteredsplit of the sample is maintained in the locked sample control area until the liti-gation is completed. All other excess sample is either returned to the submitteror discarded. If hazardous materials/waste disposal costs are incurred, the sub-mitter is responsible.

A trained and certified sample preparation technician accepts the sample(s)from the SCC. The samples are taken to the COC sample preparation labora-tory and prepared for analysis. Upon completion of preparation the techniciannotes on the RFA any problems such as broken seals. The sample preparer’slog book details all steps taken in the processing of samples to allow for recallof these specific samples. The samples and excess bulk, if any, are secured withevidence tape, initialed and dated. They are then returned to the SCC. The SCCchecks to ensure all samples are present and sealed properly and signs the bot-tom section of the COC form, next to the analyst’s name, to indicate theresumption of custody.

CHAIN-OF-CUSTODY SAMPLE LABORATORY ANALYSIS

After the prepared samples are returned to sample control, laboratory ana-lysts withdraw samples following the procedure discussed above. Samples aremoved to secured laboratory areas. Any sample removed from the custodialsample (for example, 10 g for Au analysis) is documented on the COC form. Ifanalysis requires formation of solutions, the solution may be kept in thesecured area, but the original sample is returned to sample control as soon asthe amount needed for analysis has been weighed and removed.

11

Routine techniques validated in the quality assurance manual for theBranch of Geochemistry (Arbogast, 1990) are used for the majority of analysesof COC samples. Nonroutine techniques may also be used for the analysis ofCOC samples, but it then becomes the responsibility of the research scientist toprovide the necessary QA/QC information and method references for valida-tion of the research technique to the SCC to be filed with the samples on whichthe analysis is performed.

Instrument calibration and maintenance are performed according to qualityassurance manual (Arbogast, 1990). Instrument calibrations are documented inlog books or on computer printouts. The laboratory chief maintains a log oflocalities for all paperwork not filed with COC samples.

Lab books and log books are bound, and entries are recorded in permanentink. Lab books contain pertinent information such as job number, name of sub-mitter, sample number, weight of sample, date of preparation, and method ofdissolution. A visitor’s log book is kept at the entrance to each COC laboratoryto record any entry and departure of non-COC personnel into the secured areasduring preparation and (or) analysis of COC samples. The analyst is responsi-ble for placing all data in a secured area during sample analysis (for example,strip charts or graphs). When the analysis is complete, all original data not con-tained in a notebook is given to the SCC for storage.

CHAIN-OF-CUSTODY SAMPLE NEUTRON ACTIVATION ANALYSIS

Samples are checked out from the SCC in the manner previouslydescribed. The samples are then taken directly to Building 15 at the DenverFederal Center, which is a controlled access building where the outside doorsare locked at all times. The samples are prepared by heat-sealing the samplesplit in a polyethylene vial, which protects the integrity of the sample. Thesample vials are also imprinted with a sample and irradiation code using a per-manent marker. The prepared sample splits are placed in a locked cabinet inthe analyst’s office, and any sample beyond the amount needed for this analy-sis is returned to the SCC. The key for the cabinet is in the possession of theanalyst.

Prior to irradiation, the samples are given to the reactor staff for loading inthe reactor. The samples remain in the reactor overnight and then are placed ina locked, lead-shielded container in the reactor bay area. This containerremains locked until the analyst, who has the only key, removes the samples.The samples are allowed to decay in this container for about 5 or 6 days. Aftersigning the appropriate forms required by the Nuclear Regulatory Commission(NRC), the samples are taken by the analyst to the laboratory in Building 15and analyzed by routine procedures described in Baedeker and McKown(1987). NRC security procedures are similar to standard evidentiary regula-tions.

12

During the analysis, unprocessed spectral data of the samples are trans-ferred from the analyzer to a VAX 750 computer. This spectral data is alsocopied to a floppy disk. The data disks are locked in the COC cabinet in theanalyst office. All of the principal data reduction is performed using the spec-tral data residing on the VAX computer. Selected data reduction routines areperformed on a computer using the spectral data stored on the floppy disks andindependent software to verify the primary results. The laboratory and office ofthe analyst is locked after business hours, and the keys to these areas are heldby the analyst.

SAMPLE COMPLETION AND MISCELLANEOUS INFORMATION

Samples that are insufficient for all requested analyses are noted on theRFA and the COC form when they become insufficient. All requested splits arekept in the secured areas with the original samples. Should a portion of thesample be requested for litigation, a split can be made available after permis-sion has been granted by the Solicitor General. The amount of sample removedand the date and time is noted on the COC form.

When all requested analyses are complete, computer printouts of theresults are filed in a loose leaf book in the secured sample control area. Thesamples and all related paperwork are secured until all litigation is complete.

Sample submitters are contacted annually to ascertain the status of the liti-gation process. When litigation is complete, the submitter is notified to retrievethe samples. A split of the original sample is maintained by MRSP for perma-nent archive but as a nonevidentiary sample. The evidentiary samples and acopy of all RFA documentation, computer printouts, and results are returned tothe submitter who signs the COC card and the COC form, which is filed insample control.

A room in the preparation area has been provided for sorting large batchesof samples which are COC. As this room is shared, there is a limited timeavailable for its use.

Samples that have a short viability (such as water samples) will be held for6 weeks. At that time they will be returned to the submitter along with a copyof all documentation. The submitter will be required to sign for the samples onthe COC card and form.

Samples that are sent through the mail room with evidence tape will not bereleased by the mail room personnel to anyone but the SCC or designatedbackup individual (fig. 6).

If the litigation is not completed, the samples and all related documentscontinue to be held as evidence with all appropriate safe guards. Storagecharges may be assessed if storage of more than two years is anticipated orincurred.

13

Figure 6. Deliveries to sample control.

14

Information regarding the samples may be released to the submitter only.Any requests for information from anyone other than the submitter are referredto the Solicitor General.

PERSONNEL POLICY GOVERNING CHAIN-OF-CUSTODY SAMPLES

Employee conduct is governed by the Ethics Reform Act of 1989. Detailsof this act are available in the local personnel office of the U.S. GeologicalSurvey. The guidelines set forth in this act are to be followed by all private(contract) and government employees working on COC samples in this labora-tory.

The supervisory sample control specialist serves as the principal COC cus-todian for the laboratory and is responsible for the coordination of sample sub-mittal, retrieval and storage (short and long term) of samples. A designatedindividual from sample control serves as a backup COC custodian.

Training documents identify the qualified analysts who can perform a par-ticular procedure or parts of a procedure. Only qualified analysts will performthe requested analyses. Training documentation (fig. 7) is kept and maintainedby the quality assurance (QA) coordinator. Analyst performance is routinelychecked using quality control (QC) results to demonstrate that the analyst per-forms under the guidelines set forth under the QA Manual for the MRSP.

COC analysis personnel have work plans that include a critical elementgoverning compliance with COC guidelines. These individuals are all certifiedby the laboratory chief to handle COC samples.

The chief scientist or the MRSP laboratory manager represent the lab in allcourt cases where routine procedures are used to analyze COC samples. Whennonroutine techniques are used in the analysis of samples it is the research sci-entist’s responsibility to provide all necessary documentation, QA/QC informa-tion, and testimony at any legal proceedings.

GENERAL POLICIES GOVERNING PHYSICALSECURITY OF CHAIN-OF-CUSTODY SAMPLES

Federal Center Security

The MRSP COC protocol includes three levels of security. The first levelcontrols passage onto the Denver Federal Center (DFC) with a fenced enclo-sure and entrance guards who record all access of nongovernment employeesand all access of government employees after normal business hours. A secondlevel of security is provided by regular police patrols of the DFC by theFederal Protective Service (FPS). The final level is provided by our buildingsecurity, which is described in detail below.

15

Low-level Au Analysis

Name______________________________________________________________Job title/Grade_______________________________________________________Supervisor__________________________________________________________Date of training initiation______________________________________________

TRAINER MUST INITIAL AND DATE

Figure 7. Low-level Au analysis Form.

PROCEDURENot yettrained

Inprocess

Proficient

1. Sample weighing

a. Cleaning crucibles andsample weighing

a. Cook samples

b. Dissolution of samples

a. Organic extraction

b. HBr extraction

a. Calibration

b. Run samples

a. Calibration

b. Run samples

2. Sample digestion

3. Au Extractions

4. Flame AA

7. QC paperwork

6. Cleanup

5. GFAA

8. Data sheets

16

Building Security

Security for COC samples restricts access to three distinct areas in the lab-oratory facility. These include sample control/sample storage, sample prepara-tion, and a portion of the analytical laboratories. In all three areas, access iscontrolled through card readers, motion detectors, or deadbolt locks. Only des-ignated personnel that have been approved by management have access tothese secured areas. The security system in all three areas can be modified toaccommodate approved changes in laboratory personnel. All security measuresthat have been installed in this facility have been approved by the FPS, whowill monitor the installation.

Sample Control Security

The sample control area (app. 2) is secured by three card-reader monitorsand a one-way alarm door. In addition to these security measures, MRSPrestricts access to this area to authorized sample control personnel and thoseauthorized by the SCC.

Sample Preparation Security

Three rooms are designated for sample preparation (app. 2). The roomsinclude a special preparation/sorting and drying room used by sample submit-ters, a room designed for sample crushing and grinding, and a room used forpreparation of biologic materials. These rooms are equipped with special com-bination locks and (or) card readers. A motion detector is in place in the plantlaboratory providing additional security.

Laboratory Security

Four laboratories are used for COC analytical work. These laboratoriesinclude ICP-AES, ICP-MS, CV-AAS for mercury determination, and AA-hydride generation for determination of arsenic, antimony, and selenium (app.2). Because these laboratories were constructed with solid walls that run fromfloor to ceiling, securing them for COC work required monitoring only theentry to the laboratory. This was accomplished by the installation of card readermonitors and (or) special door combination locks. These security measures pro-vide adequate electronic monitoring while providing reasonable access for anapproved analyst. In addition, they can be deactivated when noncustodial sam-ples are being analyzed. The easy installation of these door security systemsallows for a “phased” installation. Thus laboratories can be secured as othertechniques are added to the suite of approved COC work.

Backup Chain-of-Custody Sample Storage Devices

A set of three storage lockers are located outside of sample control to serveas temporary sample storage units. These lockers can be used by analysts orsample submitters if samples cannot be secured in the sample control area by

17

the close of business. After these lockers have been closed, only the SCC canreopen them.

Computer Security for Chain of Custody

Computer access to the COC information stored in MRSP computersrequires a valid user identification and a password. Authorized computer accessis limited to selected personnel.

When a COC job is entered into the laboratory information managementsystem (LIMS), the assigned job number and laboratory numbers are sent topersonnel who work with these samples. No one has authority to access thisdata without special permission.

Analytical data are printed as they are generated. This hard copy is consid-ered the original (primary) document. The analytical results are also stored inthe computer as a backup to the primary document. Data storage is a designfeature of LIMS.

A password is required to access the system. Additional precautions maybe taken such as storing data on separate electronic storage devices, if itbecomes apparent that the computer security that is currently in place has beenbreached.

REFERENCES

Arbogast, B.F., editor, 1990, Quality assurance manual for the Branch ofGeochemistry, U.S. Geological Survey: U.S. Geological Survey Open-FileReport 90-668, 184 p.

Baedecker, P.A., and McKown, D.M., 1987, Instrumental neutron activation analysisof geochemical samples, in Baedecker, P.A. (ed.), Methods for geochemicalanalysis: U.S. Geological Survey Bulletin 1770, p. H1–H14.

18

APPENDIX 1Government Cost Estimate

2/17/94

Bldg 20 Rev 4/22/94Alt Rev 4/22/94Alt 1 Rev 4/22/94Rev 4/26/94

Labor GrandItem Cost Quan Total Hrs Cost Total Total

Prox 941 $433.00 16 $6,928.00 4 $35.00 $2,240.00 $9,168.00Strike 250.00 11 2,750.00 4 35.00 1,540.00 4,290.00Xmfr 25.00 11 275.00 1 35.00 385.00 660.00Special I/F 75.00 16 1,200.00 2 35.00 1,120.00 2,320.00Micro 4 2,317.00 1 2,317.00 8 35.00 280.00 2,597.008RP board 1,031.00 2 2,062.00 1 35.00 70.00 2,132.006000 ID cap 250.00 1 250.00 2 35.00 70.00 320.00Modem 450.00 2 900.00 2 35.00 140.00 1,040.00PIR 95.00 6 570.00 3 35.00 630.00 1,200.00Balanced Contact 65.00 7 455.00 3 35.00 735.00 1,190.00Exit switch 50.00 3 150.00 2 35.00 210.00 360.00Power Supply 125.00 1 125.00 4 35.00 140.00 265.00Moose MPI-775 60.00 2 120.00 1 35.00 70.00 190.00Siren 40.00 1 40.00 2 35.00 70.00 110.00

0.00 35.00 0.00 0.00Wire 0.75 1500 1,125.00 1,125.00Miscellaneous expenses 250.00 250.00

__________ __________ __________Total $19,517.00 $7,700.00 $27,217.00

APPENDIX 2Building 20 Street Plan Map

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20

APPENDIX 3

Shortened Version of Chain-of-Custody Policies

INTRODUCTION

The Mineral Resource Survey Program (MRSP), formerly the Branch ofGeochemistry (BGC), provides support expertise for geologic/analytical products.This includes the following:

• Development and application of single element and multi-element methodsused in geochemical investigations.

• Development and application of geochemical techniques for environmentalprograms.

• Expert testimony on sample handling and on the methods used.

• Maintenance of an up-to-date quality assurance program.

To ensure the integrity of evidentiary samples, policies have been established andare outlined below.

SAMPLE CONTROL ROUTINE PROCEDURES

Sample control personnel are responsible for maintaining the chain of cus-tody for all samples submitted to MRSP. Samples involved in litigation are con-trolled more rigorously to ensure their admissibility as evidence in court.

All samples submitted to MRSP must be accompanied by a completedrequest for analysis (RFA) form. This form is the record of accountability.Information, such as the evidentiary nature of a sample or high elemental concen-trations in a sample, are noted on this form along with the requested analysis.

ACCEPTANCE OF ROUTINE SAMPLES (NONEVIDENTIARY)

Samples are counted and checked against the RFA. Discrepancies areresolved prior to formal acceptance. The information from the RFA is entered inthe computer and numbers are issued for each batch (job number) and each indi-vidual sample numbers (laboratory numbers).

A computer printout of the information from the RFA and the informationgenerated by the computer is sent to the submitter for verification. The samplesand paperwork remain in a sample control holding area until requested by thesample preparation laboratory personnel.

The policies used in processing routine samples are documented and main-tained in the sample control office. Copies of this information are available uponrequest.

When all work on a job has been completed, sample control personnel file allof the original paperwork in loose leaf computer notebooks by job number. Six

21

months after the completion of analysis, samples from completed jobs are thenmoved to the permanent storage facility.

POLICIES REQUIRED PRIOR TO ACCEPTANCE OF EVIDENTIARY SAMPLES

Pre-Assessment Meeting

Prior to sample submittal, the project leader(s) requesting strict chain of cus-tody (COC) conducts a meeting with all relevant laboratory personnel to discussdetails of the project relating to the handling, analysis, and final disposition ofsamples.

The laboratory reserves the right to refuse any sample that exceeds labora-tory safety guidelines.

SAMPLE CONTROL EVIDENTIARY PROCEDURES

Samples that might involve litigation are handled as evidence. A specific setof COC procedures are maintained on all such samples. The process for handlingthese samples requires additional precautions. Specific rules are detailed below.

The sample control specialist (SCC) or designated representative is the custo-dian of evidentiary samples and maintains all COC samples, forms, and trackingcards in a secured area.

Acceptance of Evidentiary Samples

While the submitter is present, sample control personnel count and check thesamples against the RFA. Any discrepancies are resolved prior to official accep-tance of the samples. The SCC has the right to refuse samples as evidentiary, ifthe sample containers are improperly sealed, damaged, leaking, above the levelsof toxicity or radioactivity pre-determined by the MRSP safety officer or arrivewith incomplete or incorrect paperwork. The identifying numbers are recorded onthe sample control COC Form, which is maintained in a bound book. The sam-ples are photographed, and this photograph is preserved with the RFA.

Samples are locked in the sample control evidentiary holding area. Formallyaccepted samples are entered into the system according to the documentation inthe sample control office. The exceptions to the routine procedure are that labora-tory and job numbers are added to the COC form, and a tracking card is createdfor evidence. This card is filed in a small file that is kept in the COC area. Thiscard must be signed by individuals with name and date before samples will bereleased by the SCC.

Withdrawal of Evidentiary Samples

Analysts authorized to work with COC samples must contact the SCC forwithdrawal of COC samples prior to arriving in the sample control area. The ana-lyst comes to the sample control area and inspects the evidence seals to assure

22

that the samples meet standard evidence rules. Samples are given to the analystafter the analyst signs the tracking card and the bottom section of the COC formwith name, date, time, reason for withdrawal, amount to be used in analysis, andlocation to where the samples are to be moved. Samples may then be moved toanother secured area. Samples are returned to sample control as soon as theamount required for analysis has been weighed and removed. Samples are not leftunattended and (or) unsecured. The analyst adds any additional notes, such asincreased amount of sample withdrawn, to the COC form when the samples arereturned to sample control.

When COC samples are in a laboratory, no other samples are permitted inthat laboratory to eliminate any possibility of cross-contamination of COC sam-ples.

SAMPLE PREPARATION OFCHAIN-OF-CUSTODY SAMPLES

COC sample preparation protocol differs from the standard operating proce-dure for the ACSG sample preparation only by the additional security and docu-mentation involved. Physical sample preparation of COC samples is performed inaccordance with the quality assurance manual (Arbogast, 1990).

Any special preparation instructions, the amount of sample to be prepared,the disposal of excess material, and the cost for disposal of any hazardous materi-als is agreed upon at the pre-assessment meeting.

If excess sample is being returned to the submitter, a 3-oz unaltered split ofthe sample is retained and safeguarded until the litigation is completed. This pre-pared sample is maintained by the ACSG and used for analytical work. All otherexcess sample is either returned to the submitter or discarded. If hazardous mate-rials/waste disposal costs are incurred, the submitter is held responsible as agreedupon at the pre-assessment meeting.

A trained and certified sample preparation technician accepts the sample(s)from the sample custodian. The samples are taken to the ACSG’s COC samplepreparation laboratory and prepared for analysis. Upon completion, the techniciannotes on the RFA any problems such as broken seals. The samples and excessbulk, if any, are secured with evidence tape, initialed and dated. They are thenreturned to the sample custodian. The sample custodian checks to ensure all sam-ples are present and sealed properly and signs the bottom section of the COCform next to the analyst’s name to indicate the resumption of custody.

CHAIN-OF-CUSTODY SAMPLE LABORATORY ANALYSIS

After the prepared samples are returned to sample control, laboratory analystswithdraw samples following the same rules. Samples can be only moved tosecured areas of the building. Any sample removed from the custodial sample (forexample, 10 g for Au analysis) is documented on the COC form. If analysisrequires formation of solutions, the solution may be kept in the secured area, but

23

the original sample is returned to sample control as soon as the amount neededfor analysis has been weighed and removed.

Routine techniques validated in Arbogast (1990) are used for the majority ofanalyses of COC samples. Nonroutine techniques may also be used for the analy-sis of COC samples, but it then becomes the responsibility of the research scien-tist to provide the necessary QA/QC information and method references for vali-dation of the research technique.

Instrument calibration and maintenance are performed according to Arbogast(1990). Instrument calibrations are documented in log books or on computerprintouts. Lab books and log books are bound with entries recorded in permanentink. Lab books contain pertinent information such as job number, name of sub-mitter, sample numbers, weight of sample, date of preparation, and method of dis-solution. The analyst is responsible for placing all data in a secured area duringsample analysis (such as strip chart and graphs). When the analysis is complete,all original data are given to the COC custodian, who is responsible for the stor-age of the information.

SAMPLE COMPLETION AND MISCELLANEOUS INFORMATION

Samples that are insufficient for all requested analyses are noted on the RFAand the COC form when they become insufficient. All requested splits are kept inthe secured areas with the original samples. Should a portion of the sample berequested for litigation, a split is made available upon request and permission ofthe Solicitor General. The amount of sample removed and the date and time isnoted on the COC form.

When all requested analyses are complete, computer printouts of the resultsare filed in a sample control loose leaf book in the sample control secured area.The samples and all related paperwork are secured until all litigation is complete.

Sample submitters are contacted on an annual basis to ascertain the status ofthe litigation process. When the litigation is complete, the submitter is notified toretrieve the samples. A split of the original sample is maintained by the MRSP forpermanent archive but on a nonevidentiary basis. The evidentiary samples and acopy of all RFA documentation, computer printouts, and results are returned tothe submitter who signs the COC card and the COC form, which is filed in sam-ple control.

Samples that have a short viability (such as water samples) will be held for 6weeks. At that time, they will be returned to the submitter along with a copy ofall documentation. The submitter will be required to sign for the samples on theCOC card and form.

Samples that are sent through the mail room with evidence tape will not bereleased by the mail room personnel to anyone but the SCC or the designatedbackup individual.

24

If the litigation is not completed, the samples and all related documents con-tinue to be held as evidence with all appropriate safeguards.

Storage charges may be assessed if storage times of more than 2 years areanticipated or incurred.

Information regarding the samples may only be released to the submitter. Anyrequests for information from anyone other than the submitter are referred to theSolicitor General.

PERSONNEL POLICY GOVERNING CHAIN-OF-CUSTODY SAMPLES

Employee conduct is governed by the Ethics Reform Act of 1989. Details ofthis act are available in the local personnel office of The U.S. Geological Survey.The guidelines set forth in this act are to be followed by all private (contract) andgovernment employees working on COC samples in this laboratory.

The supervisory sample control specialist serves as the principal sample COCcustodian for the laboratory and is responsible for the coordination of sample sub-mittal, retrieval and storage (short and long term). A designated individual fromsample control acts as a backup COC custodian.

Training documents identify those analysts who are qualified to perform aparticular procedure or parts of a procedure. Only analysts who are documentedas qualified will perform the requested analyses. Training documents are kept andmaintained by the quality assurance coordinator.

The analyst’s performance is routinely checked using Quality Control (QC)results to demonstrate that the analyst performs under the guidelines set forthunder the Quality Assurance (QA) Manual for Branch of Geochemistry (Arbogast,1990).

Individuals involved with COC analyses have work plans that include a criti-cal element governing compliance with COC guidelines. These individuals are allcertified by the laboratory chief as qualified to handle COC samples.

The chief scientist or the MRSP laboratory manager represent the lab in allcourt cases where routine procedures are used to analyze COC samples.

When nonroutine techniques are used in the analysis of samples, it is theresearch scientist’s responsibility to provide all necessary documentation, QA/QCinformation, and testimony at any legal proceedings.

GENERAL POLICIES GOVERNING PHYSICALSECURITY OF CHAIN-OF-CUSTODY SAMPLES

Federal Center Security

The COC protocol includes three levels of security. The first level controls ofentrance and exit of the Denver Federal Center (DFC) with a fenced enclosure

25

and guards who record all access after normal business hours. A second level ofsecurity is provided by regular police patrols of the DFC by the FederalProtective Service (FPS), and a final level is provided by our building securitysystem.

Building Security

Security for COC samples restricts access to three distinct areas in the labo-ratory facility. In all areas, security equipment was recommended, installed, andis monitored by the FPS. Only designated individuals who have been approvedby MRSP management have access to these secured areas. The security system inall three areas can be modified to accommodate changes in laboratory personnelwithout endangering the security of COC samples.

Sample Control Security

The sample control area is secured by various methods recommended by theFPS and installed under their supervision. In addition to these security improve-ments, MRSP restricts access to this area to authorized sample control personneland those authorized by the SCC.

Sample Preparation Security

Three rooms are designated for sample preparation. The rooms include a spe-cial preparation/sorting and drying room used by sample submitters, a roomdesigned for sample crushing and grinding, and a room used for preparation ofbiologic materials. The security of these rooms was also installed under the super-vision of FPS.

Laboratory Security

Four laboratories are used for COC analytical work. Electronic security mea-sures provide complete monitoring but still provide reasonable access for anapproved analyst. In addition, the security can be deactivated when noncustodialsamples are being analyzed. Access is monitored by FPS anytime COC samplesare being analyzed.

Backup Chain-of-Custody Sample Storage Devices

A set of three storage lockers are located outside of sample control to serveas temporary sample storage units. These lockers are used by analysts or samplesubmitters if samples cannot be secured in the sample control area by the close ofbusiness. After these lockers have been closed, only the sample custodian canreopen them.

Computer Security for Chain of Custody

Computer access to the COC information stored in computers requires avalid user identification and a password. Authorized computer access is limited toselected MRSP personnel.

26

When a COC job is entered into the laboratory information management sys-tem (LIMS), the assigned job number and laboratory numbers are sent to the per-sonnel who work with these samples. No one has authority to access this datawithout special permission.

Analytical data are printed as they are generated from laboratory instruments.This hard copy is considered the original (primary) document. The analyticalresults are also stored in the computer as a backup to the primary document. Datastorage is a design feature of LIMS. A password is required to access the system.Additional precautions may be taken such as storing data on separate electronicstorage devises, if it becomes apparent that the computer security that is currentlyin place has been breached.

REFERENCE

Arbogast, B.F., editor, 1990, Quality assurance manual for the Branch ofGeochemistry, U.S. Geological Survey: U.S. Geological Survey Open-File Report 90-668, 184 p.

ACKNOWLEDGMENTS

We especially want to thank the following people for sharing their expertise:

Belinda Arbogast Mineral Resource Survey ProgramJim Budahn Mineral Resource Survey ProgramPaul Lamothe Mineral Resource Survey ProgramSteve McDanal Mineral Resource Survey Program

Vince Marino Federal Protective ServiceJon Werkmeister Federal Protective Service

Peter Mang Colorado Bureau of InvestigationJackie Bailey Colorado Bureau of Investigation

Bob Huestis Lakewood Police Department

Glenn Tiedt Office of the Solicitor General,Department of the Interior

Anthony Palizzi EnescoJerry Porr Enesco

Bruce Binkley Environmental Protection AgencyEric Nottingham Environmental Protection Agency

AVAILABILITY OF BOOKS AND MAPS OF THE U.S. GEOLOGICAL SURVEY

Instructions on ordering publications of the U.S. Geological Survey, along with prices of the last offerings, are given in the current-yearissues of the monthly catalog “New Publications of the U.S. Geological Survey.” Prices of available U.S. Geological Survey publications re-leased prior to the current year are listed in the most recent annual “Price and Availability List.” Publications that may be listed in various U.S.Geological Survey catalogs (

see back inside cover) but not listed in the most recent annual “Price and Availability List” may no longer beavailable.

Reports released through the NTIS may be obtained by writing to the National Technical Information Service, U.S. Department ofCommerce, Springfield, VA 22161; please include NTIS report number with inquiry.

Order U.S. Geological Survey publications by mail or over the counter from the offices listed below.

BY MAIL

Books

Professional Papers, Bulletins, Water-Supply Papers, Tech-niques of Water-Resources Investigations, Circulars, publications ofgeneral interest (such as leaflets, pamphlets, booklets), single copiesof Earthquakes & Volcanoes, Preliminary Determination of Epicen-ters, and some miscellaneous reports, including some of the forego-ing series that have gone out of print at the Superintendent ofDocuments, are obtainable by mail from

U.S. Geological Survey, Information ServicesBox 25286, Federal Center

Denver, CO 80225

Subscriptions to periodicals (Earthquakes & Volcanoes andPreliminary Determination of Epicenters) can be obtained ONLYfrom the

Superintendent of DocumentsGovernment Printing Office

Washington, DC 20402

(Check or money order must be payable to Superintendent ofDocuments.)

Maps

For maps, address mail orders to

U.S. Geological Survey, Information ServicesBox 25286, Federal Center

Denver, CO 80225

Residents of Alaska may order maps from

U.S. Geological Survey, Earth Science Information Center101 Twelfth Ave., Box 12

Fairbanks, AK 99701

OVER THE COUNTER

Books and Maps

Books and maps of the U.S. Geological Survey are availableover the counter at the following U.S. Geological Survey offices, allof which are authorized agents of the Superintendent of Documents.

•

ANCHORAGE, Alaska

–Rm. 101, 4230 University Dr.

•

LAKEWOOD, Colorado

–Federal Center, Bldg. 810

•

MENLO PARK, California

–Bldg. 3, Rm. 3128,345 Middlefield Rd.

•

RESTON, Virginia

–USGS National Center, Rm. 1C402, 12201 Sunrise Valley Dr.

•

SALT LAKE CITY, Utah

–Federal Bldg., Rm. 8105,125 South State St.

•

SPOKANE, Washington

–U.S. Post Office Bldg., Rm. 135,West 904 Riverside Ave.

•

WASHINGTON, D.C

.–Main Interior Bldg., Rm. 2650,18th and C Sts., NW.

Maps Only

Maps may be purchased over the counter at the followingU.S. Geological Survey offices:

•

FAIRBANKS, Alask

a–New Federal Bldg, 101 Twelfth Ave.

•

ROLLA, Missouri

–1400 Independence Rd.

•

STENNIS SPACE CENTER, Mississippi

–Bldg. 3101

SELECTED SERIES OF U.S. GEOLOGICAL SURVEY PUBLICATIONS

Periodicals

Earthquakes & Volcanoes

(issued bimonthly).

Preliminary Determination of Epicenters

(issued monthly).

Technical Books and Reports

Professional Papers

are mainly comprehensive scientific reportsof wide and lasting interest and importance to professional scientists andengineers. Included are reports on the results of resource studies and oftopographic, hydrologic, and geologic investigations. They also includecollections of related papers addressing different aspects of a single sci-entific topic.

Bulletins

contain significant data and interpretations that are oflasting scientific interest but are generally more limited in scope or geo-graphic coverage than Professional Papers. They include the results of re-source studies and of geologic and topographic investigations; as well ascollections of short papers related to a specific topic.

Water-Supply Paper

s are comprehensive reports that present sig-nificant interpretive results of hydrologic investigations of wide interestto professional geologists, hydrologists, and engineers. The series coversinvestigations in all phases of hydrology, including hydrology, availabil-ity of water, quality of water, and use of water.

Circulars

present administrative information or important scientif-ic information of wide popular interest in a format designed for distribu-tion at no cost to the public. Information is usually of short-term interest.

Water-Resources Investigations Reports

are papers of an inter-pretive nature made available to the public outside the formal USGS pub-lications series. Copies are reproduced on request unlike formal USGSpublications, and they are also available for public inspection at deposi-tories indicated in USGS catalogs.

Open-File Reports

include unpublished manuscript reports, maps,and other material that are made available for public consultation at de-positories. They are a nonpermanent form of publication that may be cit-ed in other publications as sources of information.

Maps

Geologic Quadrangle Maps

are multicolor geologic maps on to-pographic bases in 7 1/2- or 15-minute quadrangle formats (scales main-ly 1:24,000 or 1:62,500) showing bedrock, surficial, or engineeringgeology. Maps generally include brief texts; some maps include structureand columnar sections only.

Geophysical Investigations Maps

are on topographic or planimet-ric bases at various scales, they show results of surveys using geophysicaltechniques, such as gravity, magnetic, seismic, or radioactivity, which re-flect subsurface structures that are of economic or geologic significance.Many maps include correlations with the geology.

Miscellaneous Investigations Series Maps

are on planimetric ortopographic bases of regular and irregular areas at various scales; theypresent a wide variety of format and subject matter. The series also in-cludes 7 1/2-minute quadrangle photogeologic maps on planimetricbases which show geology as interpreted from aerial photographs. Theseries also includes maps of Mars and the Moon.

Coal Investigations Maps

are geologic maps on topographic orplanimetric bases at various scales showing bedrock or surficial geology,stratigraphy, and structural relations in certain coal-resource areas.

Oil and Gas Investigations Charts

show stratigraphic informa-tion for certain oil and gas fields and other areas having petroleum poten-tial.

Miscellaneous Field Studies Maps

are multicolor or black-and-white maps on topographic or planimetric bases on quadrangle or irreg-ular areas at various scales. Pre-1971 maps show bedrock geology in re-lation to specific mining or mineral-deposit problems; post-1971 mapsare primarily black-and-white maps on various subjects such as environ-mental studies or wilderness mineral investigations.

Hydrologic Investigations Atlases

are multicolored or black-and-white maps on topographic or planimetric bases presenting a wide rangeof geohydrologic data of both regular and irregular areas; the principalscale is 1:24,000, and regional studies are at 1:250,000 scale or smaller.

Catalogs

Permanent catalogs, as well as some others, giving comprehensivelistings of U.S. Geological Survey publications are available under theconditions indicated below from USGS Map Distribution, Box 25286,Building 810, Denver Federal Center, Denver, CO 80225. (See latestPrice and Availability List.)

“Publications of the Geological Survey, 1879-1961”

may be pur-chased by mail and over the counter in paperback book form and as a setmicrofiche.

“Publications of the Geological Survey, 1962-1970”

may be pur-chased by mail and over the counter in paperback book form and as a setof microfiche.

“Publications of the U.S. Geological Survey, 1971-1981”

may bepurchased by mail and over the counter in paperback book form (two vol-umes, publications listing and index) and as a set of microfiche.

Supplements

for 1982, 1983, 1984, 1985, 1986, and for subse-quent years since the last permanent catalog may be purchased by mailand over the counter in paperback book form.

State catalogs

, “List of U.S. Geological Survey Geologic and Wa-ter-Supply Reports and Maps For (State),” may be purchased by mail andover the counter in paperback booklet form only.

“Price and Availability List of U.S. Geological Survey Publica-tions,”

issued annually, is available free of charge in paperback bookletform only.

Selected copies of a monthly catalog

“New Publications of theU.S. Geological Survey” is available free of charge by mail or may be ob-tained over the counter in paperback booklet form only. Those wishing afree subscription to the monthly catalog “New Publications of the U.S.Geological Survey” should write to the U.S. Geological Survey, 582 Na-tional Center, Reston, VA 22092.

Note.

–Prices of Government publications listed in older catalogs,announcements, and publications may be incorrect. Therefore, the pricescharged may differ from the prices in catalogs, announcements, and pub-lications.