Standard Guide for Sample Chain-of-Custody Procedures

SIGNIFICANCE AND USE
5.1 Chain-of-custody procedures are a necessary element in a program to assure one’s ability to support data and conclusions adequately from the time samples are collected until sample disposal. In a legal or regulatory situation custody documentation alone is not sufficient. A complete data defensibility scheme should be followed that fits the given situation.  
5.2 In applying the sample chain-of-custody procedures in this guide, it is assumed that all of the other elements of data defensibility have been applied, if applicable.  
5.3 Because there is no definitive program that guarantees legal defensibility of data integrity in any given situation, this guide provides a description and discussion of a comprehensive list of possible elements of a chain-of-custody program, all of which have been employed in actual programs but are given as options for the development of a specific chain-of-custody program. In addition, within particular chain-of-custody elements, this guide proscribes certain activities to assure that if these options are chosen, they will be implemented properly.
SCOPE
1.1 This guide contains a comprehensive discussion of potential requirements, in the analysis of water, for a sample chain-of-custody program and describes the procedures involved in sample chain-of-custody. The purpose of these procedures is to provide accountability for and documentation of sample integrity from the time samples are collected until sample disposal.  
1.2 These procedures are intended to document sample possession during each stage of a sample’s life cycle, that is, during collection, shipment, storage, and the process of analysis.  
1.3 Sample chain-of-custody is just one aspect of the larger issue of data defensibility (see 3.2.2 and Appendix X1).  
1.4 A sufficient chain-of-custody process, that is, one that provides sufficient evidence of sample integrity in a legal or regulatory setting, is situationally dependent. The procedures presented in this guide are generally considered sufficient to assure legal defensibility of sample integrity. In a given situation, less stringent measures may be adequate. It is the responsibility of the users of this guide to determine their exact needs. Legal counsel may be needed to make this determination.  
1.5 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.  
1.6 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
´1
Designation: D4840 − 99 (Reapproved 2018)
Standard Guide for
Sample Chain-of-Custody Procedures
This standard is issued under the fixed designation D4840; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
ε NOTE—This standard was reapproved with editorial changes in August 2018.
1. Scope 2. Referenced Documents
1.1 This guide contains a comprehensive discussion of 2.1 ASTM Standards:
potential requirements, in the analysis of water, for a sample D1129 Terminology Relating to Water
chain-of-custody program and describes the procedures in- D3325 Practice for Preservation of Waterborne Oil Samples
volved in sample chain-of-custody. The purpose of these D3370 Practices for Sampling Water from Closed Conduits
procedures is to provide accountability for and documentation D3694 Practices for Preparation of Sample Containers and
of sample integrity from the time samples are collected until for Preservation of Organic Constituents
sample disposal. D3856 Guide for Management Systems in Laboratories
Engaged in Analysis of Water
1.2 These procedures are intended to document sample
D4210 Practice for Intralaboratory Quality Control Proce-
possession during each stage of a sample’s life cycle, that is,
dures and a Discussion on Reporting Low-Level Data
during collection, shipment, storage, and the process of analy-
(Withdrawn 2002)
sis.
D4841 Practice for Estimation of Holding Time for Water
1.3 Sample chain-of-custody is just one aspect of the larger
Samples Containing Organic and Inorganic Constituents
issue of data defensibility (see 3.2.2 and Appendix X1).
2.2 U.S. EPA Standard:
U.S. EPA Good Automated Laboratory Practices
1.4 A sufficient chain-of-custody process, that is, one that
provides sufficient evidence of sample integrity in a legal or
3. Terminology
regulatory setting, is situationally dependent. The procedures
3.1 Definitions:
presented in this guide are generally considered sufficient to
3.1.1 For definitions of terms used in this standard, refer to
assure legal defensibility of sample integrity. In a given
Terminology D1129.
situation, less stringent measures may be adequate. It is the
responsibility of the users of this guide to determine their exact
3.2 Definitions of Terms Specific to This Standard:
needs. Legal counsel may be needed to make this determina-
3.2.1 custody, n—physicalpossessionorcontrol;asampleis
tion.
under custody if it is in possession or under control so as to
1.5 This standard does not purport to address all of the prevent tampering or alteration of its characteristics.
safety concerns, if any, associated with its use. It is the
3.2.2 data defensibility, n—a process that provides sufficient
responsibility of the user of this standard to establish appro-
assurance, both legal and technical, that assertions made about
priate safety, health, and environmental practices and deter-
a sample and its measurable characteristics can be supported to
mine the applicability of regulatory limitations prior to use.
an acceptable level of certainty. See Appendix X1 for a
1.6 This international standard was developed in accor-
discussion of the elements of a data defensibility process.
dance with internationally recognized principles on standard-
3.2.3 sample, n—a portion of an environmental or source
ization established in the Decision on Principles for the
matrix that is collected and used to determine the characteris-
Development of International Standards, Guides and Recom-
tics of that matrix.
mendations issued by the World Trade Organization Technical
Barriers to Trade (TBT) Committee.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
Standards volume information, refer to the standard’s Document Summary page on
This guide is under the jurisdiction of ASTM Committee D19 on Water and is the ASTM website.
thedirectresponsibilityofSubcommitteeD19.02onQualitySystems,Specification, The last approved version of this historical standard is referenced on
and Statistics. www.astm.org.
Current edition approved Aug. 15, 2018. Published August 2018. Originally Available from U.S. Government Printing Office, Superintendent of
approved in 1988. Last previous edition approved in 2010 as D4840 – 99 (2010). Documents, 732 N. Capitol St., NW, Washington, DC 20401-0001, http://
DOI: 10.1520/D4840-99R18E01. www.access.gpo.gov.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
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D4840 − 99 (2018)
3.2.4 sample chain-of-custody, n—a process whereby a The forms may be designed to handle one sample or multiple
sample is maintained under physical possession or control samples.Asingle sample form may allow room for laboratory
during its entire life cycle, that is, from collection to disposal. chain-of-custody.
6.2.2.2 In any sampling effort, there is field information
3.2.5 sample chain-of-custody record, n—documentation
related to sample collection and field measurements that are
providing evidence that physical possession or control was
recorded. This information is not specifically part of chain-of-
maintained during sample chain-of-custody.
custody, but part of the larger aspect of data defensibility. This
information may be recorded on chain-of-custody forms or
4. Summary of Guide
other forms specific for the purpose. Record keeping may be
4.1 This guide addresses chain-of-custody procedures as
simplified if separate forms are used.
they relate to field practices, shipping methods, and laboratory
6.2.2.3 It may be useful to print field forms on polyethylene
handling of samples.
or other plastic coated paper to keep them from being affected
bywaterorchemicals.Anindelibleink,paint,orcrayonshould
5. Significance and Use
be used to enter information on the forms.
6.2.2.4 Spaces for the following information should be on
5.1 Chain-of-custody procedures are a necessary element in
the form:
a program to assure one’s ability to support data and conclu-
(1) Sample identifying name.
sions adequately from the time samples are collected until
(2) Sampling location ID, sampling point ID, date, and
sample disposal. In a legal or regulatory situation custody
sampling time interval.
documentation alone is not sufficient. A complete data defen-
(3) Signatures of sampling personnel and signatures of all
sibility scheme should be followed that fits the given situation.
personnel handling and receiving the samples.
5.2 In applying the sample chain-of-custody procedures in
(4) Project identification code (if applicable).
this guide, it is assumed that all of the other elements of data
(5) Preservation (to alert lab personnel): amount and type.
defensibility have been applied, if applicable.
(6) Number of containers (where field sub-sampling oc-
curs). Indicate number of replicates if there are multiple
5.3 Because there is no definitive program that guarantees
containers of the same sample.
legal defensibility of data integrity in any given situation, this
(7) Field notes.
guide provides a description and discussion of a comprehen-
(8) Analyses desired (may be required in some situations).
sivelistofpossibleelementsofachain-of-custodyprogram,all
(9) Sample type: grab, composite, etc.
of which have been employed in actual programs but are given
as options for the development of a specific chain-of-custody Example forms are shown in Appendix X2.
program. In addition, within particular chain-of-custody
6.2.2.5 Freight bills, post office receipts, and bills of lading
elements, this guide proscribes certain activities to assure that
should be retained as part of the permanent custody documen-
if these options are chosen, they will be implemented properly.
tation.
6.2.3 Sample Labeling:
6. Procedure
6.2.3.1 Sample labels may be in the form of adhesive labels
ortags,orboth.Tagshavetheadvantageofbeingremovableto
6.1 Facility Chain-of-Custody Standard Operating
become part of the record keeping process, although their
Procedure—Each organization should have a chain-of-custody
inadvertentlossorinappropriateremovalmayleavethesample
procedure document. This document should spell out in detail
without documentation. Labels should be made of waterproof
the specific procedures utilized at this facility to achieve
paper and indelible ink should be used to make entries.
sample chain-of-custody. It should contain copies of all the
Alternatively, sample information may be written directly on
forms used in the chain-of-custody process and detailed
the sample container, as long as the writing can be done
instructions for their use. It should be kept current and
indelibly.Containersshouldbefreefromotherlabelsandother
revisions tracked. This guide may serve as a template for the
writing to prevent any confusion. If both tags and labels are
chain-of-custody procedure document.
used, care should be taken to ensure that the information on
6.2 Sample Collection Phase:
both is identical.
6.2.1 Custody Assignment—A single field sampling person
6.2.3.2 Labels or tags should be filled out just before or
should be assigned responsibility for custody of samples. An
immediately after sample collection. Labels should contain
alternate custodian should also be assigned to cover the prime
spaces for the following information:
custodian’s absence. As few people as possible should handle
(1) Project identification code (if applicable).
samples. The assigned field sampler should be personally
(2) Sample identifying name (exactly as it appears on the
responsible for the care and custody of the samples collected
chain-of-custody record).
until they are properly transferred. While samples are in their
(3) Sampling location ID, sampling point ID, and sam-
custody, field personnel should be able to testify that no one
pling time interval.
was able to tamper with the samples without their knowledge.
(4) Safety considerations (if applicable).
6.2.2 Documentation/Field Custody Forms:
(5) Analysis schedule or schedule code (if applicable).
6.2.2.1 Standard forms should be designed and available for (6) Company or agency name.
recording custody information related to field sample handling. An example label is shown in Appendix X2.
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D4840 − 99 (2018)
6.2.4 Sample Sealing: multiple forms will be needed to accompany the sample splits.
Transfer sample identification information to the forms accom-
6.2.4.1 Sample custody seals of waterproof adhesive paper
panying the splits exactly as it appears on the primary receipt
may be used to detect unauthorized tampering with samples
laboratory chain-of-custody form. If an LIMS label is used for
prior to receipt by the lab. When seals are used, they shall be
appliedsothatitisnecessarytobreaktheminordertoopenthe the sample splits, a duplicate should be placed on the chain-
of-custody form that accompanies them. Example forms are
sample container.
shown in Appendix X2.
6.2.4.2 Electrical (vinyl) tape may be used to prevent bottle
closures from loosening in transit. Tape should be applied
6.3.2 Laboratory Sample Receipt and Handling:
before any custody seals are applied.
6.3.2.1 In the laboratory, assign a sample custodian(s) to
receive the samples. It is preferable to assign one person the
NOTE 1—Electrical tape should not be used to seal vials used for
primary responsibility to receive samples as the sample custo-
volatile organic analyses due to the potential for sample contamination.
dian for the laboratory. A second person should serve only as
6.2.5 Field Transfer of Custody and Shipment:
an alternate.
6.2.5.1 Package samples properly for shipment to insure
6.3.2.2 Upon receipt of a sample, the custodian should
sample integrity, and transport them to the laboratory for
inspect the condition of the sample and the custody sample
analysis.Specialcareshouldbetakenwhenpackaginginglass.
seal, if used. If sample seals are used, record condition on
It is important that all laws and regulations related to the
chain-of-custody record. Reconcile the information on the
transport of materials have been adequately addressed before
sample label against that on the chain-of-custody record. The
shipping samples.
temperature of the samples should be recorded on the chain-
6.2.5.2 When employing a common carrier, the use of
of-custody record. If samples are not delivered in a cooler,
padlocks or custody seals on shipping containers should be
indicate on record. If pH adjustment to preserve the sample
considered.Ifpadlocksareemployed,thekeysshallbeshipped
was done in the field, the pH of the samples should be checked
separately from the samples. Alternatively, padlocks may be
and recorded on the chain-of-custody record.
sent unfastened to the field and the keys can be retained by the
6.3.2.3 If a sample container is leaking, note it on the
laboratory sample custodian (see 6.3.2.1). A separate custody
custody record. The custodian, along with the supervisor
record should accompany each shipment. Enter the method of
responsible for the analytical work, should decide whether the
shipment, courier name(s), and other pertinent information in
leaky sample is valid. If seals are used, the custodian should
the “remarks” section on the custody record.
examine whether the sample seal is intact or broken, since a
6.2.5.3 If sent by mail, register the package with return
broken seal may mean sample tampering and may make
receipt requested.
analytical results inadmissible as evidence in court. Any
6.2.5.4 When transferring the possession of samples, the
discrepancies between the information on the sample label and
individuals relinquishing and the individuals receiving the
seal and the information on the chain-of-custody record should
samples should sign, date, and note the time on the custody
be resolved before the sample is assigned for analysis. This
record. Document any opening and closing of the sample
effort might require communication with the sample collector.
containers on the custody record. Provisions should be made
Record the results of any such investigation.
for receipt of samples at nonstandard hours, such as nights and
weekends by nonlaboratory personnel. Shipping documents, 6.3.2.4 After processing the sample, (splitting, logging,
with noted time of receipt and receipt by whom, should be preserving) record all sample splits on th
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