Standard Guide for Sampling Chain-of-Custody Procedures

SIGNIFICANCE AND USE
Chain-of-custody procedures are a necessary element in a program to assure one's ability to support data and conclusions adequately in a legal or regulatory situation, but custody documentation alone is not sufficient. A complete data defensibility scheme should be followed.
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.
SCOPE
1.1 This guide contains a comprehensive discussion of potential requirements 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 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.
1.6 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 and health practices and determine the applicability of regulatory limitations prior to use.

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NOTICE: This standard has either been superseded and replaced by a new version or withdrawn.
Contact ASTM International (www.astm.org) for the latest information
Designation: D4840 − 99 (Reapproved 2010)
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.
1. Scope 1.7 This international standard was developed in accor-
dance with internationally recognized principles on standard-
1.1 This guide contains a comprehensive discussion of
ization established in the Decision on Principles for the
potential requirements for a sample chain-of-custody program
Development of International Standards, Guides and Recom-
and describes the procedures involved in sample chain-of-
mendations issued by the World Trade Organization Technical
custody.Thepurposeoftheseproceduresistoprovideaccount-
Barriers to Trade (TBT) Committee.
abilityforanddocumentationofsampleintegrityfromthetime
samples are collected until sample disposal.
2. Referenced Documents
1.2 These procedures are intended to document sample
2.1 ASTM Standards:
possession during each stage of a sample’s life cycle, that is,
D1129 Terminology Relating to Water
during collection, shipment, storage, and the process of analy-
D3325 Practice for Preservation of Waterborne Oil Samples
sis.
D3370 Practices for Sampling Water from Closed Conduits
1.3 Sample chain-of-custody is just one aspect of the larger
D3694 Practices for Preparation of Sample Containers and
issue of data defensibility (see 3.2.2 and Appendix X1).
for Preservation of Organic Constituents
D3856 Guide for Management Systems in Laboratories
1.4 A sufficient chain-of-custody process, that is, one that
Engaged in Analysis of Water
provides sufficient evidence of sample integrity in a legal or
D4210 Practice for Intralaboratory Quality Control Proce-
regulatory setting, is situationally dependent. The procedures
dures and a Discussion on Reporting Low-Level Data
presented in this guide are generally considered sufficient to
(Withdrawn 2002)
assure legal defensibility of sample integrity. In a given
D4841 Practice for Estimation of Holding Time for Water
situation, less stringent measures may be adequate. It is the
Samples Containing Organic and Inorganic Constituents
responsibility of the users of this guide to determine their exact
2.2 U.S. EPA Standard:
needs. Legal counsel may be needed to make this determina-
tion. U.S. EPA Good Automated Laboratory Practices
1.5 Because there is no definitive program that guarantees
3. Terminology
legal defensibility of data integrity in any given situation, this
3.1 Definitions—For definitions of terms used in this guide,
guide provides a description and discussion of a comprehen-
refer to Terminology D1129.
sivelistofpossibleelementsofachain-of-custodyprogram,all
of which have been employed in actual programs but are given
3.2 Definitions of Terms Specific to This Standard:
as options for the development of a specific chain-of-custody
3.2.1 custody—physical possession or control. A sample is
program. In addition, within particular chain-of-custody
under custody if it is in possession or under control so as to
elements, this guide proscribes certain activities to assure that
prevent tampering or alteration of its characteristics.
if these options are chosen, they will be implemented properly.
3.2.2 data defensibility—a process that provides sufficient
1.6 This standard does not purport to address all of the
assurance, both legal and technical, that assertions made about
safety concerns, if any, associated with its use. It is the
a sample and its measurable characteristics can be supported to
responsibility of the user of this standard to establish appro-
priate safety, health, and environmental practices and deter-
mine the applicability of regulatory limitations prior to use. 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 Feb. 1, 2010. Published March 2010. Originally AvailablefromU.S.GovernmentPrintingOfficeSuperintendentofDocuments,
approved in 1988. Last previous edition approved in 2004 as D4840 – 99 (2004). 732 N. Capitol St., NW, Mail Stop: SDE, Washington, DC 20401, http://
DOI: 10.1520/D4840-99R10. www.access.gpo.gov.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D4840 − 99 (2010)
an acceptable level of certainty. See Appendix X1 for a information may be recorded on chain-of-custody forms or
discussion of the elements of a data defensibility process. other forms specific for the purpose. Record keeping may be
simplified if separate forms are used.
3.2.3 sample—a portion of an environmental or source
6.2.2.3 It may be useful to print field forms on polyethylene
matrix that is collected and used to determine the characteris-
tics of that matrix. or other plastic coated paper to keep them from being affected
bywaterorchemicals.Anindelibleink,paint,orcrayonshould
3.2.4 sample chain-of-custody—aprocesswherebyasample
be used to enter information on the forms.
is maintained under physical possession or control during its
6.2.2.4 Spaces for the following information should be on
entire life cycle, that is, from collection to disposal.
the form:
3.2.5 sample chain-of-custody record— documentation pro-
(a) Sample identifying name.
viding evidence that physical possession or control was main-
(b) Sampling location ID, sampling point ID, date, and
tained during sample chain-of-custody.
sampling time interval.
(c) Signatures of sampling personnel and signatures of all
4. Summary of Guide
personnel handling and receiving the samples.
4.1 This guide addresses chain-of-custody procedures as
(d) Project identification code (if applicable).
they relate to field practices, shipping methods, and laboratory
(e) Preservation (to alert lab personnel): amount and type.
handling of samples.
(f) Number of containers (where field sub-sampling oc-
curs). Indicate number of replicates if there are multiple
5. Significance and Use
containers of the same sample.
5.1 Chain-of-custody procedures are a necessary element in
(g) Field notes.
a program to assure one’s ability to support data and conclu-
(h) Analyses desired (may be required in some situations).
sions adequately in a legal or regulatory situation, but custody
(i) Sample type: grab, composite, etc.
documentation alone is not sufficient. A complete data defen-
Example forms are shown in Appendix X2.
sibility scheme should be followed.
6.2.2.5 Freight bills, post office receipts, and bills of lading
5.2 In applying the sample chain-of-custody procedures in
should be retained as part of the permanent custody documen-
this guide, it is assumed that all of the other elements of data
tation.
defensibility have been applied, if applicable.
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
(a) Project identification code (if applicable).
samples. The assigned field sampler should be personally
(b) 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
(c) SamplinglocationID,samplingpointID,andsampling
custody, field personnel should be able to testify that no one
time interval.
was able to tamper with the samples without their knowledge.
(d) Safety considerations (if applicable).
6.2.2 Documentation/Field Custody Forms:
(e) Analysis schedule or schedule code (if applicable).
6.2.2.1 Standard forms should be designed and available for
(f) Company or agency name.
recording custody information related to field sample handling.
An example label is shown in Appendix X2.
The forms may be designed to handle one sample or multiple
6.2.4 Sample Sealing:
samples.Asingle sample form may allow room for laboratory
chain-of-custody. 6.2.4.1 Sample custody seals of waterproof adhesive paper
6.2.2.2 In any sampling effort, there is field information may be used to detect unauthorized tampering with samples
related to sample collection and field measurements that are prior to receipt by the lab. When seals are used, they shall be
recorded. This information is not specifically part of chain-of- appliedsothatitisnecessarytobreaktheminordertoopenthe
custody, but part of the larger aspect of data defensibility. This sample container.
D4840 − 99 (2010)
6.2.4.2 Electrical (vinyl) tape may be used to prevent bottle 6.3.2 Laboratory Sample Receipt and Handling:
closures from loosening in transit. Tape should be applied
6.3.2.1 In the laboratory, assign a sample custodian(s) to
before any custody seals are applied.
receive the samples. It is preferable to assign one person the
primary responsibility to receive samples as the sample custo-
NOTE 1—Electrical tape should not be used to seal vials used for
volatile organic analyses due to the potential for sample contamination. dian for the laboratory. A second person should serve only as
an alternate.
6.2.5 Field Transfer of Custody and Shipment:
6.3.2.2 Upon receipt of a sample, the custodian should
6.2.5.1 Package samples properly for shipment and trans-
inspect the condition of the sample and the custody sample
port them to the laboratory for analysis. Special care should be
seal, if used. If sample seals are used, record condition on
taken when packaging in glass. It is important that all laws and
chain-of-custody record. Reconcile the information on the
regulations related to the transport of materials have been
sample label against that on the chain-of-custody record. The
adequately addressed before 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
laboratory sample custodian (see 6.3.2.1). A separate custody
6.3.2.3 If a sample container is leaking, note it on the
record should accompany each shipment. Enter the method of
custody record. The custodian, along with the supervisor
shipment, courier name(s), and other pertinent information in
responsible for the analytical work, should decide whether the
the “remarks” section on the custody record.
leaky sample is valid. If seals are used, the custodian should
6.2.5.3 If sent by mail, register the package with return
examine whether the sample seal is intact or broken, since a
receipt requested.
broken seal may mean sample tampering and may make
6.2.5.4 When transferring the possession of samples, the
analytical results inadmissible as evidence in court. Any
individuals relinquishing and the individuals receiving the discrepancies between the information on the sample label and
samples should sign, date, and note the time on the custody
seal and the information on the chain-of-custody record should
record. Document any opening and closing of the sample
be resolved before the sample is assigned for analysis. This
containers on the custody record. Provisions should be made
effort might require communication with the sample collector.
for receipt of samples at nonstandard hours, such as nights and
Record the results of any such investigation.
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 the laboratory chain-of-
made part of the custody record.
custody form. When the sample is logged, the sample identi-
6.3 Laboratory Handling and Analysis Phase: fyinginformationshouldbetranscribedexactlyasitappearson
the field chain-of-custody form. If custody transfer to analyti-
6.3.1 Documentation—Laboratory Custody Forms:
cal staff will not occur immediately or if sample processing is
6.3.1.1 The sample chain-of-custody record in the labora-
delayed, the samples should be transferred to the custody
tory is traditionally maintained on paper forms. Based on the
lockup (see 6.3.3). Record all transfers to and from a lockup on
data defensibility needs of the organization, it may be possible
the chain-of-custody form. The custody form should remain
to maintain the laboratory record in an electronic fo
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