False Inspection Reports The National Market Supervision Administration clearly stipulates in Order No. 39, Article 13 of the “Regulations on the Supervision and Administration of Inspection and Testing Institutions” that inspection and testing institutions must not issue false inspection reports. A report is considered false if it contains any of the following situations, and the data or results are erroneous or cannot be verified. 1. Sample Collection Management The methods of obtaining, managing samples, and sample preparation are crucial for the authenticity, accuracy, and completeness of inspection reports. During supervision and inspection, it is common for inspection and testing institutions to have irregularities in sample management, including instances of false samples and forgery. This includes non-compliance with standards in sample collection, labeling, distribution, transfer, preparation, preservation, and disposal, leading to contamination, confusion, damage, or abnormal changes in properties. The main manifestations are: (1) Errors in on-site investigation: On-site investigation records do not accurately reflect the actual situation, such as discrepancies between the original sampling records for smoke and gas and the verification of the dust removal facility being inconsistent with the on-site verification of the water film dust removal process; (2) Cross-collection personnel: The same personnel appear at different sampling locations at the same time, such as Liu collecting wastewater samples at 13:00 on August 10, 2021, for COD, TP, TN, SS, BOD5, color, and on-site pH detection, while simultaneously at 14:05, Liu is collecting organized waste gas samples for mercury and its compounds; (3) Insufficient collection quantity: Sampling does not meet the requirements for sampling points, frequency, area, quantity, and parallel samples, such as the detection standard for volatile organic compounds in soil requiring at least 3 samples per point, but the sampling record shows only 1 sample; (4) Incomplete sampling time: Sampling records lack complete information, and sampling times do not meet standard requirements. For example, the gas sampling record lacks flow and duration information for ammonia and hydrogen sulfide; (5) Incorrect sampling containers: Sampling containers are not used correctly according to sampling specifications, such as using aluminum-plastic bags for non-methane total hydrocarbon sampling; (6) Confusion in sample transfer: Sample handover, transfer, and testing times are chaotic, such as chlorophyll A and volatile phenols being outside the institution’s CMA capability, with original sampling records showing chlorophyll A, the sample receipt form showing both chlorophyll A and volatile phenols, and the sample transfer form only having volatile phenols, while analysis records include volatile phenol results, but external reports lack data for chlorophyll A and volatile phenols; (7) Lack of pre-treatment process: The sample preparation process is a key step in testing and must follow standard methods and be traceable. For example, in the analysis records for petroleum and animal and plant oils in wastewater, there is no information on sample pre-treatment, and several sample volumes are recorded as 500.0 ml, but not all were transferred; (8) Incorrect sample preservation: For microbiological projects, water samples were not treated with fixatives to eliminate interference. 2. Instrument and Equipment Traceability Refers to the use of instruments, equipment, or facilities that have not been verified or calibrated. For example, two portable multi-parameter analyzers numbered HJK-011 and HJK-012 (used for measuring pH) have calibration records that are identical copies of the same version, with measurement values, instrument readings, and errors being the same; the atmospheric sampler numbered JK-006 is unqualified for calibration but still has usage records. 3. Inspection and Testing Methods Refers to violations of national mandatory regulations regarding inspection and testing procedures or methods. The main manifestations are: (1) Analysis time exceeded: Samples for coliform bacteria collected on June 9, 2021, were not analyzed within the valid period as they only began to circulate on June 10 at 8:50; (2) Incorrect reference standards: Standard methods have their applicability, and the methods for lead and nickel in surface water were incorrectly used (lead: GB/T 7457-1987 direct method, nickel: GB 11912-1989) with detection limits higher than standard limits; (3) Deviation from testing methods: On-site sampling sensory descriptions of water samples being yellow and turbid, while total phosphorus sample analysis did not compensate for color/turbidity; (4) Incorrect instrument configuration: The extraction equipment used for petroleum was a jet extractor; (5) Environmental condition deviations: The environmental temperature requirement for the dissolved oxygen meter usage record is 14°C to 25°C, which does not comply with the standard; (6) Lack of constant weight information: In weight methods, constant weight information is not reflected as required. For example, in the gas particulate filter membrane weighing records, the data for 12 filter membranes before and after constant weight are completely consistent, raising logical doubts; (7) Not conducting segmented testing: The adsorption efficiency of activated carbon tubes for aromatic compounds should be above 80%, meaning the combination collected by segment B should be less than 25% of segment A, but there are activated carbon tubes for aromatic compounds that were not tested according to method requirements and their sampling efficiency was not determined; (8) Quality control not synchronized: The VOCs calibration curve analysis date was May 26, 2021 (the original record was not printed), while the sample analysis date was July 2, 2021, without following method requirements for calibration curve verification; (9) Blank deviation from normal: Volatile phenols were not transported according to standard requirements, and the laboratory blank was above the detection limit, not meeting requirements; (10) Calculation errors in results: In noise measurement records, some noise fluctuations exceeded 3 decibels, belonging to non-steady noise, yet all were monitored as 1-minute steady noise. 4. Data Transmission and Preservation Refers to the failure to transmit and preserve original data and reports according to standards and regulations. This mainly refers to violations of data and information management requirements, with the main manifestations being: (1) Instrument data preservation: This is reflected in inconsistencies between paper original records and electronic storage data records. For example, the automatic smoke testing instrument YQ008-5 used for gas monitoring has original record print serial numbers from 01274-01276, but no corresponding electronic records can be found on the instrument; (2) Data incompleteness: This is reflected in the destruction and abandonment, concealment of original records, and selective use of inspection and testing data, such as the odor concentration item only having a summary of sniffing results, lacking original records for each sniffing personnel; (3) Data cannot be traced: This is reflected in the inspection report not corresponding to original data records, such as the slope of the fluoride curve equation being -50.194, the intercept being 308.62, R² being 1, and the analysis result not originating from the equation, making it untraceable; (4) Report inconsistency: This is reflected in the saved copies of inspection reports being inconsistent with the issued originals; (5) Time inconsistency: This is reflected in discrepancies between recording times and report times. For example, the wastewater ammonia nitrogen sample handover record shows the sample handover time as April 14, while the analysis time in the report shows April 13; (6) Instrument usage records: This is reflected in instrument usage records not being logged in a timely manner, with discrepancies between recorded items, users, and original records, such as the carbon monoxide meter usage record having usage time and user information inconsistent with original records.
Fraudulent Inspection Reports
1. Uninspected Data Refers to issuing data and reports directly without inspection, mainly manifested as: (1) Original data discrepancies: The report data exceeds the original detection records, such as the benzene sampling record in public places being for 6 points, with the sample handover form showing 6 activated carbon tubes, the original records and spectra being for 6 points, but the report shows results for 18 points; (2) Lack of spectra in instruments: Analysis instruments cannot trace detection data and spectra, such as lead sampling atomic absorption spectrophotometry, but the instrument computer has no original data or spectra saved, making it untraceable; (3) Identical data: Reports from different times have identical data, such as finding 3 identical numbered detection reports with sampling dates of June 1, August 1, and November 6, 2019, and issuance dates of June 15, August 15, and November 20, 2019, with completely consistent report content; (4) Overly similar results: Different sample detection results are excessively similar, such as in 22 weighing records for particulate matter, 8 pairs of data are identical to 0.01 mg, while the other 14 pairs differ by 0.01 mg, raising logical doubts. 2. Forged or Altered Records Refers to forging or altering original data, records, or not using original data and records according to standards. (1) Time logic is questionable: For example, in a certain detection report, the original record for ammonia nitrogen shows the standard substance certificate batch number as B21040500, with a certification date of March 4, 2021, while also showing the working solution preparation date as January 6, 2021, and usage time as January 6, 2021, all before the certification date; (2) Original data is questionable: For example, on May 2, 2021, from 9:48 to 11:02, Li and Yang collected surface water samples with codes JC36, JC37, JC38, while Wang and Shen collected surface water samples with codes JC61, JC62, JC63 from 9:49 to 11:03 on the same day, with the handwriting of the two original records being identical, but the sampling personnel were different, and the dissolved oxygen, redox potential, total phosphorus, ammonia nitrogen, and other indicators from different rivers and points were abnormally close; (3) Data cannot be traced: The laboratory cannot provide original information records for the constant weight and weighing of total suspended solids filter membranes, checking the balance usage records, with no records of weighing before filter membrane sampling. Checking two weighing data, the difference between the first and second weights is 0.0002 g; (4) Altered original data: The VOCs calibration curve only used 4 concentration points, and due to the linearity of acetone being unqualified, the peak area of the first concentration point was manually adjusted to meet linearity quality control requirements; (5) Spectra cannot be traced: The analysis date for volatile organic compounds was December 24, 2020, with the standard spectrum dated September 26, 2019, and the record lacked quality control measures for the standard solution, checking the standard substance usage records, with no records of volatile organic compound standard substance usage after August 19, 2020. 3. Changing Testing Items Reducing, omitting, or changing the inspection and testing items that should be tested according to standards, or altering key inspection and testing conditions. (1) Reducing testing items: For example, checking the usage records of the biochemical incubator (DQ/YQ-70) from March 25 to March 27, a total of 12 batches were cultivated, each with samples 001-006 and 001ZK, totaling 7 samples, while according to standard methods, at least 84 culture bottles should be cultivated simultaneously, and on-site verification showed that the incubator could not accommodate 84 culture bottles, raising logical doubts; (2) Standards not changed: The pH detection basis is the “Methods for the Detection and Analysis of Water and Wastewater” (Fourth Edition) by the National Environmental Protection Agency in 2002, and the monitoring basis for water quality pH has changed, but the report does not reflect this change; (3) Volume application errors: The monitoring results for non-organized waste gas particulate matter were evaluated according to “GB 16297-1996 Comprehensive Emission Standards for Air Pollutants,” with only the measured volume recorded, and the standard state volume not recorded, and the laboratory analysis also used the measured volume for calculations, leading to errors in sampling volume application; (4) Not converting according to standards: Testing results were not correctly converted according to method requirements, leading to deviations in the final report data, such as the concentration of ceramic particulate matter emissions not being converted to the standard excess air coefficient emission concentration; (5) Not synchronously removing interference: The high-flow smoke (gas) testing instrument did not test for CO interference according to standard requirements, and CO concentration was not determined during on-site inspection, making it impossible to judge the potential interference on SO2 measurement results; (6) Incomplete report items: The testing commission agreement required testing of 9 indicators, but only 2 reports were issued, one with CMA marking (7 indicators) and one without CMA marking (2 indicators), and without the consent of the commissioning party; (7) Incomplete testing items: The institution’s VOCs testing basis was HJ 734-2014 method, with a total of 24 parameters, but the CMA capability appendix only approved 19 parameters, and the testing report only listed the VOCs value (the sum of the concentrations of 19 parameters) and conducted compliance evaluation, which did not comply with regulations; (8) Testing beyond the scope: The laboratory conducted ethanol analysis based on the methanol analysis method but did not confirm the non-standard method for ethanol analysis capability, resulting in an undetected ethanol result. 4. Switching Testing Samples Switching inspection and testing samples or altering their original state for inspection and testing. For example, if the silicate in mineral water does not meet standards, to satisfy customer reporting needs, the sample is switched to commercially available mineral water for testing and reporting. 5. Forging Seals and Signatures Forging the official seal of the inspection and testing institution, the special seal for inspection and testing, or forging the signature and issuance time of the authorized signatory, which also includes signatures and writings of inspection personnel that are not their own. For example, the authorized signatory Li used a stamped signature, and upon inquiry, it was found that Li only came to the unit once a week, so urgent samples could only use the stamped signature; the original record for ammonia nitrogen detection was signed by Shao, but the content and signature of the original record were completely different from his handwriting.
Source: China Health Inspection Journal, Authors: Yang Fenghua, Wu Danqing, et al.