Defining Full and Partial Implementation of Standards

What is the difference between full implementation and partial implementation of a standard? Many forensic science service providers (FSSPs) have shared their experiences with the OSAC Program Office about the challenge of defining partial implementation. Does the FSSP satisfy sufficient criteria to report that it has achieved partial implementation of a standard or should they report it as not yet implemented?

The purpose of this article is to share the experiences of six FSSPs in addressing the challenge of defining partial implementation and the recommendations they provided to help others mitigate this challenge.

The design of OSAC was created specifically to give voice to grass roots FSSPs in the development and implementation of standards. Throughout the history of OSAC, its membership has been composed of more than 50% practitioners. The reason behind this operational strategy is that OSAC can only succeed if the forensic science community buys into the standards that have been developed and posted on the OSAC Registry. The best way to win buy-in is to empower practitioners with a voice in the process of standards development and implementation. While it is no guarantee that the forensic science community will buy into implementing standards by consistently maintaining more than 50% practitioner representation on OSAC membership, there is certainly no possibility of success without it.

For this reason, OSAC has consistently encouraged forensic science service providers to own their quality system from the bench up. By developing a framework where the bench scientists through their section technical leaders are represented to senior management and the QA manager, participative management is the surest path to commitment to standards implementation in any organization. With over 140 standards now on the OSAC Registry and more than 125 laboratories having submitted to OSAC their standards implementation declaration forms, we have evidence-based data to demonstrate that strategy of participative management is bearing fruit in achieving the OSAC mission.

Rather than creating one single OSAC definition of full and partial implementation and forcing that definition to be applicable and effective for all forensic science service providers from the top down, we elected instead to ask six FSSPs to provide examples of their own definitions and share them with other forensic science organizations in the newsletter and the OSAC website. We encourage each agency to discuss and develop their own definitions internally and apply them consistently across all disciplines within their organizations.

1. From Tate Yeatman, Crime Laboratory Director, Palm Beach County Sheriff's Office:

• The following definitions have been created to help you fill out the form and determine if you are fully or partially implementing a standard.
  • Fully implemented: All requirements within an OSAC registry standard have been implemented where applicable.
  • Partially Implemented: Not all requirements within an OSAC registry standard have been implemented where applicable. 
  • Applicable standards: Standards that can be applied. Note: A standard is not applicable only if we currently do not perform the laboratory activity or have the instrumentation referred to within the standard.

2. From Eva M. L. King, Quality Assurance Director, Wisconsin Stat Crime Laboratories:

• We wanted the definitions to have flexibility and Unit (Leader) authority. Here they are:
  • Partial implementation: Compliance with a portion of an OSAC standard as defined by the declaring unit. 
  • Full implementation: Complete compliance of OSAC standard upon declaration or update by the unit.

3. From Reta Newman, Director, Pinellas County Forensic Laboratory:

• Full implementation:
  • all REQUIRED (shall) criteria are met, and
  • the majority of RECOMMENDED (should) criteria have been met
• Partial implementation: 
  • some but not all, of the REQUIRED (shall) are met or majority of RECOMMENDED (should) have not been met
  • AND it is our intent to work toward full compliance (through additional validation, policy revisions, training, etc.).

4. From Peter Stout, CEO and Erika Ziemak, former Quality Manager, Houston Forensic Science Center:

• Here are two excepts from the HFSC Quality Manual, effective March 15, 2022:
  • [Full Implementation:] HFSC staff will follow the requirements set forth in this manual as well as those in the current version of ISO/IEC 17025 General Requirements for the Competence of Testing and Calibration Laboratories, any applicable supplemental requirements, and the current FBI Quality Assurance Standards for Forensic DNA Testing Laboratories. Applicable sections are accredited by and follow the requirements of the Texas Forensic Science Commission (TFSC). HFSC will also meet applicable standards published on the Organization of Scientific Area Committees (OSAC) for Forensic Science Registry. If TFSC requirements conflict with OSAC Registry standards, HFSC will follow the TFSC requirements.
  • [Partial Implementation:] Discipline-specific manuals will not be less stringent than this Quality Manual. OSAC Registry includes standards applicable to individual forensic science disciplines as well as cross-disciplinary use. When applicable standards are published on the OSAC Registry, these will be implemented within a year of being published. Once an OSAC Registry standard has been implemented, conformance and clauses that cannot be followed in their totality will be documented in the HFSC OSAC Registry Compliance Form located in Qualtrax. 

A slightly different approach was adopted by the Kentucky State Police Forensic Science Laboratories and the Texas Department of Public Safety Crime Laboratory Division. Their quality system operates without using specific definitions of full or partial implementation but rather uses the following language in their Quality Manuals.

5. From Jeremy Triplett, Laboratory Director, Kentucky State Police Central Forensic Science Laboratory:

• Seized Drugs Quality Manual (current revision effective 7/27/20):

  • 7.2.1 Selection and verification of methods

    • 7.2.1.1  The Kentucky State Police Seized Drugs section adheres to standards and guidelines from the Organization of Scientific Area Committees for Forensic Science (OSAC) and recommendations by the Scientific Working Group for the Analysis of Seized Drugs (SWGDRUG) in formulating its testing methods and procedures. During the annual review of seized drugs documents, OSAC and SWGDRUG standards, guidelines, and recommendations that have been published within the prior year will be evaluated for incorporation into the laboratory’s policies and procedures.

  • ​​​​​​​7.7 Ensuring the validity of results

    • ​​​​​​​ 7.7.1  The seized drugs section ensures the validity of results with quality control schemes including but not limited to:

      • ​​​​​​​Adherence to Organization of Scientific Area Committees (OSAC) standards and guidelines

​​​​​​​​​​​​​​​​​​​​​​​​​​​​6. From Melissa Valadez, Assistant Laboratory Director – Technical Services, Texas Department of Public Safety Crime Laboratory Division:

• We don’t define full or partial implementation in our policies for Texas DPS.
• We did update our primary manual earlier this year to discuss the general implementation of OSAC standards. The revision was in our Quality Policy Statement:
  • ​​​​​​​C. The Laboratory is committed to providing an impartial, defect-free service to all customers through:
    • ​​​​​​​8. Implementation of applicable published standards on the Organization of Scientific Area Committees (OSAC) for Forensic Science Registry.
• ​​​​​​​Generally, we don’t consider a standard to be fully implemented until we can point to a policy that demonstrates compliance. Some of the standards that we are marking as partially implemented are just waiting for SOP updates. In practice, they are fully implemented, but the requirements from the standards are not described or outlined in policy yet.