Who are the stakeholders for the Certification Program?
What are the main quality indicators for each stakeholder?
Who has problems with the status quo?
What are the needs that are driving the issue?
What are the politics?
Is the Certification Program addressing the problem root-cause or is it a workaround?
Is this a work around because there is no way for EPA to address the real problem?
Is there a connection with the IRS/CPA model? The Clean Water Act? NISH, other?
What is the cost benefit analysis. Would a cost benefit analysis be a waste of time since no way of knowing either.
Is the AIM of certification cleaner air? Is the aim of the EPA Division of Air and Radiation cleaner air?
How will certification result in cleaner air?
Might be better to spend the money buying old cars.
If an audit must be done, should it be an audit of the quality process and ethical culture that insures consistent results everyday or a dress rehearsal for an occasional performance.
The biggest problem with quality today in stack testing is customer need. If customers don't need quality they surely are not going to pay for it and no amount of certification will change this.
Why is the focus on present EPA Methods and not science based credible results. What's more important the method or truth?
What is the role of ethics. Why not just give all tester a lie detector test? Have you cheated on a test? Cutting corners is the real problem!!
I think it would be much more cost effective to teach observers and report reviewers how to identify bad tests and give them the authority to reject tests and audit test companies.