NYSDOH ELAP Decision Trees

In our previous blog post on the Professional Abatement Contractors of New York's (PACNY's) 16th Annual Environmental Conference, we mentioned that Dr. Stephanie Ostrowski, of the New York State Department of Health's Environmental Laboratory Approval Program (ELAP), was one of the presenters.  Dr. Ostrowski's presentation, as we mentioned in our blog, included lengthy discussions on vermiculite and ceiling tiles.
 
The discussion regarding ceiling tiles included reviewing the decision trees she provided us to help explain the analysis process for regular bulk samples and samples required to undergo gravimetric reduction.  Analysis of friable bulk sample (material) must use analysis method 198.1, while non-friable, organically bound (NOB) bulk material must use analysis method 198.6/198.4.  Visit my website under Resources for the copy of the decision trees she provided us.  Her explainations were excellent and the decision trees did make it easier to understand. 

There was also some discussion regarding whether this meant that ceiling tiles were considered NOBs and hence could be removed under the In-plant regulations of New York State Department of Labor (NYSDOL) Industrial Code Rule 56 (ICR56).  Mr. Chris Alonge of NYSDOL came to the microphone and immediately put that issue to rest, saying that ceiling tiles are not considered non-friable, so as such cannot be removed under the In-plant operations section of the regulation.  This year's conference was as informative as usual, a great job was done by PACNY, Deborah Johnson of Aramsco, Darren Yehl of LeChase Construction Services and Kevin Hutton of Cornerstone Training Institute.

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What Happened with NYS ELAP Ceiling Tile Analysis?

On April 8, 2011, New York State Department of Health's Environmental Laboratory Approval Program (ELAP) issued an FAQ regarding asbestos sample analysis.  In this FAQ, ELAP informed us that ceiling tiles with cellulose need to be analyzed using the procedures in Items 198.6/198.4.  This meant analysis using gravimetric reduction and inconclusive results requiring transmission electron microscopy analysis (TEM).  In addition, the NYS Education Department (SED) in their newsletter #107 (July 2011) recommended that if schools have not tested their ceiling tiles in accordance with the current protocols, they should do so either as part of an existing or planned capital improvement or as an independent analysis prior to disturbance.

Well its been over six months since this new procedure/protocol was announced, and next month it will be six months since the SED clarification.  We would like to hear if this procedure has led to any new findings/concerns or are ceiling tiles still coming back primarily not containing asbestos?  Please let us know what you are experiencing regarding this issue?  So, far our experience is that most ceiling tiles are coming back not containing asbestos.  What is your experience?

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