Metro-NY AIHA Meeting on Vermiculite, Part 2.

As we discussed in our previous post we attended the Metro New York (Metro-NY) American Industrial Hygiene Association (AIHA) chapter meeting on September 9, 2013.  This meeting was on the "New York State Asbestos & Vermiculite Analysis Guidance Update" it was presented in two parts, part one by Robert J. DeMalo, Senior Vice President of Lab. Services & Business Development and part two by Edward Cahill, Vice President of Asbesto, both from EMSL Analytical, Inc.  For pictures from the event visit Metro NY AIHA web album and for copies of EMSL's powerpoint presentation visit Metro-NY AIHA Meetings website for the Part 1 Handout and the Part 2 Handout.  Our previous post discussed part one of the presentation.  This post we will discuss part two, which was on the "Analytical Challenges of Vermiculite Containing Materials".

The second part of the presentation was significantly more complicated than the first part.  This does not mean the first part was not valuable, we are trying to indicate the second part really got into some of the details of analyzing the minerals utilizing polarized light microscopes, the quantitation of the samples, and additional methods of analysis including advantages and disadvantages (enough big words for everyone).

The second presentation started with a discussion of the new NYS DOH Guidance letter regarding the analysis of vermiculite containing materials (VCM).  We discussed this issue in our Blog on 7/21/13.  The big issue is the disclaimer being placed on the results and what is the best course of action for results that indicate greater than 10% vermiculite and less than or equal to 1% asbestos with the disclaimer.  

To understand the problems with analysis Mr. Cahill’s presentation showed us that vermiculite comes in three types – large (light), medium, & fine (dark).  See figure below:

As you can see the material is varying levels of “chunkiness”.  According to EMSL, when picking through the sample rice grain sized asbestos chunks can sometimes be detected visually.  However, the absence of these chunks does not mean the sample is asbestos free.  The polarized light microscope (PLM) methodology is strong for identification, while quantification is weak.  The PLM analysis is only as good as the prep (especially for point counting).  The sample must be uniform, random, & a monolayer (the height of a particle size prevents a nice monolayer).   Based on this information the problems regarding vermiculite analysis are:

• Particle size prohibits making a proper slide mount.
• Asbestos not always homogeneous within the sample
• Asbestos can be locked between plates & therefore not easily detected
• Non-regulated Libby Amphiboles are present.

The discussion then turned to other methods of analysis, noting that monokote fireproofing has removable matrix.  Methods with matrix removal include:

·         EPA (600) PLM NOB

·         EPA (600) TEM NOB

·         NYS ELAP 198.6 (PLM)

·         NYS ELAP 198.4 (TEM)

·         Chatfield SOP (TEM)

At this point, the preferred NYS ELAP method is 198.6, but that means you get the disclaimer on your results.  EMSL’s presentation discussed 4 different approaches of what to do regarding VCM, these approaches are:

1. Cancel or delay asbestos surveys if possible until final regulations are in place.
2. If initial analysis determines vermiculite content >10% they are stopping.  The material is treated as ACM.
3. If 198.1 analysis determines vermiculite content >10% proceed to 198.6 to determine the asbestos percentage.  Materials are classified as ACM or non-ACM accordingly, disclaimer is tolerated.
4. Approach 2 or 3 are followed for regulatory compliance and then various additional prep and analysis steps are requested.  Transmission Electron Microscopy (TEM) analysis is typically a part of this process to demonstrate “Best Available Technology”.

Options available for Approach 4 are:

• Cincinnati Method – vermiculite separated into fractions, floating, sinks, & suspended fractions.  Analysis is by a combination PLM/TEM
• CARB (CA Air Resource Board) 435 Method – Sample is milled, followed by a PLM point count
• EPA 600 Milling followed by PLM/EPA 600 Milling followed by TEM analysis – Can break out of mass percent with & without the contribution of Libby amphiboles
• ASTM TEM Qualitative Method – excellent fiber ID but no quantification
• Addison Davies Method – remove vermiculite prior analysis

We learned a lot in this seminar regarding different methodologies and the problems involved with analyzing vermiculite and VCM.  It will be interesting moving forward to see which direction the analysis of these materials goes.   Based on the presentation, the EPA 600 milling followed by TEM analysis sounds interesting and promising.  However, NYS ELAP or EPA will be making that decision and only time will tell.

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Metro-NY AIHA Meeting on Vermiculite, Part 1

We attended the Metro New York (Metro-NY) American Industrial Hygiene Association (AIHA) chapter meeting on September 9, 2013.  This meeting was on the "New York State Asbestos & Vermiculite Analysis Guidance Update" it was presented in two parts, part one by Robert J. DeMalo, Senior Vice President of Lab. Services & Business Development and part two by Edward Cahill, Vice President of Asbesto, both from EMSL Analytical, Inc.  For pictures from the event visit Metro NY AIHA web album and for copies of EMSL's powerpoint presentation visit Metro-NY AIHA Meetings website for the Part 1 Handout and the Part 2 Handout.

Sample Passed Around the During the Meeting

Some very interesting facts from the first part of the presentation included:

• The Libby mine was the source of an estimated 70-90% of all vermiculite sold in the US from 1919 to 1990.
• Veins of asbestos contaminated most, if not all of the material taken from the mine; Libby Amphibole was an accessory mineral."
• The Libby mine in 1926 opened up a vein of asbestos that is considered one of the largest deposits of asbestos ever uncovered.
• Regardless of the method used to analyze the material a mixture of regulated asbestos as well as non-regulated asbestos is likely to be encountered.
• "Libby Amphiboles" is a collective term for the complex mixture of amphiboles that are known to exist at the Libby mine site.  That mixture is Winchite (nonregulated amphibole); Richterite (nonregulated amphibole); and Tremolite (regulated amphibole).
• Increased mortality rates are observed not only among the miners and their families, even in citizens with no direct connection to the mine.  Mortality rates are 40 times higher than the rest of Montana and 60 times higher than the rest of the US.

Based on the above information it is clear that Libby Amphiboles are the problem and that the nonregulated amphibole portions of the vermiculite is also a problem.  According to the US Geological Survey, the amount of asbestiform amphiboles contaminating the Libby vermiculite as approximately 84% winchite, 11% richterite, and 6% tremolite (American Mineralogist; November 2003; v. 88; no. 11-12; p. 1955-1969).  The mortality rate indicates a need to regulate these amphiboles plus others minerals that we now typically call elongated mineral particles (see NIOSH website for more information regarding asbestos fibers and other elongated mineral particles).  In our next blog post we will discuss part two of the vermiculite meeting.

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New Vermiculite Guidance Shifts Liability to Consultants & Owners

On July 9, 2013, the New York State Department of Health (NYSDOH) Environmental Laboratory Approval Program (ELAP) released a further clarification regarding the analysis of surfacing materials, thermal system insulation, and miscellaneous materials that contain vermiculite (nothing has changed regarding loose fill vermiculite this still must be reported as an asbestos containing material (ACM)).  Visit Future Environment Design's Resource Page for the New Interim Vermiculite Guidance 7/9/13 from NYSDOH.

To sum up the changes, when you send surfacing materials, thermal system insulation, and miscellaneous materials for analysis the lab will start with the friable bulk sample method 198.1.  Once the material is determined to contain greater than 10% vermiculite the lab will then use the gravimetric reduction method 198.6.  No matter what result you get with the 198.6 method, the result must be accompanied with the following disclaimer:

“This method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing greater than 10% vermiculite.”

We think most of you would agree the problem is not with having a disclaimer on results that report >1% asbestos, these are reported as ACM with the disclaimer.  The problem & liability come from materials that are now being reported as < 1% asbestos, these will be reported as non-ACM with the above disclaimer.  As far as we are concerned this disclaimer basically says these results may not be accurate.  This change puts heavy liability on the asbestos inspector (consultant) as the person who under Industrial Code Rule 56 (ICR 56) makes this decision.  As Dr. Eileen Franco, acting director of NYSDOL Division of Safety and Health, stated "The Certified Inspector who performs the sample collection and analysis in support of the required asbestos survey is responsible for determining if a material is ACM or not.  If they classify it as ACM, it is ACM and covered by ICR 56.  If they classify it as non-ACM, ICR 56 does not apply.  DOL enforces ICR 56 which is for asbestos.  If a product has greater than 1% asbestos it is asbestos. If they do further testing of something with >10% vermiculite and it is less than or equal to 1% asbestos it is non-ACM. "

Certified Asbestos Free by Who?
Thank you Mr. Henry Alilionis for the photo.

 In our opinion, this is insufficient to advise a client on what to do with a material that has a result of < 1% ACM with the disclaimer.  So the question is how do we proceed?  We obviously need more information.  It means asbestos inspectors need to do more research on the material (material safety data sheets, manufacture specifications, etc.) and the source of the vermiculite.  If that is not possible for whatever reason, maybe other types of analysis could be used.  Presently, other methods available are the Cincinnati method (Environmental Protection Agency (EPA) method A 600/R-04/004) which is a research method or the American Society for Testing and Materials (ASTM) D22.07 method, neither are approved by NYSDOH ELAP.  However, at this point NYSDOH has given us a result which says the material is non-ACM with a disclaimer.  As asbestos inspectors we must address the disclaimer.  NYSDOH has not given us a way to do that, allowing us to find our own way.  Our advice would be to research the material and if that is now successful, then use one of the other lab methods to address the disclaimer.  In our view this is what a reasonable person would do to avoid the potential liability of exposing construction workers to asbestos.

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NYS Department Of Health Vermiculite Clarification

New York State Department of Health's (NYSDOH) Environmental Laboratory Approval Program (ELAP) has released an update that revises FAQ #10 from the 4/8/11 FAQ document.  This update is posted at:
http://www.wadsworth.org/labcert/elapcert/forms/Vermiculite%20Guidance_Rev062212.pdf.  

The revision separates vermiculite into two types.  Vermiculite material used for thermal systems insulation (TSI), surfacing materials, and other miscellaneous ACM (including but not limited to:  existing or new surfacing material, plaster, pipe lagging, and sprayed-on fireproofing) or vermiculite material used for attic fill, block fill, and other loose bulk vermiculite material.  For the vermiculite material used for attic fill, etc. nothing has changed.  We still cannot analyze it and material must be assumed to contain asbestos and designated an asbestos containing material.

New Evaluation for Surfacing Material Containing Vermiculite

For the vermiculite used for TSI, surfacing material, etc. anaylze by ELAP certification manual item 198.1 (polarized light microscopy [PLM] friable method).  Vermiculite evaluation shall follow these three steps:

1. If vermiculite is calculated to be less than 10% of the entire material composition and no asbestos fibers are detected, the material may be reported as non-ACM.
2. If any asbestos fibers are identified, analysis must proceed according to Item 198.1 PLM and reported as ACM according to Section 6.3.
3. If vermiculite is calculated to be 10% or more of the material, the material must be reported as ACM.

According to NYSDOH ELAP the reason for the difference is that vermiculite used for TSI, etc can be more constrained that loose fill, there is less of a public health concern pertaining to airborne asbestos fibers following disturbance.

Related articles

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New York State Releases FAQ on Asbestos Analysis

Image via WikipediaLate last week we received a FAQ from New York State Department of Health.  The FAQ is focused on analyzing asbestos samples and the environmental laboratory accreditation program.  The FAQ has several interesting piece of information.  Those of you who attend my classes, have heard me discuss the problems with analyzing vermiculite and the Environmental Protection Agency (EPA) statement that asbestos inspectors should not sample the material but should assume the material is asbestos.  Well Question 10 in this document states "Since there is currently no approved analytical methodology to reliably confirm vermiculite as non-asbestos containing it is best to assume vermiculite is contaminated with asbestos and proceed accordingly."  We will add this document to all our course manuals, and/or you can access the document at: http://futureenvironmentdesigns.com/Media/NYS%20Asbestos%20FAQ%20%20April%208-2011%20(2).pdf.

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Colorado Man's Home is a Living Laboratory.

Part 2 of the "Killer In The Attic" articles from AOL News discussed the story of 71 year-old William Cawlfield, who has mesothelioma.  Mr. Cawlfield lives in a two-story red-brick farmhouse in Pueblo, Colorado that had been his family's home for more than a century.  When he was 15 years old Mr. Cawlfield helped his father install Zonolite insulation in the attic.  In addition, Mr Cawlfield also said "I used to play up there and kept my toys and a bunch of books because it was like a sand pile where I could hide things,..."  He had no knowledge that the material contained asbestos.

Last month, Cawlfield stood outside his family's home watching a specially trained asbestos-removal experts wearing respirators and dressed head to toe in Tyvek carefully remove the Zonolite insulation from inside. He was paying $15,000 to have them do so.  The reason he was doing this was testing conducted by the Environmental Protection Agency's (EPA) Denver regional office found that high levels of the lethal tremolite fibers were released from the Zonolite insulation that was spread between the rafters in its attic.  EPA inspectors concluded that the almost-invisible asbestos-containing dust from the Zonolite sifted though the light fixtures and switches, ceiling fans and the seams of dried-out joint tape.  Copies of the reports from EPA (that AOL News obtained) determined that some of the levels of asbestos recorded in the house exceeded the maximum number of lethal fibers that the Occupational Safety and Health Administration (OSHA) says is too dangerous for workers.

Unfortunately, EPA continues to not provide any guidance to the asbestos abatement industry on how to handle this material and continues to rely on its website as the only source of information on this dangerous situation.

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Government Refuses to Act on Cancer-Causing Insulation

Image via WikipediaWe have discussed this issue in our asbestos initial and refresher classes.  The Zonolite insulation made from vermiculite mineral mined from the Libby, Montana.  The vermiculite from this mine is contaminated with tremolite asbestos.  Mr. Andrew Schneider wrote this excellant article "Government Refuses to Act on Cancer-Causing Insulation".  This is also an important issue for asbestos inspectors because the Environmental Protection Agency (EPA) is specifically saying not to take samples of this material.  This material gives false negative results and EPA recommends that this material be treated and handled as an asbestos containing material.  In addition, vermiculite was not only used as attic insulation, it was also used in sprayed-on fireproofing until late 1980s.  High-rise buildings built between 1980-1989, using sprayed-on fireproofing made by W.R. Grace (monokote made with vermiculite) also is suspect and again it is suggested that you do not sample this material.  This material should be assumed to be asbestos containing.

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W. R. Grace To Pay For Asbestos Cleanup in Easthampton, MA.

Image via Wikipedia

W.R. Grace and Company leased a facility in Easthampton, Massachusetts where they produced zonolite attic insulation and fireproofing.  This facility received vermiculite that was mined in Libby, MT which is known to be contaminated with tremolite asbestos.  WR Grace and the owner of the property Oldon Limited Partnership agreed to pay an estimated $833,000 to cleanup the site and reimburse the Environmental Protection Agency (EPA) for past cleanup costs of $72, 537 as recently reported by Environmental Protection (click on title to see the full article).

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Public Health Emergency Declared in Libby, Montana

As with everyone else who is aware of this tragedy we applaud the Environmental Protection Agency’s decision on June 17, 2009 to declare that a public health emergency exits at the Libby asbestos site (vermiculite mine contaminated with tremolite asbestos) in northwest Montana. The New York Times, Newsday and other newspapers covered this press release and the Asbestos Disease Awareness Organization issued their own release covering this issue. The documentary film “Dust to Dust” directed by Michael Brown told the Libby story (we have watched this film in some of our classes). As the press release indicates, this announcement, which is long overdue, will provide funds for the continued clean-up of the contaminated areas in the towns of Libby and Troy. In addition, the Department of Health and Human Services will provide grant money to provide medical care for the area residents impacted by the contamination.