Vermiculite Questions and Answers – LAB.055.1* and 198.8
Recently changes to the New York State Department of Health’s (NYS DOH) requirements for vermiculite containing materials have made staying current and up-to-date with the guidelines for compliance critical. Thousands of structures across New York State with spray-on fireproofing containing vermiculite (SOF-V) are affected by these new regulations. RJ Lee Group is here to assist with answering your questions about these rule changes and to provide you with details on the available techniques for analysis.
The following questions were asked during the Question & Answer segments of the first three webinars in the RJ Lee Group Webinar Series: New York State Regulation of Vermiculite. To view these webinars, please fill out the form to the left. To ask a question, please scroll to the bottom of the page.
Basic Information
Can you talk about the difference between asbestos fibers and asbestos forms found in your presentation?
Asbestos fibers refer to the crystal habit of formation of asbestos; i.e., long, thin fibrils with parallel sides and high aspect ratios. The asbestos form refers to the mineral name of the specific asbestos fiber. There are six regulated forms of asbestos. (See EPA Guidelines) – Webinar #1
At what percentage in a bulk sample is winchite and richterite considered to be a health concern?
On a per unit exposure basis, there is no reason to expect that winchite/richterite asbestos will be significantly different than other amphibole asbestos. HOWEVER, for a given work practice, which ultimately determines the level of airborne exposure, you can expect that it will take higher levels of winchite/richterite asbestos to produce the same exposure levels as a commercial asbestos that was artificially added to the product. This is because the percentage of fine fibers will be less, and a significant portion of the material will be trapped by the vermiculite. Webinar #1
Do you typically see more fiberglass or chrysotile in the samples you receive?
Most of the samples examined to date contain fiberglass rather than chrysotile; this is based on the age of the spray-on fireproofing material. The transition from chrysotile to fiberglass took place after the asbestos regulations were introduced in the 1970s. Older samples of spray-on fireproofing will likely contain chrysotile, while newer samples contain fiberglass rather than chrysotile. Webinar #3
How many samples must be analyzed for each method?
As far as samples needed for the methods, it’s going to be based on the same practices you employ for NESHAPS and EPA requirements. If you have 1000-5000 sq ft, a minimum of 5 samples are required. Over 5000 sq ft, a minimum 7 samples are required. Often, more are taken to ensure that a reliable determination is made. There is a difference in the amount of sample material needed for the new methods. For both LAB.055.1 and 198.8, you need to get about 10 grams of material, although LAB.055.1 can be performed with 5 grams. Webinar #1
Why does the lab request so much material when you only need 3-5 grams for analysis?
In order to determine whether or not the sample has multiple layers of spray-on fireproofing, and to obtain a representative sample of the material, it is necessary to sample the SOF-V from the inside surface adjacent to the steel out to the exterior surface. This requires a larger sample. Webinar #3
What are the turnaround times for vermiculite analysis?
RJ Lee Group’s standard turnaround time for spray-on fireproofing samples is 10 days. Webinar #3
Would it be preferred to test the ore or popped vermiculite rather than the fireproofing?
Yes, this would be preferred. Ore or popped vermiculite are tested for asbestos on a routine basis by both mining and manufacturing companies. This testing is required by both OSHA and EPA for proper labeling and selling of materials regulations. The scope and frequency of testing is left up to the individual mines and producers of vermiculite products. Methods used in these tests are primarily PLM based, although TEM may also be employed. Webinar #3
However, both methods have been shown to underestimate the true quantity of asbestiform fiber in a sample. LAB.055.1 improves on these legacy methods by utilizing the latest technology, developed specifically to address these problems seen in the vermiculite mining industry. LAB.055.1 chemically dissolves the vermiculite from the sample (whether raw of expanded ore), providing highly accurate detection and quantification, as well as differentiation between regular and on-regulated forms of asbestos. Webinar #3
Have any other vermiculite producing sites had testing done for asbestos content other than Libby?
Nearly all vermiculite mines monitor for asbestiform minerals as part of their ore collection operations. Given this emphasis on quality control, RJ Lee Group has historically been a part of these efforts and routinely provides 3rd party substantiation of ore quality. The majority of vermiculite ores sold today do not contain detectable chrysotile or amphibole asbestos contamination, which is determined using standard asbestos testing procedures. Webinar #3
How often do the materials require testing for new construction products?
Because asbestos materials are not totally banned within the US, the EPA and OSHA continue to mandate that all construction materials undergo analysis (or have manufacturer certification warranting them as asbestos-free) prior to any disturbance that might cause environmental or occupational exposure. Please note that vermiculite-containing materials cannot generally be certified as asbestos-free using 198.8. Since only LAB.055.1 is capable of differentiating between regulated and non-regulated forms of asbestos, exemption from current EPA and OSHA regulation only exists when LAB.055.1 warrants the vermiculite-containing material to be free of regulated asbestiform minerals. Webinar #3
Most of my building was remodeled in the early nineties. Why should I worry about asbestos?
There are generally two reasons. The first has to do with any asbestos that may be remaining after the remodeling project. The other has to do with whether or not the asbestos amphiboles were brought in with vermiculite during the spray-on fireproofing insulation in the nineties. Although they did not add asbestos to the mixes at that time, you can have material that is hitchhiking in, as it were, with the vermiculite, as we saw in the slides in this presentation. Webinar #2
RJ Lee Group Method LAB.055.1
You stated you are approved by New York for a method called 055.1, why did you pursue your own method when the state already had 198.8?
RJ Lee Group was approached by a New York building owner about 2 years ago to develop an analytical method to measure asbestos in vermiculite spray-on fireproofing. Based on this request, the LAB.055.1 method was developed and submitted to the NYSDOH for approval. We received approval for LAB.055.1 prior to the NYSDOH making 198.8 method available. Webinar #3
Why should I care about regulated verses non-regulated amphiboles? Isn’t all of it asbestos and therefore, shouldn’t I have to go through the abatement process regardless?
The decision on whether or not to abate should be made by the industrial hygienist supervising the work and the owner agent. In samples containing non-regulated ACM, they can make a decision to use standard OSHA negative exposure assessment techniques to evaluate whether their work will create an exposure, and then base their decisions on good industrial hygiene practice on that data. The LAB.055.1 method distinguishes between regulated and non-regulated asbestiform amphiboles. Webinar #3
How is the concentration of regulated vs. non-regulated asbestos determined?
The concentration of regulated and non-regulated asbestos is determined through SEM/EDS analysis. The EDS spectra are compared to the NIST standards for regulated asbestos, and the unregulated winchite-richterite is compared to samples from Libby. The ratio of regulated to non-regulated observed in the SEM is then applied to the amount of asbestiform amphibole in PLM in Level II. Webinar #2
How does the more aggressive digestion in Level 2 affect the amphiboles?
In other words, does it damage the amphiboles in any way, and how do you know? We have run tests in which we’ve taken the five regulated amphiboles, as well as winchite-richterite, and run them through Level II processing, which is an aggressive acid-based digestion, and we have seen no elimination or dissolution of the amphibole. The process does, however, change the appearance of the amphiboles with the heat and the chemical processing, and that’s one of the reasons why we rely on the SEM/EDS to do the speciation of each mineral. Webinar #2
Should there still be a disclaimer on the lab report as the other non-regulated forms are likely to be hazardous to human health?
One of the benefits of LAB.055.1 is that it allows the Industrial Hygienist supervising the work and the owner/owner’s agent to decide whether to abate non-regulated asbestos containing material (ACM). They can use standard OSHA negative exposure assessment techniques to evaluate whether their work practices will create an exposure, and base their decisions on good industrial hygiene practice, rather than simply have to abate. Webinar #1
How does this save me money in my remodeling project?
By determining whether or not you have to abate the project you have, you can use this to determine the actual value of asbestos in your spray-on fireproofing. If necessary you have to set up barriers and to do abatement, but if you have levels underneath that, you can employ engineering controls and work practices to reduce or eliminate exposures. This generally saves money. Webinar #2
Is any of this method good for composite TSI? Or does one have to go back to 198.6?
Until our updated method is approved for TSI, you have to use 198.6. Webinar #3
Comparison of RJ Lee Group LAB.055.1 and Item No. 198.8
Can you summarize the major difference between LAB.055.1 and 198.8?
The major difference is how each method reduces the matrix to allow you to lower the detection limit and see the asbestos. In Lab.055.1, we use aggressive heat and an acid base digestion, whereas in 198.8 they separate the materials through heavy liquid separation. But we’ll be talking about this in the future in our next webinar, which will actually be on the 198.8 method, so we can expand on that method at that time. Webinar #2
Which method is more accurate?
LAB.055.1 underwent extensive comparative analysis using naturally-occurring and spiked vermiculite construction materials in order to pass the NYS DOH validation process. Throughout this work, LAB.055.1 demonstrated superior precision, including 90% accuracy in its ability to determine whether SOF-V is an asbestos-containing material (ACM), compared with a 59% effectiveness rate for method 198.6. LAB.055.1 was found to be 100% reliable in identifying both regulated and non-regulated amphibole asbestos, while NYS DOH 198.6 only showed a 5% effectiveness rate in detecting non-regulated amphibole species. In-depth testing of 198.8 found that it was unable to differentiate between regulated and non-regulated forms of asbestos, which means it reports all amphibole species as a regulated type. Webinar #3
If the state accepts 198.8, why should I do more?
There are two general reasons. First, you potentially have both regulated and non-regulated asbestos. Knowing whether you are dealing with regulated or non-regulated material allows you to make decisions based on those findings. Second, LAB.055.1 reduces the probability of false positives and false negatives, which is important for both economic and health reasons. Second, from the lab perspective, there may be a risk if you are issued a report that is technically incorrect. Webinar #1
Which method is better to eliminate false positives and false negatives?
Unfortunately, NYSDOH has yet to release validation data associated with the development of 198.8, making direct comparison of false positive/negative data unavailable at the moment. However, if non-regulated forms of amphibole are included based on incorrect identification of the amphibole asbestos, Lab.055 will more accurately eliminate false positives due to its ability to distinguish winchite/richterite type amphiboles from tremolite/actinolite using SEM-EDS techniques. PLM is unable to make these distinctions. Webinar #3
The 198.8 method uses sink float, but 055.1 uses acid base digestion—can you talk about how an analytical result might differ based on these methods?
Speaking as a PLM analyst, both the 198.8 and the LAB.055.1 methods do a good job of reducing cellulose, gypsum, and carbonates from the sample. Removal of these phases makes it easier to observe chrysotile, if present, and also lower the detection limit for PLM chrysotile analysis. However, in using PLM to analyze the sample for amphibole asbestos, the LAB.055.1 aggressive acid/base dissolution does a better job of reducing sheet silicates in the residue than heavy liquid separation/centrifugation does. Using PLM, it is easier to detect amphibole asbestos in LAB Level 2 residue because virtually all of the sheet silicates have been eliminated. Webinar #3
It appears the DOH method identifies non-regulated forms as positive. Your method does not. The non-regulated form appears in your photos to be very similar to the regulated forms. As a safety precaution should we not treat the non-regulated forms as we do the regulated forms?
The best practice is to treat any form of asbestos as a potential health hazard, whether it is regulated or not. However, if you know you have non-regulated asbestos, you can conduct an evaluation of airborne exposure levels during disturbance to see if you should abate the material, which is not permitted if you treat the material as regulated asbestos. Webinar #1
Can either of the ELAP methods be used for analysis of asbestos content in troweled-on fireproofing with >10% vermiculite?
NYS DOH has yet to approve either 198.8 or 055.1 for any materials other than SOF-V, but we are confident of their ability to provide similar analytical performance in trowel-applied fireproofing. In the meantime, other approved and applicable methods must be utilized. Webinar #3
Can this process be used to analyze loose fill insulation?
The matrix reduction techniques utilized by either the LAB.055.1 or 198.8 methods would assist in reducing the PLM detection limits used in measuring asbestos concentration of loose fill insulation, but to date, neither of these methods has been approved for loose fill vermiculite insulation.
What is the cost of both methods?
At this time (January 28, 2015) there is one lab that has applied and received their accreditation for 198.8. We have applied for accreditation, but until we receive it, we will be offering our LAB.055.1 method at the same price as the 198.8. Our method is more extensive due to the scanning electron microscopy (SEM) work, so it will cost more in the future, but until we have both options available, we’ll be offering our approved LAB.055.1 method at the same cost. Webinar #3
Item No. 198.8
What is the difference between 198.8 and EPA/600/R93/116?
In general, the EPA method is written for all types of bulk building materials in mind, and allows freedom to use multiple preparation and analytical techniques beyond PLM. Item No. 198.8 is specifically written to address the analysis of spray-on fireproofing materials containing vermiculite. Both methods use gravimetric reduction to separate the components and identify and quantify asbestos, but 198.8 employs the additional step of using heavy liquids and centrifugation to separate amphibole (and other denser minerals) from the vermiculite matrix before microscopic analysis. This leads to more accurate determination of actual asbestos content in the construction materials. NYSDOH does not recognize the EPA/600/R93/116 method, and still references the interim EPA/600/M4-82-02 method in NY state regulations. The alternative approved method, LAB.055.1, offers an even higher level of precision and accuracy, as it chemically removes the vermiculite then uses Scanning Electron Microscopy (SEM) to detect and quantify the asbestos content. LAB.055.01 is the only approved method that can provide differentiation between regulated and non-regulated forms of amphibole asbestos. Webinar #3
Have you seen any sample results yet that are ACM due to the amphibole % alone?
Because RJ Lee Group has yet to receive NYS DOH certification for its 198.8 application, we have not conducted large-scale commercial analysis of SOF-V using the this method. As a result, we’re currently unable to quantify the number of samples which might report as ACM from 198.8. Webinar #3
If so, how often does it occur?
While data on the performance of 198.8 is currently unavailable, analyses using LAB.055.1 have yet to yield a positive asbestos sample from amphibole asbestos. We have seen multiple ACMs based on chrysotile. Webinar #3