Asbestos in Settled Dust The Forgotten Matrix American Industrial Hygiene Association – Metro NY New York Blood Center, NY, NY Wednesday, April 5, 2017 EMSL Analytical, Inc. Robert J. DeMalo, M.Sc. Sr. VP, Lab. Svcs. & Bus. Dev. Email: rdemalo@emsl.com EMSL Analytical Inc. 307 W. 38th Street, NY, NY Copyright EMSL 2017 1 Dust is Different EMSL Analytical Inc. EMSL Copyright 2017 2 Asbestos in Settled Dust • “Settled Dust” – Industry Definition: loose fibers and particles that have collected on building surfaces1 • ASTM Definition: Any material composed of particles in a size range of <1 mm • Generally there are 5 Sample collection methods2: • Scrape or scoop method • Adhesive Tape sampling • Vacuuming • Wiping (Wet or Dry) • Passive Monitors 1 Light, E.N. and Jankovic, J.T., Assessment of asbestos fiber release in buildings through analysis of settled dust, NAC Journal, 4(4), 9, 1986. 2 Millette, J.R. and Hays, S.M., Settled Asbestos Dust Sampling and Analysis, Lewis Publishers, Boca Raton, FL, 1994 EMSL Analytical Inc. Copyright 2017 3 Asbestos in Settled Dust • Why is asbestos in dust a problem? • The concerns with settled dust are that routine housekeeping or maintenance work may result in unnecessary worker exposures or further contamination of a building environment • 1994 OSHA reg. housekeeping section: “dust and debris in an area containing TSI or surfacing ACM/PACM or visibly deteriorated ACM, shall not be dusted or swept dry, or vacuumed without using a HEPA filter”1 • The National Institute of Building Sciences (NIBS) addressed this issue in their 2nd Edition of the Guidance Manual Asbestos Operations and Maintenance work practices 10 Occupational Safety and Health Administration Field Operations Manual. “Instruction CPL 2-2.0A, March 1984, Chapter VII: Sampling for Surface Contamination. 1.h. 1 EMSL Analytical Inc. Copyright 2017 4 Scenario 1: Spot Check Settled Dust Sampling can give us a spot check when we come across a suspicious dust covering a surface. • • • • Dust Bunny: Tape lift: Microvac: Wipe: EMSL Analytical Inc. PLM +/or TEM PLM +/or SEM TEM TEM Copyright 2017 5 Scenario 2: Passive Dust fall Settled Dust sampling can show us evidence of asbestos that is currently accumulating (i.e. VAI) Settling Tins Structures or fibers per gram per area and per time period Sampling times anywhere from 1 week to over a year PetriSlides Indiamart.com EMSL Analytical Inc. Copyright 2017 6 Scenario 3:Hidden Reservoirs Settled Dust Sampling can show us a reservoir of asbestos that has accumulated over years EMSL Analytical Inc. Copyright 2017 7 Scenario 1: Spot Checks Is that asbestos? Business card collection PLM Qualitative – detect/non detect Quantitative - % (not a building material) TEM Qualitative Quantitative Limitations of Quantitative - non homogeneity, insufficient sample? - % such as 1% not applicable anyway - in loose dust, fibers often not visible by LM EMSL Analytical Inc. Copyright 2017 8 Scenario 1: Spot Check Is that asbestos? Tape Lift (clear) collection PLM • Qualitative • Quantitative (poor) SEM • Qualitative • Quantitative (poor) Limitations of Quantitative • non homogeneity • % such as 1% not applicable anyway • fibers often not be visible (too small for LM) EMSL Analytical Inc. Copyright 2017 9 Scenario 2: Dust fall Is there Asbestos Dust Settling over Time? Passive Dust Collection PLM - maybe (if enough material) Limitations Often insufficient material, fibers too small %age such as 1% not applicable anyway TEM - Yes - Qualitative - Quantitative - fibers/gram - fibers per square meter per 30 days EMSL Analytical Inc. Copyright 2017 10 Scenario 2: Dust fall Designation: D1i'39 - 93 (Fleappreued ~ull Hi "mam Standard Test Method fer Cellectien and Measurement ef Dustfall (Settleable Particulate Matter)? This standard is issued under Ute lised designatien the number immediately l'c-llewing the designatien indicates the year ef eriginal adeptien er. in the case at res'isien. Ute yearel' last rerisien. A number in paiend'leses indicates the year at last reappraisal. a superscript epsilc-n tel indicates an editerial change since Ute last res?isien er reappraisal. l. Scepe 1.1 This test methed cevers a precedttre fer cellectien ef dustfall and its measurement. This test methed is net appre- priate fer determinatien ef the dustfall rate in small areas affected by speci?c settrces. This test methed describes deter- minatien ef beth water-seluble and particulate mat- ter. 1.2 This test methed is inapprepriate fer industrial hygiene use escept where ether mere speci?c metheds are alse used. 1.3 This startdantr daes hat parpart ta address al'i af the saer caiiceriis. if ah}: asst:ciateal with its are. it is the respahsihil'iri.? af the riser af this standard ta estahiish appra- priate s'rnfetjc and heaith practices and deteritriae the appiica- hil'irt' af repaititaijr priar ta ase. 2. Referenced Iiecuments 2.1 .4323? Standards; EMSL Analytical Inc. Copyright 2017 3. Terminelepjt' 3.1 De?aitiaas?Fer de?nitiens ef terms used in this test methed. referte Terminelegjt I3l3?t?i. An esplanatien ef units. and cens'ersien facters may be feund in Practice E3313. 3.2 De?aitiaa {if Teritis Specific ta This Standard: 3.2.1 settieahie patticaiate material' any material cem- pesed ef particles small eneugh te pass threugh a 1-mm screen isee Speci?catien and large eneugh te settle by 1.tirtue ef their weight inte the centainer frem the ambient air. 4. Summary uf Test hlethetl 4.1 IEentainers ef a standard size and shape are prepared and sealed in a laberatery and then epened and set up at apprepri- ately chesen sites se that particulate matter can settle inte them fer perieds ef abeut 313 days. The centainers are then clesed and retunied te the laberaters'. The masses ef the water-seluble 11 Scenario 3: Hidden Reservoirs Air Sampling, even only a few hours after serious disturbances can yield low air concentrations. (NIOSH 7402 does not count small, thin fibers: AR ≥ 3:1, longer than 5µm, diameter greater than 0.25 µm) This can give a false sense of security to occupants. EMSL Analytical Inc. Copyright 2017 12 Scenario 3: Hidden Reservoirs Air Samples are snapshots in time A microvac or wipe of settled dust can find a reservoir of asbestos accumulated over long periods. EMSL Analytical Inc. Copyright 2017 13 13 Scenario?iddenReseW EMSL Analytical Inc. Copyright 2017 14 Scenario 3: Hidden Reservoirs • ASTM 5755 (and 5756) MicroVac • ASTM 6480 Wipe • Carpet Sonication “Method” No coincidence that they are all TEM methods Asbestos in settled dust can be extremely fine and not visible to a light microscope EMSL Analytical Inc. Copyright 2017 15 EMSL Analytical IncToo Small for Li Mi croscopy Carpet Sonication Known areas are sonicated to remove particulate. Then the rinsate is filtered. Results in fibers or structures/cm2 EMSL Analytical Inc. Copyright 2017 17 ASTM Micro Vac Method Tl??lm Standard Test Method for Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structure Number Surface Loading1 This standard is issued under me iised designation 135755: Ihe number immediately following the designation indicates die year of original adoption or. in the case of revision. die year of last revision. A number in parendteses indicates Ihe year of last reappraisal. A superscript epsilon tat indicates an editorial change since the last resisien or reappraisal. 1. Scope This test method covers a procedure to [all identify asbestos in dust and {it} provide an estimate of the surface loading of asbestos in the sampled dust reported as the number of asbestos structures per unit area of sampled surface. 1. .1 If an estimate of the asbestos mass is to be determined. the user is referred to Test Method Ij?i'fi?. 1.2 This test method describes the equipment and proce? dures necessary for sampling. by a micros'acuum technique. non-airbonie dust for levels of asbestos structures. The non- airbonie sample is collected inside a standard ?lter membrane cassette from the sampling of a surface area for dust which may contain asbestos. This procedure uses a microvacuuming sampling tech- nique. The collection ef?ciency of this technique is unknown and will vary among substrates. Properties in?uencing collec- asbestos as sampled. More speci?cally. the procedure de? scribed neither creates nor destroys asbestos. but it may alter the physical form of the mineral ?bers. L5 The 1talues stated in SI units are to be regarded as the standard. The values given in parentheses are for information only. If: This standard does not purport to address ail air the safety concerns. if any. associated with its use. it is die of the aser ad this standard to estaiafisit appra- priate safety and .fiE'El'fift practices and determine the appiica- edits of reetdatory iintitatians prior to use. 1. Referenced Documents 2.1 ASTM Standards? Speci?cation for Reagent Water [33195 Practice for Rotametet Calibration 'e for Determinatioi I. Precisi - of EMSL Analytical Inc. Copyright 2017 ASTM Micro Vac Method 2 EMSL Analytical Inc. (ERIE) Designation: 57'55 I12 {Fleapprotted "marrow Standard Test Method for Microvacuum Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Mass Surface Load ing1 This standard is issued under the fixed designation l} Ihe numher immediately following the designation indicates dte year of original adoption or. in me case of reyision- the year of last reyisic-n. A numher in paten IJ'Ieses indicates the year of last reapproyal- A superscript epsilon indicates an editorial change since Ihe last reyision or reapproyal. 1. Scope l.1 This test method covers a procedure to identify asbestos in dust and {it} provide an estimate of the surface loading of asbestos in the sampled dust. reported as either the mass of asbestos per unit area of sampled surface or as the mass of asbestos per mass of sampled dust. l.1.l If an estimate of asbestos structure counts is to be determined. the user is referred to Test Method [It l2 This test method describes the equipment and pro-ce? dures necessaty for sampling. by a itticroy'acuum technique. non?airbome dust for levels of asbestos. The non-airbonie sample is collected inside a standard ?lter membrane cassette from the sampling of a surface area for dust 1.yhich may contain asbestos. l.2.l This procedure uses a microvacuunting sampling tech? nique. The collection e?iciency of this technique is unknown. 1'r'ariabiliqgi' of collection ef?ciency for any particular substrate id across different types of strates is also known. The quantitation may not represent the physical form of the asbestos as sampled. More speci?cally. the procedure de? scribed neither creates not destroys asbestos. but it may alter the physical form of the mineral ?bers. 1.5 The values stated in SI units are to be regarded as the standard. 1.6 This standard does not purport to address of the safety coitceras- if arty. associated with its use- it is the responsibility of the user of this standard to estaiI-iisit appro? priate sepfety arid iteai'tii practices and deterrtriae tire appiica? iriit'ty of regttiatars' prior to use. 2. Referenced Hocuments ll ASTM Standards: 3 [It 193 Speci?cation for Reagent 1 i'lt'ater 3195 Practice for Rotaitteter Calibration [It Test Method for Microyacuum Sampling and [ndi? rect Analysis of Dust by Transmission Electron Micros? ASTM Micro Vac Sampling I I i 45 0mm ANGLE 1" T0 14/1/4" ouumn wemc Copy?ght2017 EMSL EMSL Analytical Inc. ASTM Micro Vac Sampling • Sample pump set to just 2 Lpm • Any area will suffice, 10cm x 10cm (100cm2) is standard • Templates are available but not necessary • Multiple passes first horizontal, then vertical then diagonal, hit the corners • Point cassette nozzle up before turning off pump • Cap both ends • Record Area Sampled! EMSL Analytical Inc. Copyright 2017 21 ASTM Micro Vac Sampling Whether collected by MicroVac or Wipe, the prep is essentially the same • The dust is sonicated off the collection filter • • • • • then brought up into solution with 50/50 alcohol-DI water All liquid passed through a 1mm screen pH adjusted to 3-4 with acetic acid An aliquot of this sample solution is filtered through a < 0.22 micron pore filter Then prepped for TEM TEM Analysis at 20,000X yields results in structures per square cm EMSL Analytical Inc. Copyright 2017 22 ASTM 6480 Wipe Sampling Designation: E430 05 "mam Standard Test Method for Wipe Sampling of Surfaces, Indirect Preparation, and Analysis for Asbestos Structure Number Surface Loading by Transmission Electron l'uilicroscopy1 This standard is issued under the fised designation l} Edi-it}: Ihe number immediately following the designation indicates d'Ie year of original adoption or. in Ihe case of resision- the year of last resision. A number in parenlheses indicates the year of last reappnnal- A superscript epsilon [at indicates an editorial change since me last resision or reapprosa]. Scope This test method covers a procedure to identify asbestos in samples wiped from surfaces and to preside an estimate of the concentration of asbestos reported as the number of asbestos structures per unit area of sampled surface. The procedure outlined in this test method employs an indirect sample preparation technique. It is intended to disperse aggre- gated asbestos into fundamental ?brils. ?ber bundles. clusters. or matrices. However. as with all indirect sample preparation techniques. the asbestos observed for quanti?cation may not represent the physical form of the asbestos as sampled. More speci?cally. the procedure described neither creates nor de- stroys asbestos. but it may alter the physical form of the mineral ?ber aggregates. LE This test method describes the equipment and proce- dures necessary for wipe sampling of surfaces for levels of asbestos structures. The sample is collected onto a particle-free wipe material [wipei from the surface of a sampling area that may contain asbestos. The collection ef?ciency of this wipe sampling tech? EMSL Analytical Inc. Copyright 2017 limit to the dimensions of asbestos ?bers. that can be detected. is yariable and dependent on individual microscopists. There- fore. a minimum length of ll? pm has been de?ned as the shortest ?ber to be incorporated in the reported results. 1.5 This test method does not pnrport to address ailr of the safety concerns- if any. associated with its are it is the responsibility of tire nser of this test method to estaidisit appropriate safety and neaitir practices and determine the of regaiatoty iitnitations prior to trse. 2. Rcfe ll ASTM Standards: 3 [Ii 1193 Speci?cation for Reagent 1 i'lt'ater [21' 1355 Terminology Relating to Sampling and Analysis of Atmospheres [ii .itii'll Guide for Determination of Precision and Bias of Methods of Committee D22 2.2 Gt?'??t?tittit't? Standard.? 40 CFR no. USEPA. Asbestos-Containing Materials in Schools: Final Rule and Notice. Appendix A to Sub-part I -I 23 ASTM 6480 Sampling • Clean Room Wiper wetted with 50/50 alcohol/water (no baby wipes please) • Any area will suffice, 10 x 10cm is standard • Templates are available but not necessary • Multiple passes, first horizontal, then vertical then hit the corners • Record Area Sampled! EMSL Analytical Inc. Copyright 2017 24 ASTM 6480 Sampling https://www.youtube.com/watch?v=Hd49JZWfcME EMSL Analytical Inc. Copyright 2017 25 ASTM 6480 Sampling In the Field Field Wipe Blank: a clean unused wipe from same supply. Processed in same way as sample but no area wiped. Remove from bulk pack, moisten, fold, place in container In the Lab Process Blank: unused wipe prepped for TEM Filtration Blank: 250 ml of lab water filtered Lot Blank (if applicable) to prove clean prior to use EMSL Analytical Inc. Copyright 2017 26 So I Got my Test Report Back@ 7 What do the Results Mean? What do the Results Mean? Wipes and MicroVacs are under-utilized due in part to the lack of a clear PASS/FAIL • They will find asbestos when air sampling (even aggressive) will not. • They can find asbestos from historic long term deposition or even the RATE of deposition in ongoing deposition • But what do I do with the results ? EMSL Analytical Inc. EMSL Analytical Cinnaminson, NJ Inc. 08077 Copyright 2017 Copyright 2014 28 28 Now What? • Don’t look for regulatory limits of asbestos in Dust • The Dust Methods are an Investigative tool • In the case of the TEM methods a very powerful investigative tool • The results represent a POTENTIAL for airborne exposure EMSL Analytical Inc. Copyright 2017 29 Qualitative Results Asbestos Detected: Now what? • We know there is a potential issue • We know the type of asbestos • We can look for more and find hot spots or hopefully even the source • We can initiate air sampling for assurance of occupants EMSL Analytical Inc. Copyright 2017 30 Quantitative Results We need to think about the results differently than with other matrices • % asbestos: 1% is not an appropriate action level. 1% is not related to risk anyway but asbestos “Releasability” is much different in dust • Fibers/structures/cm2 : Now we can start to compare sample to sample differences EMSL Analytical Inc. Copyright 2017 31 Quantitative Results ASTM 5755-09 • Target Analytical Sensitivity (AS) of approx. 1,000 asbestos s/cm2 • This AS can be achieved by increasing GO, Vol and/or SPL • Most labs only include 10 GO’s analyzed in the price, more GO’s can be analyzed, however $/GO will apply EMSL Analytical Inc. Copyright 2017 32 There are Some Guidelines • ASTM 5755 MicroVac • ASTM 6480 Wipe What do the numbers mean? • Asbestos present • Compare values to a “Control Area” • From Millette/Hayes “Settled Dust” 1,000 - 10,000 - 100,000 s/cm2 low - medium - high EMSL Analytical Inc. Copyright 2014 2017 33 More Guidelines Dust Sampling and Analysis Plan (SAP) for Libby, 8/2003 “If the average concentration of LA in indoor dust on a particular level (floor) of a particular residence or building is greater than 5,000 LA structures per cm2, EPA will perform active remediation of that contaminated dust.” USEPA QAPP for Lower Manhattan Indoor Dust Test and Clean Program, May 15, 2007 “EPA will clean up building units and common areas found to have contamination above specified benchmarks.” Benchmarks: Accessible areas 5,000 s/cm2 Infrequently accessible areas: 50,000 s/cm2 EMSL Analytical Inc. Copyright 2017 34 ASTM Settled Dust Guide EMSL Analytical Inc. Designation: F390 Ila- "marrow Standard Guide for Evaluating Asbestos in Dust on Surfaces by Comparison Between Two Environments? This standard is issued under the tised designation TtJu'ltt}: the number immediately follouing the designation indicates Ute year of original adoption or. in the case of revision. the year of last revision. A number in parentheses indicates the year of last reapproya]. A superscript epsilon [ei indicates an editorial change since the last revision or reapproval. 1. Scope l.1 There are multiple purposes for determining the loading of asbestos in dust on surfaces. Each particular purpose may require unique sampling strategies. analytical methods. and procedures for data interpretation. Procedures are provided to facilitate application of available methods for determining asbestos surface loadings andt'or asbestos loadings in surface dust for comparison between two environments. At present. this guide addresses one application of the ASTM surface dust methods. It is anticipated that additional areas will be added in the future. It is not intended that the discussion of one application should limit use of the methods in other areas. l2 This standard does not purport to address at" tire safety concerns. if any. associated with its use. it is die of the user of this standard to estaidisit appro- priate safety and iteaitit practices and determine tire appiica- isifitjv of regtdatmy' iitnitations prior to ttse. For speci?c wanting statements. see 5.1 l. Referenced Documents 1 With Speci?ed Precision. the Average for a Characteristic of a Lot or Process 45s Terminology Relating to Quality and Statistics 335th Practice for Comprehensive Building Asbestos Sur? veys 2.2 Diner Dacrnnent: Environmental Protection Agency~ US. il-iPA]- [Pink Briekt Asbestos in Buildings: Simpli?ed Sampling Scheme for Surfacing Materials. EPA ssootssrosoa. US. Environmental Protection Agency. Washington. DC. 3. 'I'erminulogy ll Definitions?Unless otherwise noted all statistical terms are as de?ned in Terminology E4551. activity" generated aerasai?a dispersion of particles in air that have become airborne due to physical disturbances such as human activity. sweeping. airflow. etc. background sainpies?samples taken from surfaces that are considered to have concentrations of asbestos in surfacedASTM Settled Dust Guide Designed specifically for the ASTM Methods (5755, 5756, 6480) Comparison to Background Samples Area with ACM disturbance compared to an area unaffected by the disturbance Comparison to Control Area One area may be taken as a “control” area. Results from all samples taken in other areas can be compared to this control value EMSL Analytical Inc. Copyright 2017 36 ASTM Settled Dust Guide Sealed Blank (1 per lot) Opened field blank (1 per 10 samples) If no asbestos found on samples don’t analyze 2 samples (or sets of samples) are considered different (asbestos loadings are different) if their 95% Confidence limits do not overlap If there is any question (close overlap) you can do a statistical z test as outlined in the standard (ASTM D7390) EMSL Analytical Inc. Copyright 2017 37 What About NYS 4 STATE OF NEW YORK DEPARTMENT OF HEALTH Wadsworth Center The Governor Nelson A. Rockefeller Empire State Plaza 90. Box 509 Albany. New York 12201 -0509 Nirav R. Shah. M.D., M.P.H. Sue Kelly Commissioner Executive Deputy Commissioner April 8. lell Ill revised on August 27. (FAQ I 2 revised on January 24. lel 3) tl'AQ #13 on December I7. 20?) FA 8: ASTM method [)5755 and D6480, which utilize microvacuum sampling and wipe sampling, respectively, are standard methods for the collection and analysis of surface dust/residue bulk samples. What are the accepted methods for collecting bulk samples of suspect materials (including bulk samples of surface dust/residue for bulk sample analyses by ELAP method or ASTJI method, to determine asbestos content EPA AHERA bulk sample collection methods shall be ttsed for collection of all bulk samples for asbestos surveys. For contamination assessments. if quantities of dust or residue are insufficient to utilize standard EPA AHERA bulk sample collection techniques. other accepted standard bulk sampling methods te.g.. ASTM D5755. ASTM D6480. etc.) may be utilized by the asbestos contractor inspection/survey firm completing the assessment. based upon their professional judgment. However. all bulk samples collected must be analyzed by ELAP approved methodology at an ELAP accredited laboratory. ASTM method [)5755 and [)6480 are not certified as approved methods of analysis. EMSL Analytical Inc. Copyright 2017 38 What About NYS ELAP? • NYS ELAP does not currently provide certification for ASTM 5755 and ASTM 6480 • When analyzing samples collected from NYS, the lab must remove their NYS ELAP Lab ID from final reports • NYS has asked that the following disclaimer be added to the reports: • “The requested analytical method is a parameter that NYS DOH currently does not offer certification under their ELAP program; therefore the data may not be used for regulatory compliance or legal purposes.” • We are hearing NYS may be adding these to tests as a certified parameter in the near future • Keep in mind US EPA Region 2 collected settled dust samples as part of WTC cleanup efforts EMSL Analytical Inc. Copyright 2014 2017 39 Crankshaw, O.S., Perkins, R.L., & Beard, M.E. (2000). An overview of settled dust analytical methods and their relative effectiveness. Advances in Environmental Measurement Methods for Asbestos, ASTM STP 1342. Papers Presented at a Symposium Held July 13 - 17, 1997 in Boulder, CO (pp. 350-365). Abstract Methods for sampling and analyzing asbestos in settled dust can be beneficial to document past (and potentially ongoing) episodes of asbestos contamination and to predict potential problems presented by asbestos-containing dust. Research Triangle Institute conducted an evaluation of several methods for dust collection and analysis, utilizing samples from industrial settings, samples from residential settings, and samples created in a laboratory dust-generation chamber. Sample collection techniques included microvacuuming, wipe sampling, tape sampling, and passive sampling. Analytical methods tested included fiber counting/sizing, fiber mass determination, qualitative analysis, and indirect and direct sample preparation procedures. The test results help illustrate the advantages and disadvantages of each technique. Each of the methods tested has specific attributes and limitations. Because of the inherent complexity of the methods and the typical variability found in real-world samples, numerous samples of each sample type are recommended, including side-by-side duplicates, representative sampling throughout the target area, and repeat sampling to determine temporal effects. EMSL Analytical Inc. Copyright 2017 40 RTI Study and Evaluation of Settled Dust Methods • RTI, under contract to EPA conducted a study to test the efficacy of the various settled dust sampling and analytical methods • Two study sites used: • Industrial Site; tire-brake repair shop, long time use of asbestos in brake linings, compressed air, no ACBM found in building, poor housekeeping • Residential sites; two homes chosen • Residence 1: built in 1927, basement contains ACM in boiler and pipe wrap, known source of asbestos fibers • Residence 2: built in 1970, no ACMs found in this residence EMSL Analytical Inc. Copyright 2017 41 RTI Study and Evaluation of Settled Dust Methods • Both the inside and outside TEM AHERA air samples had no asbestos fibers detected!!! • Wipe > Microvac; oil, mist, dust, etc. may bind asbestos fibers to surface EMSL Analytical Inc. Copyright 2017 42 RTI Study and Evaluation of Settled Dust Methods • R1, Basement; Side by side wipe and microvac samples showed wipe results on average 2.6 times more asbestos • R1, 2 TEM AHERAs in Basement; 0.077 s/cc & 0.098 s/cc • R2, no ACBM, asbestos still found; Background? • R2, Passive samples has levels 100 times below R1, indicating present accumulation rates low EMSL Analytical Inc. Copyright 2017 43 RTI Study and Evaluation of Settled Dust Methods Conclusions: • Each settled dust method has their inherent strengths and weaknesses • Settled dust is loose, microvac is more appropriate • Settled dust is bound to surface, wipe is more appropriate • Where dust is still accumulating, passive sampling should be used • Microvac more accurately reflect potential for asbestos fiber re-entrainment • Wipes more accurately reflect total accumulated asbestos fibers • Air sampling is a snapshot in time and may provide a false negative result EMSL Analytical Inc. Copyright 2017 44 Asbestos in Settled Dust  Similar Asbestos counts, however varying final concentrations  This is due to different dilutions used in sample preparation EMSL Analytical Inc. Copyright 2017 45 Asbestos in Settled Dust  High AS and final concentration  Very dirty sample, low dilutions used EMSL Analytical Inc. Copyright 2017 46 Asbestos in Settled Dust . EMSL C) I 04140437? EMSL Analytical, Inc. Fer CustomerlD: 200 Route-130 North, Cinnaminson, NJ 030?? CustomerPO' Phonei'Fax: (800) ZEDLEETE .i (855) "4 cinnasblab@EMSLcom I) Attn: Phone: I ery lg Received: 02.928104 9:40 AM Analysis Date: 3I12r'2014 Collected: a es OS CO . Project: Test Report: Asbestos Analysis of Wipe Samples Using Method ASTM 6480 AREA SAMPLED ASBESTOS Sensitivity CONCENTRATION SAMPLE io {cmzl TYPE STRUCTURES (Stricmai COMMENTS 01 100 None Detected ?2.99 486 *il450 Due to excessive particulate the 941404533901 analytical sensitivity of 260 as required by the method was not reached. 02 100 5 971 5830 Due to excessive particulate the 941404510902 analytical sensitivity of 260 as required by the method was not reached. 03 100 ?299 0?1 ?:2900 Due to excessive particulate the 9414045;7_0903 analytical sensitivity of 280 stricm2 as required by the method was not reached. 04 100 None Detected ?2.99 971 42900 Due to excessive particulate the 941404533904 analytical sensitivity of 260 as required by the method was not reached. f??M 05 100 122 12100 1480000 Due to excessive particulate the 941404510905 analytical sensitivity of 260 as required by the method was not reached. 06 100 08 486 4?600 Due to excessive particulate the o414a4armoos analytical sensitivity of 260 as required by the method was not reached. 0? None Detected ?:299 Blank EMSL Analytical Inc. Copyright 2017 Asbestos in Settled Dust  Multiple asbestos types detected EMSL Analytical Inc. Copyright 2017 48 Asbestos in Settled Dust  Multiple levels in one sample event EMSL Analytical Inc. Copyright 2017 49 Asbestos in Settled Dust  High AS and Final Concentration EMSL Analytical Inc. Copyright 2017 50 What Does TSCA Reform Mean to the Asbestos Abatement Industry? J. Brent Kynoch Managing Director, EIA TSCA Reform? What is this? • Frank R. Lautenberg Chemical Safety for the 21st Century Act • Signed into law by President Obama on June 22, 2016 • First revision to the TSCA law originally enacted in 1976 Major Provisions • Mandatory requirement for EPA to evaluate existing chemicals with clear and enforceable deadlines; • New risk-based safety standard; • Increased public transparency for chemical information; and • Consistent source of funding for EPA to carry out the responsibilities under the new law. Existing Chemicals (Asbestos is addressed here) • Prioritization – EPA must establish a risk-based process to determine which chemicals it will prioritize for assessment. – High – Chemical may present an unreasonable risk of injury or health or to the environment due to potential hazard and route of exposure, including to susceptible subpopulations – Low – Does not meet the standard for high priority. Risk Evaluations • High priority designation triggers a requirement and deadline for EPA to complete a risk evaluation on that chemical to determine its safety. • Low priority designation does not require further action, although the chemical can move to high-priority based on new information. Assessment Pipeline • First 180 days – EPA must have 10 ongoing risk evaluations. • Within 3.5 years – EPA must have 20 ongoing risk evaluations. • As EPA finishes evaluation of one chemical, they must “re-load” the pipeline. New Risk-Based Safety Standard • Chemicals are evaluated against a new riskbased safety standard - “unreasonable risk” – Risk evaluation excludes consideration of costs or non-risk factors – Must consider risks to susceptible and highly exposed populations “Unreasonable Risk” • EPA must take final risk management action within 2 years, or 4 years if extension needed • Costs and availability of alternatives considered when determining appropriate action to address risks • Action, including bans and phaseouts, must begin as quickly as possible but no later than 5 years after the final regulation PBT Chemicals Persistent, Bio-Accumulative and Toxic • New fast-track process to address certain PBT chemicals on the TSCA Workplan. – Risk evaluation not needed, only use and exposure to chemical needed. – Action to reduce exposure to extent practicable must be proposed no later than three years after the new law and finalized 18 months later. – Additional requirements for PBTs in the prioritization process for assessments. Source of Sustained Funding • Allows EPA to collect up to $25 million annually in user fees from chemical manufacturers and processors when they: – Submit test data for EPA review – Submit a premanufacture notice for a new chemicals or a notice of new use – Manufacture or process a chemical substance that is the subject of a risk evaluation; or – Request that EPA conduct a chemical risk evaluation • New fees will defray costs for new chemical reviews and a range of TSCA implementation activities for existing chemicals Review of 10 Chemicals within 180 days • EPA MUST begin review of 10 chemicals by 12/22/2016. • Chemicals selected from “workplan” list. • Asbestos is on the workplan list. • GREAT NEWS!!! Asbestos was selected in the “Top 10” chemicals for review by EPA. • Now the fun begins!! Differences in Old and New TSCA • Old – Risks must be weighed against its benefits and cost of restriction or ban. – EPA must choose “least burdensome means” of regulating to protect against risk. • New – Must review using a “health-based standard” and not the cost of restriction or ban. – EPA must protect “potentially exposed or susceptible populations.” Review of 1976 TSCA • Grandfathering. • 62,000 chemicals. • Since TSCA went into effect, 21,000 new chemicals have hit the market. • 82,000 chemicals • 5 chemicals of the original 62,000 have been evaluated and “controlled” by TSCA. (PCBs, chlorofluorocarbons, dioxin, asbestos, and hexavalent chromium) • 4 of the new chemicals have been controlled by TSCA. What does all of this mean for asbestos? • Review – From the moment TSCA went into effect in 1976, EPA was working to ban asbestos. – EPA issued final ban and phase out rule under the authority of Section 6 of TSCA in 1989. – In 1991, the rule was vacated, reversed and remanded by the Fifth Circuit Court of Appeals. Politics? Who was behind the appeal of the rule? • • • • • • Corrosion Proof Fittings v. EPA Federal Government of Canada Province of Quebec, Canada Cassiar Mineral Company Scrap Recycling Industries, Inc. Asbestos Institute Asbestos?? • Hasn’t it already been banned?? These are still allowed – – – – – – – – – – – – – – – – – Cement corrugated sheet Cement flat sheet Clothing Roofing felt Vinyl floor tile Cement shingle Millboard Cement pipe Automatic transmission components Clutch facings Friction materials Disk brake pads Drum brake linings Brake blocks Gaskets Non-roofing coatings Roof coatings After 1989, Asbestos became the poster child for TSCA reform • EPA was always hoping to ban asbestos under TSCA. • Ban failed. • Consequently, TSCA reform has been talked about since 1991. • Obviously the number of chemicals that have been restricted shows how ineffective TSCA actually was. What happens now? • Timing – Chemical (Asbestos) selected for review. – Risk Evaluation can take up to 3 years. – Create and enact restrictions can take up to 2 years, with an allowance for a 2 year extension. – Time before implementation – 5 years – Best case scenario – 2021 – Worst case scenario - 2028 Obama’s remarks “In fact, out of those original 62,000 chemicals, only five have been banned. Five. And only a tiny percentage have even been reviewed for health and safety. The system was so complex, it was so burdensome that our country hasn’t even been able to uphold a ban on asbestos -- a known carcinogen that kills as many as 10,000 Americans every year. I think a lot of Americans would be shocked by all that.” EPA names top 10 November 29, 2016 – – – – – – – – – – 1,4-Dioxane 1-Bromopropane Asbestos Carbon Tetrachloride Cyclic Aliphatic Bromide Cluster Methylene Chloride N-methylpyrrolidone Pigment Violet 29 Tetrachloroethylene, also known as perchloroethylene Trichloroethylene What happens now? • EPA held a TSCA review and scoping or “information gathering” session on February 14, 2017. • Oral presentation given by EIA and ADAO, among others. • Docket open for comments until March 15, 2017 reliminar document February 101? D'P?ce of Chemial Safety and US. EPA Preliminary Information on Manufacturing, Processing, Dishihutiun, Use, and Disposal: Asbestos 1332-11-4 Fdlru'y 2111? Sup-part damn-urn: flu-r Bucket Pig: 1&15 Chlor-Alkali Industry • Enemy in this process • Account for 90% of asbestos imports into US in 2015 • Use raw asbestos as part of the process to make chlorine gas. • 16 plants in the US using the asbestos diaphragm technology. What is likely to happen? • Self-funding mechanism • That should be good • Eliminate 2 regulations for every new regulation • This regulation is already in place - - we might be able to skip this one. • There seems to be no push-back about the dangers of asbestos • Any exposure is deemed dangerous. This should be good. What is likely to happen? • Possibly, asbestos will get lost in all of the discussion about the other chemicals. • New Administrator, Scott Pruitt, has bigger fist to fry - - Climate Change. Brent’s prediction • History is on our side - - other asbestos regulations during Republican administrations. • Asbestos ban will go through - - but it will not be easy • There will be a carve out for the Chlor-Alkali industry. Questions? • Robert J. DeMalo, M.Sc. Senior Vice President, Laboratory Services & Business Development • 307 West 38th Street, New York, NY 10018 • 800-220-3675 / rdemalo@emsl.com Thank You For Your Time & Thank You Metro NY AIHA!