Resolving the Vermiculite Asbestos Conflict

Transcription

1 Resolving the Vermiculite Asbestos Conflict A New Approach to Detection and Quantitation The Vermiculite Association: Annual Meeting Park City, Utah (September 11-13, 2014)

2 Don Ewert; Industrial Hygienist Occupational Health Services 35 Years as a Practicing Industrial Hygienist Education in Industrial Hygiene, Toxicology, Biochemistry, Business Administration Career Work in Chronic Toxins (High Energy Rad, Asbestos, CrVI, Parenteral Oncology, Nanomaterials Creation of the first EPA-NIST/NBS Certified Mobile Laboratory for On-Site OEHS Assessments Co-Author of Major OSHA and EPA Laws Involving Industrial Hygiene & Environmental Sampling 20 Years as an Expert Witness in the Field of Forensic Toxicology (Post-Injury Analysis) Research Scholar - Center for Environmental Toxicology & Technology at CO State University Past-Chair; AIHA Nanotechnology Working Group Full Member Society of Toxicology RJ Lee Group Resolving the Vermiculite Asbestos Conflict 2

3 Asbestos A Summary Refresher Asbestos Occurs naturally in rock and soil, including the regulated forms of chrysotile, amosite, crocidolite, tremolite, and anthophyllite asbestiform minerals. All asbestos minerals have demonstrated an ability to produce cancer in animals as well as humans. In fact, asbestos is one of only a few known carcinogens regulated by USOSHA. AIHA Webinar - Wednesday, May 7, 2014 By: Andrey Korchevskiy, Eric Rasmuson, and James Rasmuson. The Synergist Edition 2, 2014 Asbestos use in the United States is limited as a result of laws passed in the 70 s and 80 s while it remains actively produced and used in other portions of the world. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 3

4 Asbestos Two Distinct Mineral Groups Serpentine Fibers Represented by chrysotile Cleared quickly from the human lung Low in iron concentration Distinct morphology Airborne fibers are often agglomerated Amphibole Fibers Represented by amosite, crocidolite, tremolite, and anthophyllite Biopersistent exceptionally long half-life Moderately high iron concentration Straight fiber bundles capability of defoliation Airborne fibers don t agglomerate RJ Lee Group Resolving the Vermiculite Asbestos Conflict 4

5 Asbestos Still a Concern Asbestos in buildings remains an ongoing abatement expense Naturally occurring asbestos (NOA) is becoming a new concern Construction Mining Libby Amphiboles Asbestos is still actively being mined and used In the former Soviet countries, up of 90% of roof materials are ACM Improved analytical methods has led to updated epidemiological results Focus on low level exposure affects Impact of asbestos-like physiological behavior on emerging materials Zeolites Nanomaterials (CNT s) Man-made fibers (macroscale ceramic, polymeric, etc) RJ Lee Group Resolving the Vermiculite Asbestos Conflict 5

6 Cancer Experience by Mineral Group RJ Lee Group Resolving the Vermiculite Asbestos Conflict 6

7 Risk Assessment Models Development History RJ Lee Group Resolving the Vermiculite Asbestos Conflict 7

8 Risk Assessment Models Low Dose Case Studies RJ Lee Group Resolving the Vermiculite Asbestos Conflict 8

9 Asbestos Risk - Model Uncertainties RJ Lee Group Resolving the Vermiculite Asbestos Conflict 9

10 Model Comparison Excess Cancer Cases/Million (0.1 f/cc, 45 years starting at 18) RJ Lee Group Resolving the Vermiculite Asbestos Conflict 10

11 International View on Asbestos Regulation European Union standard = 0.1 f/cc Health Council of the Netherlands proposals for asbestos: Amphiboles = f/cc Mixed Species = f/cc Chrysotile = f/cc Germany; instead of occupational exposure limits for asbestos, requirements exist for protective measures depending upon airborne fiber concentration (e.g. PPE can be waived if concentration < f/cc) Russia has extremely cumbersome regulation Occupational exposure regulated as a dust in mg/m 3 based on an assumed fiber content. Different standards for chrysotile and amphiboles (200 fold) Ambient standard of 0.06 f/cc by PCM, 0.08 mg/m 3 total dust having an asbestos content of >20%. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 11

12 Chronology of Rainy Creek and Libby Vermiculite Operators mined most of the vermiculite ore through large open cuts; several adits, one 750 feet long, also provided access to the ore. Initial processing took place at a concentrator near the mine. Trucks then hauled the concentrate to the Libby plant Edward The for heating N. Alley Rainy Creek and expansion discovered sub-district into the encompasses the vermiculite final product. deposits a small Some during area northeast of World concentrates War I when of Libby in were he the was Rainy shipped prospecting Creek to plants for drainage. vanadium. Great Prospectors Falls, He other experimented located states, isolated Canada, with copper and samples, other built deposits foreign a small there countries kiln to in the late for process 1890s final processing the ore, and early there. and promoted 1900s. About John L. 1940, the material Neihart, Universal under of the Zonolite the mining town mined trade name of 500 Neihart, tons of Zonolite. of caused ore each This led considerable day, Large to reducing a deposits demonstration excitement of to vermiculite 200 tons plant when of in and concentrates. 1924, he examined small followed metallic Twenty-four two these deposits years deposits years later in and the by later, Rainy a larger predicted the Creek company facility that subdistrict make out are of processing 2400 found the Rainy tons a of 100 stock Creek ore tons of each district alkaline of day, ore each they capable would turned "another reducing rocks day. that Butte this Alley intrudes amount sold his the production into interests 500 the Proterozoic tons in 1934, of of copper" rocks leaving (Renk concentrates. of the 1994). Belt two series. different Copper There Two-thirds are companies mining no figures never of the working developed for stock total the is production coarse-grained deposits on Rainy much beyond since pyroxenite, Creek. They the this stage information of from merged wishful which was in thinking, restricted vermiculite 1939 to form but after is the derived, 1930 Universal Rainy (Perry and Zonolite Creek one-third 1948; Insulation district Johns became is coarse-grained 1970; Co., altering well-known WPA 1941). syenite. the name for a very Hydrothermal to Zonolite unassuming Co. mineral alteration in called has The vermiculite. caused business major came Mica changes under particles in the the control heated stock, of expands producing W. R. Grace up white and to 15 times mica, Co. in their aegirite 1963 and original and continued aegirite-diopside, operations size. The end product vermiculite, until 1991 is vermiculite, and (Renk fibrous 1994). which amphiboles is used primarily (Pardee and in fireproofing Larsen and 1929). insulation from heat, cold, and sound (Renk 1994; Perry 1948). Discovery of Copper Vermiculite Discovered Zonolite is Created Year Legacy RJ Lee Group Resolving the Vermiculite Asbestos Conflict 14

13 Chronology of NY DOH Guidance on Vermiculite New York DOH introduces publicly available Item 198.8, a modified Chatfield Method for the analysis of asbestos in Spray-On Fireproofing containing Vermiculite (SOF- V) by Polarized-Light Microscopy (PLM). New New York York State State DOH DOH guidance notifies RJ FAQ Lee #10 Group states that that validation wherever for SOF-V LAB is calculated has met to the be >10% conditions vermiculite set forth containing, in 10NYCRR Item and may is be fully used certified New York State DOH announces the imminent availability to evaluate for SOF-V of two new the NYS asbestos testing. DOH content of ELAP-approved the material; methods provided, for however, the detection that any and test quantitation results using of this asbestos method content must in be reported spray-on fireproofing with the following that contains conspicuous vermiculite disclaimer: (SOF-V). This New York method State does DOH not interpretation remove vermiculite of vermiculite-related and may underestimate guidance does the level not of prohibit asbestos the use or present application in a sample of vermiculite containing materials, greater but than instead 10% vermiculite. applies during renovation and/or demolishing of structures when the origin of the vermiculite material is New unknown. York State DOH guidance FAQ #10 recommends that with no approved analytical methodology New York State to DOH reliably guidance confirm FAQ vermiculite #10 states as that non-asbestos wherever SOF-V containing, is calculated it is always to be New best >10% to York vermiculite assume State law that containing, modified vermiculite to the designate is material contaminated vermiculite must be with reported asbestos insulation and ACM. as proceed Suspect Miscellaneous accordingly. ACM that must be treated as ACM unless proven otherwise by approved laboratory testing. 3/21/07 4/8/11 6/22/12 8/27/12 7/9/13 7/22/14 7/24/14 8/20/14 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 15

14 Vermiculite Study - Definitions Regulated Asbestos - The EPA definition of 'asbestos' includes six asbestos minerals: chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, 29 CFR (b), definitions. The state of New York regulates asbestos by the same standard. According to the US EPA, materials containing greater than 1 percent (>1%) asbestos are regulated as asbestos containing materials (ACM). RJ Lee Group Resolving the Vermiculite Asbestos Conflict 16

15 Vermiculite Study - Definitions Non-Regulated Amphibole Asbestos (e.g., winchite/ richterite) - Reported when the morphological characteristics of the amphibole are consistent with asbestos. However, it is not used in determining whether a material is ACM. While winchite and richterite amphiboles are nonregulated forms of asbestos, they exhibit some of the same characteristics as regulated asbestos. As a result, they are often misreported as asbestos because of the fact that their characteristics are consistent with asbestiform minerals. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 17

16 Vermiculite Study - Definitions Spray-On Fireproofing containing Vermiculite (SOF-V) - SOF-V is defined as a material containing vermiculite, intended to act as a fire-retardant coating when applied to building structures via spraying equipment as opposed to a manually applied (trowel) material. SOF-V can be in the form of Thermal Systems Insulation (TSI), surfacing material, or other presumed ACM (PACM). No matter the form, it is a miscellaneous suspect ACM as specified in 12 NYCRR Part 56 which include, but are not limited to, existing or new surfacing material, plaster, pipe lagging, and spray-on fireproofing. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 18

17 Testing Requirements for Sprayed-on Fireproofing Containing Vermiculite (SOF-V) This communication is in follow up to the July 9, 2013 interim guidance letter regarding testing alternatives for materials containing vermiculite, issued by the New York State Department of Health (NYS DOH), in collaboration with the New York State Department of Labor (NYS DOL). The enclosed communication announces the imminent availability of two new NYS DOH ELAP-approved methods for the detection and quantitation of asbestos content in spray-on fireproofing that contains vermiculite (SOF-V). The testing strategies for SOF-V outlined in the July 9, 2013 interim guidance letter may be used until October 31, After October 31, 2014, one of the new methods must be used to test SOF-V, regardless of the percent of vermiculite. Since the new methods will be capable of removing vermiculite content, they are the only results for SOF-V that may generate a Non-ACM result without the need for the disclaimer required in the July 9, 2013 interim guidance letter. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 19

18 The following is a brief description of how and when these new methods must be utilized for analytical testing; please also refer to the enclosed Decision Tree for more guidance. In the field, when an inspector, using his/her professional judgment, determines that a sprayed-on fireproofing (SOF) may contain vermiculite, the material may be presumed ACM according to 12 NYCRR Part 56 (NYS Industrial Code Rule 56), or they must forward that material to a NYS DOH ELAP certified laboratory for analysis. Since all NYS approved PLM methods begin with a stereoscopic examination of the material, this stereoscopic examination can confirm the presence or absence of vermiculite. If vermiculite is present (regardless of the amount), one of the two new approved methods must be used for the detection and quantitation of asbestos content. If vermiculite is not present, then Items or must be used, as appropriate, and based upon the presence of organically-bound or microscopically interfering materials. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 20

19 The following is a brief description of how and when these new methods must be utilized for analytical testing; please also refer to the enclosed Decision Tree for more guidance. In the field, when an inspector, using his/her professional judgment, can not make the determination if the (SOF) contains vermiculite, the material may be presumed ACM or sent to a laboratory certified for Items 198.1, 198.6, or one of the two new approved methods. If vermiculite is determined to be present at any concentration during the stereoscopic examination required in all NYS PLM approved methods, then the material must be further analyzed by one of the two new approved methods. If vermiculite is not present, then Items or must be used, as appropriate, and based upon the presence of organicallybound or microscopically interfering materials. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 21

20 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 22

21 Industry Implications: The approval of these new methods for the identification and quantitation of asbestos in SOF-V will have the following implications during the demolition, renovation, remodeling and/or repair of buildings that fall under the authority of NYS Industrial Code Rule 56. For future projects that have no associated survey MUST use one of the new methods and current NYS guidance. For projects that have an existing survey, but no project plan MUST resample and resurvey and use one of the new methods and current NYS guidance prior to starting any new project. For projects with an existing survey, and project yet to be done (Phase 1A) MUST resample and resurvey and use one of the new methods and current NYS guidance. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 23

22 Industry Implications: The approval of these new methods for the identification and quantitation of asbestos in SOF-V will have the following implications during the demolition, renovation, remodeling and/or repair of buildings that fall under the authority of NYS Industrial Code Rule 56. For projects in progress using an old survey, and work actively underway (Phase 2A-2D) re-sampling and use one of the new methods is RECOMMENDED, but NOT REQUIRED UNLESS there is a change to the project design requiring a change order. If a change order is required, then re-sampling and analysis by one of the new methods and current NYS guidance is REQUIRED on the new area. For completed projects that were conducted under an old survey there is no requirement to go back and re-sample. However, if there is a need to disturb a material in the future - MUST use one of the new methods and current NYS guidance. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 24

23 An Analytical Solution is Developed RJ Lee Group Resolving the Vermiculite Asbestos Conflict 26

24 COMPREHENSIVE TEST APPROVAL POLICY AND SUBMISSION GUIDELINES Subsection (g) of Part 58 of Title 10 (Health) of the Official Compilation of Codes, Rules and Regulations of the State of New York states that all technical procedures employed in a laboratory shall be of proven reliability and generally accepted by leading authorities in the specialties of laboratory medicine and/or approved by the Department. A laboratory can perform only those assays for which the performance characteristics have been established and validated, or if already established (typically by a manufacturer) verified at the site where the assay will be performed. The laboratory must also hold the appropriate permit category for the test and must meet all other requirements related to on-site survey, personnel and proficiency testing. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 27

25 RJ Lee Group Instrumentation Cutting Edge Technology RJLG utilizes innovative technology for unprecedented materials characterization abilities. Hitachi HD-2300 STEM Hitachi S-5500 SEM/STEM 1 st Mira delivered to EPA RJ Lee Group Resolving the Vermiculite Asbestos Conflict 28

26 RJ Lee Group Instrumentation Microscopy Optical Microscopes Scanning electron microscopes Transmission electron microscopes High resolution electron microscopes Computer-controlled microscopy Surface Analysis: ESCA/XPS X-ray Diffraction X-ray Fluorescence Fourier Transform Infrared Spectroscopy Raman Imaging & Spectroscopy Analytical Chemistry ICP-ES and ICP-MS AA and IC GC-MS, GC-FID, GC-ECD DSC / TGA Counts / s 7.00E E E E E E E E+00 Thermo K-Alpha XPS Mg1s Na1s Zn2p Fe2p O1s N1s Ca2p K2p C1s Cl2p B1s Si2p Al2p Binding Energy (ev) 0 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 29

27 Vermiculite Method Introduction RJ Lee Group Response (18 Month Process) Develop a Method Paid in part by New York Major Property Manager Seek NY DOH Approval Provided Proof of Concept Study Drafted Method for Single Laboratory Approval Submitted Method and Met with DOH Repeatedly NY DOH Review Requested a complete method validation study RJ Lee Group Resolving the Vermiculite Asbestos Conflict 30

28 Vermiculite Study Design Challenges Current methods may underreport asbestos content & generally don t report or speciate naturally occurring asbestos Other methods, incorporating processes for physical separation of materials are subject to significant inter-laboratory variability Methods were designed for bulk vermiculite with minimal binding materials. Use of PLM & TEM is known to be highly variable at low concentrations. Much and most often amphibole materials are tied up within sheets of the vermiculite matrix. Most laboratories have limited mineralogical expertise in differentiating between asbestos and non-asbestos amphiboles RJ Lee Group Resolving the Vermiculite Asbestos Conflict 31

29 Vermiculite Study Design Solution Take advantage of common materials used in vermiculite fireproofing vermiculite, cellulose, carbonates, gypsum, cement, and fiberglass Selectively eliminate these materials to reveal materials of concern RJLG Method Sample Prep Features Benefits to Material Screening Level 1 (PLM) Level 2 (PLM & SEM) Removes gypsum, carbonates, and cellulose to making vermiculite content quantifiable. Removes vermiculite, fiberglass, and other soluble material in order to clearly quantify asbestos. Removes speculation about vermiculite content of the material (> or <10%). Avoid unnecessary abatement. Fast and unambiguous results to determine asbestos content (> or <1%). Creates a digital record of SEM results for later reference. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 32

30 Vermiculite Study Design Solution Steps and Actions in RJLG Vermiculite-Containing Fireproofing Analysis RJLG Analysis Levels Steps and Actions in SOF-V Analysis Regulated Asbestos* Outcome/Action >2.0% Chrysotile ACM RJLG Level I: Water/acid wash to remove gypsum and carbonates, then ash to remove cellulose 0.5% and 2.0% Chrysotile Repeat Level I analysis at least two more times (n 3) If arithmetic mean result is >1%, report as ACM If arithmetic mean of repeated results is 1%, proceed to RJLG Level II RJLG Level II: Ash, then aggressive acid base digestion to dissolve vermiculite and other soluble materials Regulated Amphibole Asbestos >1%, Regulated Amphibole Asbestos 1% ACM Report regulated amphibole asbestos Reporting Sum of Level I and Level II regulated Asbestos >1% ACM *Reported analysis results include quantitation of non-regulated asbestos species. These amphiboles are not considered in determining final outcomes. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 33

31 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 34

32 Method Description - LAB RJ Lee Group Method LAB is a two tier analytical process wherein Level I is restricted to the detection and quantitation of chrysotile. During Level I preparation, the raw material is ashed and washed using water and hydrochloric acid (HCl) to remove residual moisture along with any acid soluble materials including cellulose that may interfere with analysis. Thereafter, the improved visibility allows PLM analysis to be used for accurately identifying and quantifying the chrysotile concentration that exists. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 36

33 Method Description - LAB Level II analysis is used to accurately detect and quantify the amount of amphibole asbestos. The process involves ashing to remove carbonate, gypsum, cellulose, and fiberglass followed by digestion with concentrated acid/base solutions to dissolve the vermiculite. Once the interfering materials are abated, Level II employs a combination of PLM and SEM to detect, speciate, and quantify the amphibole asbestos content that exists. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 37

34 VC-SOF Sample LAB Process Level I Treatment Chrysotile Analysis (400 Point Count) Level II Treatment Amphibole Analysis (PLM / SEM) If >2.0% Chrysotile Report As ACM If 0.5% - 2.0% Chrysotile If <0.5% Chrysotile Proceed to Level II If <1.0% Regulated Amphibole If >1.0% Regulated Amphibole Triplicate Analysis With Averaging of Results Sum the Results of Level I and Level II (Regulated Asbestos) If X >1.0% If X 1.0% If X 1.0% If X >1.0% Report As ACM Proceed to Level II Report As Non-ACM Report As ACM X = arithmetic mean Reporting Differentiates Regulated and Non-Regulated Amphibole Content RJ Lee Group Resolving the Vermiculite Asbestos Conflict 38

35 Samples Before and After Matrix Reduction RJLG Level II (Left) Light microscopy image of bulk vermiculite material and (right) scanning electron microscopy (SEM) image of Level II matrix reduction to remove vermiculite and other interfering materials leaving behind any amphiboles (circled). RJ Lee Group Resolving the Vermiculite Asbestos Conflict 39

36 Vermiculite Study Design Validation Over 1000 tests performed Spiked, 5.0-gram samples of vermiculite fireproofing 5, 2, 0.5, 0.1, and 0.02 percent of each regulated amphibole type and chrysotile. Direct comparison of NY DOH and methods with RJLG Level 1 and 2 analysis RJ Lee Group Resolving the Vermiculite Asbestos Conflict 40

37 Vermiculite Analysis - Reporting RJ Lee Group Resolving the Vermiculite Asbestos Conflict 41

38 Vermiculite Analysis - Reporting RJ Lee Group Resolving the Vermiculite Asbestos Conflict 42

39 Chrysotile Samples vs RJ Lee Group Resolving the Vermiculite Asbestos Conflict 43

40 Amphibole Samples vs. RJLG Level 2 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 44

41 Precision and Accuracy of RJLG Level 2 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 45

42 LAB Performance Summary Overall, the effectiveness of the Level I procedure in detecting Chrysotile as a means of defining whether a sample should be treated as asbestos containing material (ACM), i.e. whether chrysotile is present at a concentration >1%, is 69%, compared with a 57% detection rate using the NYS DOH method. The Level II amphibole procedure has been shown to be more than 90% accurate in determining whether SOF-V is ACM, compared with a 59% effectiveness rate using NYS DOH method Furthermore, Level II was found to be 100% reliable in identifying non-regulated amphibole asbestos whereas, NYS DOH only showed a 5% effectiveness rate in detecting non-regulated amphibole species. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 46

43 From: Stephanie E Ostrowski [mailto:stephanie.ostrowski@health.ny.gov] On Behalf Of ELAP BML Sent: Wednesday, August 20, :43 AM Cc: ELAP BML Subject: Update!! - NYS DOH Asbestos Methods revised & DOH Method for SOF containing Vermiculite NOTE: These are several changes to all of the DOH- approved asbestos methods in the Solid and Hazardous Waste category. Please read the following carefully. ELAP is announcing the availability of Item of Manual (ELAP code 4601) entitled: Polarized-Light Microscopy Method for Identifying + and Quantitating Asbestos in Sprayed-On Fireproofing Containing Vermiculite Bulk Samples Please also refer to the Department of Health's recent guidance entitled Testing Requirements for Sprayed-on Fireproofing Containing Vermiculite (SOF-V) dated July 22, pdf RJ Lee Group Resolving the Vermiculite Asbestos Conflict 47

44 Method Description - NY DOH Item incorporates a two-step approach for the identification and quantitation of chrysotile and amphibole asbestos, including Libby amphiboles, in SOF-V. The first step utilizes gravimetric reduction including ashing to remove the organic materials and dilute acid treatment to remove gypsum and cement from SOF-V. The residue is then examined by PLM for the presence of chrysotile, which is quantitated by point counting. If the concentration of chrysotile is found to exceed 1%, the material is considered asbestos containing material (ACM) and the analysis is terminated. If chrysotile is either not detected, or is found at a concentration less than 1%, then the analysis is continued to determine the concentration of amphibole asbestos. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 48

45 Method Description - NY DOH Heavy liquid centrifugation is used to separate particles with densities exceeding 2.75 g/cc from the majority of the less dense matrix components. This results in a centrifugate that contains any amphibole that was present in the original sample. The concentration of the remaining amphibole is determined by PLM and point counting. The total asbestos content is obtained by adding the concentration of asbestos quantitated in step one (chrysotile) with the asbestos quantitated in step two (amphibole). If the final concentration is determined to be greater than 1%, the material is designated as ACM. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 49

46 VC-SOF Sample Ash for 10 hours 1 st Centrifugation Remove Vermiculite Process Acid Treatment Disperse Centrifugate Filter Suspension 2 nd Centrifugation Chrysotile Analysis Aspirate Centrifugate If >1.0% Chrysotile Report As ACM If <0.5% Chrysotile Proceed to Centrifugation Amphibole Analysis (PLM Only) If <1.0% Amphibole Sum the Results Total Asbestos If >1.0% Amphibole If X >1.0% Report As ACM If X 1.0% Report As Non-ACM RJ Lee Group Resolving the Vermiculite Asbestos Conflict 50

47 Method Comparison Detail LAB Vermiculite-Amphibole Separation Method Chemical Physical Microscopy Method SEM / PLM PLM Only Differentiation of Naturally Occurring Amphiboles Yes Analysis Pricing 18 Hour Process - $ Hour Process - $? Number of Contact and Transfer Processes Round Robin (Zonolite vs Spiked Samples) No <5 >10 TBD TBD RJ Lee Group Resolving the Vermiculite Asbestos Conflict 51

48 Conclusions The RJLG method: Provides sound data based on chemical separation and SEM analysis of the material (results are definitive). Reliably determines whether a product is ACM at the 1.0% level (NY DOH Limit) Accurately quantifies all amphibole types down to 0.01 percent. RJ Lee Group Resolving the Vermiculite Asbestos Conflict 52

49 RJ Lee Group Resolving the Vermiculite Asbestos Conflict 53

50 We thank the professionals and staff of RJ Lee Group who contributed to the success of this endeavor. RJLG also wants to recognize the dedicated efforts of the New York Department of Health during development and approval of method LAB Contact Information Donald Ewert, IH RJ Lee Group An Industrial Forensic Approach 54