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In correspondence with EMSL, NYELAP has clarified their guidance on vermiculite and has confirmed that Non-friable Organically Bound (NOB) samples are not exempted from this policy (see scenario 3 below). EMSL will continue to stay on top of this issue and provide further guidance as more information becomes available. In a document dated August 27, 2012 the New York State Department of Health issued a clarification on how it expects vermiculite to be treated with regards to asbestos content.
The document can be found here.Vermiculite was mined and milled for many purposes including use as insulation (Vermiculite Attic Insulation (VAI), Block Fill, etc.), and also as a component in the manufacture of various building materials (thermal insulation systems, surfacing, pipe lagging, spray on, etc.). Unfortunately, some of the vermiculite used for these purposes was contaminated with asbestos.
It is New York State’s position that there is currently no analytical method that can reliably confirm the absence of asbestos in vermiculite. And when encountered in its loose form, this material must be assumed to be contaminated with asbestos and designated Asbestos Containing Material (ACM). Recognizing that when vermiculite is used as a component in building materials it may comprise just a small percentage, NY has separated vermiculite samples into two main categories with different procedures spelled out for each.
-Loose Vermiculite - Vermiculite Attic Insulation (VAI), Block Fill and all other loose vermiculite materials. -Vermiculite-Containing Materials – Building materials that contain vermiculite as a component. Scenario 1Loose vermiculite samples are to be considered asbestos containing materials (ACM). No analysis is necessary for this determination. All the same precautions applied to other ACMs should be used.
Scenario 2Vermiculite-containing building material samples are analyzed first for vermiculite (not asbestos) content via NY stratified point count (method 198.1). If the vermiculite content of the sample is greater than 10%, the material should be considered ACM. If the vermiculite content of a building material is less than 10%, analysis may then be conducted by the New York State PLM Method (198.
1) as usual to determine the asbestos content. Scenario 3Non-friable Organically Bound (NOB) Vermiculite Containing Building Material Samples are not exempt from this new guidance. Samples containing more than 10% vermiculite should be considered ACM. If the vermiculite content of a building material is less than 10%, then analysis for asbestos content may be conducted. EMSL Procedures to Comply with New York State Guidance Scenario 1Samples of loose vermiculite samples such as VAI or block fill should be assumed to be an asbestos containing material (ACM).
If they are submitted to the lab as billable samples they will be listed on the final report and reported as "Loose Vermiculite - ACM by NYS Guidance." Scenario 2Samples that contain vermiculite as a component will be analyzed for vermiculite percentage by point counting (when possible) viaNew York method 198.1. -If the vermiculite concentration is determined to be 10% or greater the material should be assumed to be an asbestos containing material (ACM).
The sample will be reported as "Vermiculite ≥10% of total material - ACM by NYS Guidance" -If the vermiculite concentration is determined to be less than 10%, analysis for asbestos content will proceed via NYS ELAP 198.1 as usual. Scenario 3Non-friable Organically Bound (NOB) Vermiculite Containing Building Material Samples are not exempt from this new guidance. -After gravimetric reduction the ashed residue will be analyzed for vermiculite content by point count (when possible) and this percentage will be used to calculate the vermiculite percentage in the original sample.
If the vermiculite percentage is calculated to be 10% or more the material is considered ACM. The sample will be reported as "Vermiculite ≥0% of total material - ACM by NYS Guidance" -If the vermiculite percentage is calculated to be less than 10%, then analysis for asbestos content will continue as normal via ELAP 198.6 Note: The requirement for a point count to determine vermiculite content necessitates that NOBs go to PLM (198.
6) prior to TEM analysis (198.4)
Title: Asbestos Testing Charlotte Nc