Asbestos in Settled Dust The Forgotten Matrix Bio-Accumulative and Toxic • New fast-track process...

Asbestos in Settled Dust The Forgotten Matrix

EMSL Analytical Inc. 307 W. 38th Street, NY, NY

Copyright EMSL 2017 1

EMSL Analytical, Inc.

Robert J. DeMalo, M.Sc.

Sr. VP, Lab. Svcs. & Bus. Dev.

Email: [email protected]

American Industrial Hygiene Association – Metro NY

New York Blood Center, NY, NY Wednesday, April 5, 2017

EMSL Analytical Inc. Copyright 2017 2

Dust is Different


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


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

1 10 Occupational Safety and Health Administration Field Operations Manual. “Instruction CPL 2-2.0A, March 1984,

Chapter VII: Sampling for Surface Contamination. 1.h.


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: PLM +/or TEM • Tape lift: PLM +/or SEM • Microvac: TEM • Wipe: TEM


Scenario 2: Passive Dust fall

Settled Dust sampling can show us evidence of asbestos that is currently accumulating (i.e. VAI) Structures or fibers per gram per area and per time period Sampling times anywhere from 1 week to over a year

Indiamart.com

Settling Tins

PetriSlides


Scenario 3:Hidden Reservoirs Settled Dust Sampling can show us a reservoir of asbestos that has accumulated over years


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


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)


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


Scenario 2: Dust fall


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.

Scenario 3: Hidden Reservoirs

EMSL Analytical Inc. Copyright 2017 13 13

Air Samples are

snapshots in time

A microvac or wipe

of settled dust can

find a reservoir of

asbestos

accumulated over

long periods.



Sampling Locations




• 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


Too Small for Light Microscopy


Carpet Sonication

Known areas are sonicated to remove particulate. Then the rinsate is filtered. Results in fibers or structures/cm2


ASTM Micro Vac Method


ASTM Micro Vac Method 2


ASTM Micro Vac Sampling


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!


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

ASTM Micro Vac Sampling


ASTM 6480 Wipe Sampling


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!


ASTM 6480 Sampling https://www.youtube.com/watch?v=Hd49JZWfcME

https://www.youtube.com/watch?v=Hd49JZWfcME


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


So I Got my Test Report Back

What do the Results Mean?

EMSL Analytical Inc. Copyright 2014 28 EMSL Analytical Inc. Cinnaminson, NJ 08077 Copyright 2017 28

• 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 ?

What do the Results Mean?


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


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


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


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


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


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


ASTM Settled Dust Guide


ASTM 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


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)


What About NYS ELAP?



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


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.


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



• 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



• 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



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


Asbestos in Settled Dust Similar Asbestos counts, however varying final concentrations This is due to different dilutions used in sample preparation


Asbestos in Settled Dust

High AS and final concentration

Very dirty sample, low dilutions used



Very high asbestos conc.



Multiple asbestos types detected


Asbestos in Settled Dust Multiple levels in one sample event



High AS and Final Concentration

What Does TSCA Reform Mean to the Asbestos Abatement Industry?

J. Brent Kynoch

Managing Director, EIA

• 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

TSCA Reform? What is this?

• 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.

Major Provisions

• 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.

Existing Chemicals (Asbestos is addressed here)

• 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.

Risk Evaluations

• 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.

Assessment Pipeline

• Chemicals are evaluated against a new risk-based safety standard - “unreasonable risk”

– Risk evaluation excludes consideration of costs or non-risk factors

– Must consider risks to susceptible and highly exposed populations

New Risk-Based Safety Standard

• 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

“Unreasonable Risk”

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.

PBT Chemicals

• 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

Source of Sustained Funding

• 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!!

Review of 10 Chemicals within 180 days

• 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.”

Differences in Old and New 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.

Review of 1976 TSCA

• 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.

What does all of this mean for asbestos?

• Corrosion Proof Fittings v. EPA

• Federal Government of Canada

• Province of Quebec, Canada

• Cassiar Mineral Company

• Scrap Recycling Industries, Inc.

• Asbestos Institute

Politics? Who was behind the appeal of the rule?

• 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

Asbestos??

• 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.

After 1989, Asbestos became the poster child for TSCA reform

• 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

What happens now?

“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.”

Obama’s remarks

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

EPA names top 10

• 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

What happens now?

EPA’s preliminary document

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.

• 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.

What is likely to happen?

• 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.

Brent’s prediction

Questions? • Robert J. DeMalo, M.Sc.

Senior Vice President, Laboratory Services & Business Development

• 307 West 38th Street, New York, NY 10018 • 800-220-3675 / [email protected]

Thank You For Your Time & Thank You Metro NY AIHA!

mailto:[email protected]

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Asbestos in Settled Dust The Forgotten Matrix Bio-Accumulative and Toxic • New fast-track process...

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