Updated NYS Guidance as of July 2013. Vermiculite Interim Guidance 7.9.13
Here is an article I wrote that appears in the October edition of the AGC’s Cornerstone
Vermiculite-A Brief Discussion
Vermiculite is a naturally-occurring mineral composed of shiny flakes, resembling mica. When heated to a high temperature, flakes of vermiculite expand as much as 8-30 times their original size. The expanded vermiculite is a light-weight, fire-resistant, and odorless material and has been used in numerous products.(1) Expanded vermiculite is used in construction and consumer materials (e.g., loose-fill insulation, acoustic finishes, spray-on insulation, and concrete mixes for swimming pools), agricultural and horticultural products (e.g., potting mixes and soil conditioners) and in industrial products (e.g., brake shoes and pads, drilling muds, furnaces, and insulation blocks). Expanded vermiculite granules are shaped like small accordions, and vary in color from silver/gold to gray/brown.(2) The vermiculite industry maintains several web sites , some of which are listed in the citations at the end of this article.
Of greatest concern is the vermiculite that was mined in Libby, MT as it is known to be contaminated with asbestos; asbestiform (asbestos-like) amphibole minerals, including the regulated forms tremolite and actinolite and forms that are not currently regulated, including winchite, richterite, and ferro-edenite(3), also referred to as “Libby Amphiboles”. Research has linked all of these forms to asbestos-related diseases. (3) The mine in Libby operated from approximately 1919 through 1990 and produced up to 80% of the world supply (4) and 70% of all vermiculite sold in the US in that period (5). Published studies (6) and EPA research have shown that unmanaged disturbances of vermiculite as found in homes (and other situations) can release a significant amount of asbestos.
The community of Libby, MT has suffered an unbelievable environmental and human toll. It is a current EPA Superfund site and in 2009 the EPA issued a first ever Public Health Emergency under CERCLA for the Libby site. In addition to the site of the mine, there are 28 sites throughout the US where vermiculite was transported for processing. The vast majority of the vermiculite was transported by rail in open cars. In 2005, the State of Montana published a report “Mesothelioma in Montana” (7). Within that report (page 5) was a map plotting the cases of mesothelioma. Although the report stopped short of claiming a causal relationship, it is interesting to note that most cases of mesothelioma occurred in people living in close proximity to the rail lines.
Many studies show that people who worked in the Libby mine or vermiculite processing facilities—and those who lived near these sites—were exposed to hazardous levels of asbestos while the facilities were in operation. (8) The EPA has established the airborne risk level for lung scarring from exposure to Libby Vermiculite at 0.00002 fibers per cubic centimeter. (9) Although not completely comparable, it is interesting to note that this risk level is significantly lower that the permissible exposure limit for asbestos, 0.1 fibers per cubic centimeter, established by OSHA.
Vermiculite has been a hot topic of discussion in New York of late. In New York the Department of Health (NYS DOH) regulates the laboratories and training and the Department of Labor (NYS DOL) regulates the handling and disturbance of ACM. Vermiculite is listed by the NYS DOL as a suspect material but the difficulty in identifying asbestos within vermiculite has posed a dilemma from an analytical standpoint. Therefore, the NYS DOH has produced several guidance documents in regards to vermiculite, the most recent being on July 9, 2013(10). Without going through the evolution of the guidance here is what the recent guidance indicates. In concert with the EPA, it should be assumed that loose fill vermiculite insulation contains asbestos and should therefore be handled as ACM (Asbestos Containing Material: any material containing greater than 1% of asbestos). Where New York State has taken a unique stance, is in regards to materials containing vermiculite as component of the material (i.e. fireproofing – there is a good historical perspective published in 2001 in the NY Times regarding WR Grace and Monokote fireproofing (11)). These materials must be tested per the NYS DOH approved method for friable materials, also known as ELAP method 198.1. During the analysis if the matrix contains 10% or less of vermiculite, the analysis may continue. New to this guidance (previously anything with 10% or more of vermiculite could not be analyzed and had to be handled as ACM) if the matrix of the sample contains greater than 10% vermiculite, the sample must be gravimetrically reduced and analyzed per the NYS DOH method for NOBs (Non-friable Organically Bound), also known as ELAP method 198.6, except that if the sample is determined not to be ACM, the sample does not have to be further analyzed by TEM (Transmission Electron Microscopy). In addition, the lab must include the following disclaimer on the analytical report, “This method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing greater than 10% vermiculite.” It is understood that this is interim guidance and the general perception is that the NYS DOH may have an approved method available as soon as early 2014. However, in this interim, labs probably won’t be sticking out their neck to make a determination as to whether theses samples are ACM or not and will simply use the disclaimer. So, is the material ACM or not? Of course the answer will be no. The determination will fall on the Certified Inspectors and Consultants after they have obtained the lab report and they will most likely not risk losing business by calling the sample ACM. Therefore, at least in my mind, this is a step backwards in regards to protecting individual’s health so the approved method cannot be available soon enough. However, there is another part to this. To my knowledge a formal protocol for the proper sampling of vermiculite and vermiculite containing materials has not been established. So even with an approved analytical method, the lack of established sampling protocols and without proper training in sampling procedures for vermiculite, asbestos may not be consistently identified if present. In any event, I applaud NYS for trying to tackle this issue as the vermiculite originating in Libby, MT has proved to be dangerous and has negatively impacted many lives.
(1) Protect Your Family from Asbestos-Contaminated Vermiculite Insulationhttp://www2.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation
(2) NIOSH Recommendations for Limiting Potential Exposures of Workers to Asbestos Associated with Vermiculite from Libby, Montanahttp://www.cdc.gov/niosh/docs/2003-141/
(4) Libby Site Background http://www.epa.gov/region8/superfund/libby/background.html
(5) Protect Your Family from Asbestos-Contaminated Vermiculite Insulation. http://www2.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation
(6) The Presence of Asbestos-Contaminated Vermiculite Attic Insulation or Other Asbestos-Containing Materials in Homes and the Potential for Living Space Contaminationhttp://www.readperiodicals.com/201210/2781959421.html#ixzz2W6hVEirT
(7) “Mesothelioma in Montana” http://archive.org/details/A18BC2AB-5606-48E2-9E6F-73B535A4EA05
(8) Summary Report: Exposure to asbestos-containing vermiculite from Libby, Montana, at 28 processing sites in the United Stateshttp://www.atsdr.cdc.gov/asbestos/sites/national_map/index.html#Libby
(9) Scientists support EPA draft analysis on Libby asbestos risks http://www.thewesternnews.com/news/local/article_cfe8f69e-7620-11e2-8c5e-0019bb2963f4.html
(10) NYS DOH Interim Vermiculite Guidance July 9, 2013 http://www.labor.state.ny.us/workerprotection/safetyhealth/PDFs/Asbestos/Vermiculite%20Interim%20Guidance%207.9.13.pdf
(11) PROTECTING THE PRODUCT: A special report.; Company’s Silence Countered Safety Fears About Asbestoshttp://www.nytimes.com/2001/07/09/us/protecting-product-special-report-company-s-silence-countered-safety-fears-about.html?pagewanted=all&src=pm
(12) Vermiculite resources
a. The Vermiculite Institute http://www.vermiculiteinstitute.org/
b. The Schundler Company http://www.schundler.com/
This information should be used as a resource and is not a substitute for an individual or an entity from pursuing their own due diligence with regards to regulatory and legal compliance. The author has merely collected information and is not responsible for the compliance or non-compliance of the readers in regards to the information provided.