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Memo on asbestos dust sampling methods debate, May 2002

Machine-extracted title · confidence 95%

A letter addressing industry debates regarding the reliability of microvacuum and wipe techniques for asbestos sampling.

NYC-WTC_000151393–000151395

Folder label: “WTC DC TO RC LETTERS CALLEHAN WHITMAN ETC. WARD DOCTOROFF KENNY

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NYC 9/11 Public Portal Document

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ibf Department of To: Commissioner Ward

From: BobAvaltroni

Environmental Date: May 29,2002 Protection 59-17 Junction Boulevard Subject: Asbestos Dust Sampling Flushing, New York 11373-5108

Asbestos dust sampling using microvacuiun and/or surface wipe techniques has been an issue of debate among industry experts and scientists for over a Christopher O. Ward decade. The major issues for acceptance have been the lack of precision and Commissioner the variability of results based on sampling collection methods and types of surfaces sampled.

Robert C. AvaltronI On September 14, 2001, and subsequently on September 26, 2001, the Deputy Commissioner Department released a memorandum to building owners indicating “Wipe Bureau of sampling and/or microvacuum sampling are not recognized methods for Environmental asbestos sampling and should not be used”. This position was taken early in Compliance the response action by the Asbestos Control Program in recognition of the controversial aspects of the sampling and the lack of standards for determination of contamination and cleanliness.

In 1995, the American Society for Testing and Materials (ASTM) issued a standard test method for microvacuum sampling for asbestos.

1. This method placed the burden on the user to determine the applicability of regulatory limitations prior to its use. 2. The standard test method specifically stated the collection efficiency was unknown and varied among substrates. The properties that influence collection efficiency included surface texture, adhesion, particle size distribution, etc. 3. The method specifically stated to “not sample any debris or dust particles greater than 1mm in diameter”. This is due to the interference generated fi'om particles greater than Immcand is a significant drawback for sample collection. 4. The test method therefore required the collection of multiple independent samples fi’om the same area. Quality control for analysis was based on reanalysis of the same samples due to difficulty in preparing quantitative asbestos samples.

The test method did not describe procedures or techniques required to evaluate the safety or habitability of buildings and did not set a standard or guidance for interpretation of the results. This method has not been adopted by any State or -------- local regulatory agency.

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NYC-WTC_000151394

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