ELAP has received several inquires from laboratories regarding the enclosed "Vermiculite Interim Guidance 7-9-13" and results reported following Section 6: "Test Reports". This email is being sent to offer further clarification.
Historically, 198.6, Section 6 has disallowed the reporting of a materials as 'Non-ACM". Instead, samples are required to be reported as 'Inconclusive" with the following qualifier:
"Polarized-light microscopy is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Quantitative transmission electron microscopy is currently the only method that can be used to determine if this material can be considered or treated as non-asbestos containing."
Please note that the "Vermiculite Interim Guidance 7-9-13" has allowed for a unique exception to 198.6 for thermal systems insulation (TSI), surfacing material, or other presumed ACM (PACM) or miscellaneous suspect ACM materials that contain greater than 10% vermiculite. For these materials only, laboratories may report a sample containing greater than 10% vermiculite as either ACM or Non-ACM (accordingly) with the following disclaimer applied to all results:
“This method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing greater than 10% vermiculite.”
TEM analysis via 198.4 will not be required to verify Non-ACM results specifically - and only for - thermal systems insulation (TSI), surfacing material, or other presumed ACM (PACM) or miscellaneous suspect ACM materials that contain greater than 10% vermiculite.