Alex,
This issue is precisely one of the burning topics which has led to
the EIC/CL:AIRE/BOHS conference on asbestos in soil.
According to my understanding, having discussed the matter with a
number of laboratories and consultants, as well as UKAS and the HSE, even if a
laboratory is conducting basic screening analysis for "asbestos", UKAS
accreditation for identification of asbestos is mandatory as prescribed by Reg.
21 of the Control of Asbestos Regulations 2006:
21(1) Every
employer who analyses a sample of any material to determine whether it contains
asbestos shall ensure that he meets criteria equivalent to those set out in the
paragraphs of ISO 17025 which cover organisation, quality systems, control of
records, personnel, accommodation and environmental conditions, test and
calibration methods, method validation, equipment, handling of test and
calibration items, and reporting results.
(2) Every employer who requests a
person to analyse a sample of any material taken to determine whether it
contains asbestos shall ensure that that person is accredited by an appropriate
body as competent to perform work in compliance with ISO
17025.
Not only that, but by Reg. 21(2), if you are sending samples to a laboratory for identification of asbestos you must ensure that the
laboratory has the appropriate accreditation.
Notwithstanding this, UKAS, it seem, have taken a
position that if you are undertaking the analysis for asbestos in soil, you must
consider fragments of asbestos-containing materials, ACM's, as well as free
dispersed fibres, i.e mass quantification. The rationale here is that
harder to determine fibres will undoubtedly pose a greater/more
significant risk than small pieces of ACM, therefore they must be assessed
if any robust decision is taken regarding hazard and risk, both from a waste
management and a human health risk assessment
perspective.
>0.1% contamination by ACM's (above hazardous waste
threshold) may in fact be more hazardous, and therefore more of a
risk, than 0.001% contamination by free
fibres...
From the work that the EIC's Asbestos Working Group has
done, we do know that a significant proportion of samples that are submitted to
laboratories for soils analysis, and that are not scheduled for asbestos
analysis, have been found to contain (unacceptable) levels of ACM and/or free
asbestos fibre contamination.
The question arises, therefore, why are such
contaminated samples being taken and submitted for environmental analysis
without being scheduled for asbestos analysis in the first place?
Regards
Steve Forster B.Sc. M.Sc. CEnv. FGS
MIEnvSc
Managing Director
IEG Technologies UK Ltd
Unit 12 Langley Wharf
Railway
Terrace
Kings Langley
Hertfordshire
WD4
8JE
Mobile +44 (0) 7855 957140
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Mark
I have spoken with my contact at our testing lab at length about
this issue. In their instance (and again not all labs are the same) they
perform a "informal inspection" of all soil samples for Asbestos. This is
not in anyway accredited or officially sanctioned (although
it is very similar to the official visual inspection version) and is purely
from a H&S point of view for lab staff.
The results aren't ever published (for obvious reasons) but any suspected
detects are subject to further analysis and the client (i.e. us lot)
informed.
Alex Smiles
On Fri, Oct 28, 2011 at 1:38 PM, Claire Stone
<[log in to unmask]>
wrote:
I suspect this is an issue
that will be discussed at length at the conference on Tuesday.
It is worth noting that not
all laboratories deal with asbestos in the same way with regard to chemical
testing of the same sample as detailed below.
I’m happy to be contacted off
list to discuss this further.
Regards,
Claire
Stone PhD, BSc(Hons), AUS,
MRSC
Quality Manager, i2
Analytical Ltd
Building 19, BRE,
Watford, WD25 9XX
T 01923
670020 E: [log in to unmask]
From:
Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of
Reg
Sent: 28 October 2011 13:14
To: [log in to unmask]
Subject:
Asbestos ID - implications for other laboratory
testing!
This is an issue which has been bugging me for some,
but it’s often difficult to find time to write things down. However,
with next week’s CL:AIRE conference in mind, now is perhaps a good time to
raise the issue.
We schedule some soil samples recovered during a
ground investigation for an asbestos “screen”, usually to confirm the absence
of a significant risk, rather than because we expect (due to previous use of
the land), or have seen (during the excavation of trial pits etc), significant
amounts of asbestos.
When we schedule asbestos ID on a soil sample, some
(but not all) laboratories are unwilling to undertake further analysis (for
other potential contaminants) until they receive the results of the ID.
If the result is non-detect, further analysis can be done (but after a
delay). However, if the result is positive the laboratories are not
willing to perform further analysis (especially where this requires sample
preparation – drying & grinding). This issue does not occur if
asbestos ID is not included in the test suite!
Whilst this approach might seem reasonable given
potential H&S implications, it strikes me as nonsensical, given that if
all the soil samples we recover during a ground investigation were rigorously
examined, a significant proportion of them would yield a few asbestos fibres;
but usually only a tiny amount (probably < 0.001% by
mass).
Given the likely presence of asbestos in many soil
samples (albeit in trace amounts), surely laboratories should either: (a)
routinely screen all samples they receive and undertake no further analysis on
samples yielding a positive ID; or (b) ensure that sample preparation and
testing procedures are designed to prevent the release of airborne fibres,
thereby providing “default” protection for laboratory staff in the event that
some samples do contain asbestos fibres. It makes no sense to adopt a
precautionary approach when asbestos ID is scheduled, but do nothing where it
is not.
On a related matter I often find it necessary to
cross-examine labs after the receipt of asbestos quantification results in
order to establish what proportion of the result is associated with loose
fibres and what proportion is “bound” in an ACM(s). Clearly, in the
context of contaminated land risk assessment if the results are due to loose
fibres, they are of far greater significance than if they are due almost
entirely to most ACMs. UKAS\MCERTS protocol does not appear to take
account of this distinction.
Regards
Mark Perrin
Director
Lithos Consulting Ltd
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