THE SCHUNDLER COMPANY


A Scientific and Technical Review of the
2000 USEPA Report on Garden Products that Contain Vermiculite
and the EPA Region 10 Report on Vermiculite


by Bruce Schundler
August 2002

SUMMARY STATEMENT

It is very, very unfortunate that both the USEPA and the EPA Region 10 have neither revised their reports on vermiculite and asbestos, nor corrected the mistaken information about vermiculite and asbestos found in their internet sites and reports.

This is particularly sad because they have had a careful scientific review of their reports for almost half a year---a report by Dr. Eric Chatfield that outlined the technical errors in the reports, the testing limitations, the organizational biases, and the simple mistakes made again and again.

Dr. Eric Chatfield, one of the world's leading experts in asbestos research, testing, and identification, reviewed the EPA's research and wrote:

  • "With the exception of experiments performed using samples of Zonolite from Libby, Montana, the results of these EPA studies provide no scientific basis for the statements that currently available vermiculite products contain asbestos, or that use of these products present measurable risks.
  • EPA ignored its own published definition of asbestos, mis-identified fibers, and applied risk factors that are not valid for non-asbestiform fibers...
  • The conclusions reached by EPA on the basis of their studies are not supported by their data."


THE INITIAL REPORTS AND DR. ERIC CHATFIELD'S REVIEW

  1. In August 2000, the Office of Prevention, Pesticides and Toxic Substances of the USEPA published Report EPA 744-R-00-010: entitled:

    "Sampling and Analysis of Consumer Garden Products That Contain Vermiculite"

    The report consists of two parts: a study by EPA Region 10 in Seattle, Washington, dated July 26, 2000; and, a study by Versar, Inc., under contract with USEPA Headquarters in Washington, D.C., dated August 22, 2000.

    (This report is available on the internet and from the EPA)

  2. Dr. Eric J. Chatfield's "Review of: Sampling and Analysis of Consumer Garden Products That Contain Vermiculite" was presented at The Vermiculite Association on November 15, 2001, presented at a meeting at USEPA to both EPA staff and representatives of its sub-contractors, and a recent conference on vermiculite and asbestos in New Hampshire.

    (This report can be downloaded from The Vermiculite Association (go to Papers and Reports from the TVA )

DISCUSSION:

The published results of both reports suggested commonly used vermiculite might have small amounts of asbestos contamination (very close to the detection limits for asbestos), and that vermiculite should be used outdoors and dampened to avoid generating dust (Region 10 recommendations), and that occupational exposures should be investigated further.

Dr. Chatfield's report demonstrates again and again how unscientific, biased and incorrect these conclusions were.

In Dr. Eric J. Chatfield's review of these reports, he describes again and again the number of mistakes made because of limitations in testing procedures and/or because of bias in the EPA's interpretation of the results.

For instance, in the EPA Region 10 Report:

  • Manchester Environmental Laboratory and Lab/Cor Inc did the analytical analysis for the EPA Region 10 report. In their own reports, the routine PLM measurements conducted by Manchester Environmental showed either no asbestos-forming amphiboles, or a trace of amphibole that was not quantified. And there were no comments on whether what was found was asbestiform or non-asbestiform.
  • Lab/Cor included a disclaimer in their report that "the scope of this analysis is to differentiate purified regulated asbestiform minerals that have been added to bulk building materials. Samples such as soils, sediments or raw ores may require further mineralogical analysis to differentiate mineral species." Essentially this would have meant that any finer with a minimum aspect ratio of 5:1 and with appropriate chemical composition had been reported as asbestos even if they were only cleavage fragments
  • In Lab/Cor's cover sheets for each set of analyses, they clearly expressed the limitations of their methodology and analyses, but EPA investigators disregarded those comments and the limitations.
  • In the simulation studies at Manchester Environmental Laboratory, "no airborne asbestos was detected in the simulation studies using Coles Cactus Mix-known to have been made with Libby, Montana vermiculite. ….After it was found that airborne asbestos was detected only in the Zonolite (Libby, Montana) samples, all subsequent simulation studies were conducted using a mixture of the Libby Zonolite and peat moss.

  • In conclusion:

  • "the EPA Region 10 study did not detect emissions of asbestos fibers from materials derived from current sources of vermiculite. The only sample that yielded airborne asbestos fibers during the simulation studies was a sample of Zonolite originating from Libby, Montana. The Libby mine was closed in 1990, and vermiculite from this source is no longer produced.
  • "There is no scientific basis for the conclusions published in the EPA Region 10 study."

In the USEPA study, Dr. Chatfield also painstakingly outlined some of the mistakes. For instance:

  • "With the exception of the analysis of the Libby Zonolite samples, the analyses of the bulk samples show that the fibers identified as asbestos are actually cleavage fragments."
  • "EPA ignored its own definition of asbestos as specified in EPA/600/r-93/116" by suggesting cleavage fragments were asbestos.
  • In a number of cases, what Versar and EPA thought was asbestos was found to be diopside and hornblende---neither of which is chemically consistent with any regulated asbestos species. (The proper analytical conclusion was determined by the use of energy dispersive X-ray methods.)
  • Unfortunately, "EPA continues to withhold the fiber counting sheets from the simulation studies. Accordingly, no information is available as to whether the fibers counted were asbestos or cleavage fragments."
  • "EPA improperly applied the Integrated Risk Information System (IRIS) to calculation of risks, when the IRIS supporting data included none for tremolite/actinolite, and none for non-asbestiform cleavage fragments. Based on the analyses of the bulk vermiculite samples, it is likely that EPA improperly assigned asbestos risk factors to non-asbestiform amphibole particles that are not asbestos".

CONCLUSIONS:

"With the exception of experiments performed using samples of Zonolite from Libby, Montana, the results of these EPA studies provide no scientific basis for the statements that currently available vermiculite products contain asbestos, or that use of these products present measurable risks.

EPA ignored its own published definition of asbestos, mis-identified fibers, and applied risk factors that are not valid for non-asbestiform fibers...

The conclusions reached by EPA on the basis of their studies are not supported by their data."

COMMENTARY:

Since the publication of these studies, the vermiculite industry in the United States has suffered tremendously. Some estimates conclude the horticultural use of vermiculite is down 75% and that the overall use of vermiculite is down 25%.

And yet, in study after study of existing mines and processing plants by the EPA itself, asbestos fibers have not been found. (See www.schundler.com/techverm.htm)

The Libby, Montana mine did have asbestos, but all the other deposits being used today and all of the vermiculite available to industrial users and consumers today are virtually free of asbestos (note: we say virtually, because although asbestos fibers haven't been found yet, there are "ambient" levels of asbestos throughout the industrial world.)

What is particularly unfortunately in this "episode" of junk science and bad publicity, is that the presence of asbestos in Libby was well known long before reporters like Andy Schneider, or writers for People Magazine or Dateline began writing about it. The EPA, the Consumer Product Safety Commission, NIOSH, and many other state and federal agencies were aware of the problem and had been involved in studies and reports which resulted in the mine being closed in 1990. Since the mid-1970's, there had been lawsuits and litigation against the W.R. Grace Company, and almost all of the cases had been resolved and/or remediated, and compensation had been paid. And because of this history, every significant supplier of crude vermiculite and every major producer or processor of expanded vermiculite had been monitoring or testing vermiculite for the presence of asbestos for thirty years.

And yet what was a new story to some became "news." Because a large corporation like W.R. Grace was involved, the story became even more enticing to reporters and writers. And because the technical issues surrounding asbestos and fibers and what is or what isn't a health concern is so confusing and difficult to ascertain, many mistakes were made by those assessing the studies and reports, by those reporting on them, and by those reading them

The Schundler Company
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