Friable Asbestos Materials from Facilities...

Friable Asbestos Materials from Facilities
Containing Less than or Equal to 1% or Trace Amounts of Asbestos

The definition of friable asbestos materials found in the federal asbestos National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 61, Subpart M, Section 141) states, “If the asbestos content is less than 10 percent as determined by a method other than point counting by polarized light microscopy (PLM), verify the asbestos content by point counting using PLM.” However, it makes little difference if a material is determined to be ten percent (10%) or eleven percent (11%) asbestos, but it is significant if it contains one percent or less (<1%) of asbestos because Spokane Regional Clean Air Agency (SRCAA) regulates asbestos material containing (ACM) greater than one percent (>1%) asbestos. Therefore, if laboratory results indicate a sample contains one percent or less (<1%) of asbestos using standard PLM, the owner or operator of the facility must either (1) treat the material as ACM and have it properly removed and disposed of as such or (2) verify it contains one percent or less (<1%) of asbestos by having it point counted using PLM (sometimes referred to as "EPA Point Count 400").

Most of the time, point counting by PLM must be requested by the client because the certified AHERA Building Inspector will not automatically request this service from the laboratory performing the analysis. It should be noted that a sample in which no asbestos is detected by standard PLM does not have to be point counted. In addition, if the results derived from point counting by PLM differs from the standard PLM results, the point counting results override the standard PLM results. Depending on the laboratory and requested turn around time, standard PLM analysis costs about $25 and point counting by PLM costs about $50.

In summary, bulk samples of suspect ACM must be point counted using PLM when the sample is: (1) from a facility*, (2) friable*, (3) found to contain one percent of asbestos or less (<1%) asbestos using standard PLM, and (4) the client does not want to have the material removed and disposed of as ACM.

* For definitions, click here to refer to SRCAA Regulation I, Article IX, Section 9.02.