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Apr 30, 2012 Mitigating the Risk of Asbestos Rock

Serpentine – A Naturally-Occurring Asbestos Rock.

“If we find 1 percent asbestos in building materials, we tear the building apart and take all kinds of precautions.” says Robert Reynolds, head of the Lake County Air Quality Management District, California. “We should do the same for rock with 1 percent asbestos.” In 1992, Lake County enacted tough regulations for handling chrysotile deposits in the subsurface where disturbance occurs. Companies proposing a construction project, roadbed or quarry on rock containing 1 percent asbestos or more must submit an extensive plan for protecting the health of workers and the community. Dust must be kept so low that it is not visible. Workers must be notified, and precautions are taken so that asbestos is not tracked off site on truck tires.

“There have been too many legal decisions and too many scientific studies for us to continue to breathe this in.” Reynolds says. “We can’t ban it, but we can make sure people are not exposed unnecessarily.”[1]

What It Is

Rock composed primarily of serpentine minerals is called serpentinite. Serpentines find use in industry for a number of purposes, such as railway ballasts and building materials, and find use as thermal and electrical insulation. When serpentine is excavated, or used as a road surface, the asbestos content can be released to the air, and this has caused concern over a long term health hazard from wind-borne dust.

Naturally Occuring Asbestos (NOA) occurs in rocks and soil as a result of natural geological processes. Natural weathering and human activities may disturb NOA-bearing rock or soil and release mineral fibers into the air, which pose a greater potential for human exposure by inhalation. [2]

A California Controversy

There are many known locations of Serpentine rock throughout the New York Metro area (home to Impact Environmental), so it is important that our clients take note of events in California, if only to establish precautionary protocols where NOAs exist. Back in 1965 the California Legislature designated Serpentine (the mineral) as “the official State Rock and lithologic emblem.” But recent controversy regarding the health hazards associated with Naturally-Occurring Asbestos Rock (NOA) created enough concern that in May of 2010, State Senator Gloria J. Romero proposed legislation (SB 624) to removed serpentine as the state rock. With no conclusive evidence regarding the real threat to health posed by the rock itself, any reference to health threats was stricken from the legislation as it was first proposed. For instance, the Act originally held the following language:

“SECTION 1. …(b) Serpentine contains the deadly mineral chrysotile asbestos, a known carcinogen, exposure to which increases the risk of the cancer mesothelioma. (c) California has the highest rate of mesothelioma deaths in the nation. (d) California should not designate a rock known to be toxic to the health of its residents as the state’s official rock. (e) It is the intent of the Legislature to remove serpentine as the State Rock.”

This section was simplified to:

“SECTION 1.  It is the intent of the Legislature to remove serpentine as the State Rock and lithologic emblem.”

This non-committal wording is emblematic of the issue surrounding NOA, i.e. the jury is still out on the real hazards of the rock in its native state (and on the legislation itself), but the documented hazards of asbestos as it has been used in the marketplace raises enough red flags so those concerned with occupational health must take note. For those responsible for the health and safety of employees exposed to this material – in excavation, construction or other tasks – an ignorance of this issue could someday turn into a nightmare of liabilities in the future.

Bloggers and Writers Take Both Sides

Perhaps depending on whether they have direct experience with mesothelioma, writers have lined up on both sides of the hazardous versu nonhazardous issue. In an article published by the NY TIMES –  “California May Drop Its Official State Rock” By Jennifer Steinhauer, July 13, 2010 – Malcolm Ross, a geologist who retired from the United States Geological Survey in 1995, said “There is no way anyone is going to get bothered by casual exposure to that kind of rock, unless they were breaking it up with a sledgehammer year after year.”

Nonetheless, KStarr of Fayetteville, NC, on July 14th, 2010 wrote:

“… I lost my stepfather to asbestos related cancer and all this bill is about is awareness – helping the public to understand that asbestos is a carcinogen and is highly dangerous. It’s not about whether anyone is going to take a sledgehammer to a serpentine rock. It’s about the SYMBOLIC meaning behind it. Good God – 10,000 people die from asbestos related diseases each year in the U.S. and CA has one of the highest rates of mesothelioma deaths (the deadliest of cancers). It is NOT from people going around smashing up rocks. It’s from INDUSTRY – mining sites, etc. where these people worked. Did you know that the rock was made the state rock in 1965 specifically because of the then “lucrative” asbestos industry – so how can geologists now say there is no link to asbestos? CA state geo and enviro groups now ALL agree that asbestos is dangerous and have issued numerous warnings about it. So what we’re really talking about here is removing a symbol that to people like me represents something tragic. And to the guy who said this is still being used to make jewelry – I hope you’re not in the room when that jewelry is being made. Seriously – how ignorant.”

Chrysotile Asbestos

In the IA/ADAO Chrysotile Asbestos Fact Sheet from The Environmental Information Association, the following may be found:

Fact #1: Asbestos is a regulated carcinogen.

California’s Response

In California as a whole, there are already strong requirements in place for construction and grading projects. Full text for the following excerpted “Final Regulation Order, Asbestos Airborne Toxic Control Measure for Construction, Grading, Quarrying, and Surface Mining Operations”, may be downloaded by accessing the California Air Resources Board’s Internet web page at http://www.arb.ca.gov/toxics/atcm/asb2atcm.htm.

New Jersey

More locally, in New Jersey, the transportation of Asbestos and Asbestos Containing Material (ACM) is a regulated activity. The transportation of asbestos and ACM must be handled in accordance with N.J.A.C. 7:26-3.5(d) and other guidelines including:

• Registered New Jersey solid waste vehicles are required for the transportation of ACM and any solid waste containing asbestos. All vehicles shall be designed to prevent any spillage or leakage or emissions.
• There shall be no visible air emissions during loading, transporting, or unloading operations.

Locations Within The New York Metropolitan Area

* From 2005 US Geological Survey Report – Published by the USGS on July 1, 2005, this report contains a regional map and an associated database that includes 324 locations where naturally occurring asbestos has been historically identified in the Eastern United States.

USEPA Guidance on Approaches for Mitigating Exposures to NOA [3]

The USEPA has provided guidance through specific recommendations where NOA is of concern. The extracts below are pertinent. The following general approaches to mitigate inhalation exposures to NOA are aimed at reducing NOA releases from rock or soil into the air:

• Leave NOA material in place and undisturbed
• Cover or cap NOA material
• Limit dust generating activities
• Excavate and dispose of NOA material Depending on the situation, a combination of engineering controls, work practices, and institutional (administrative) controls may be needed to implement an approach and reduce potential exposures to NOA.

Selecting an approach depends on factors including:

• Accessibility of NOA (ground surface vs. below ground surface)
• Types of activities that disturb NOA (construction project vs. gardening)
• Climate and weather conditions
• Current and future land uses
• Technical and administrative feasibility of the approach

Approaches for reducing NOA exposure are similar to practices used for asbestos containing materials in commercial applications.

Excavation, Grading, or Utility Work at Construction Projects

Roads and Parking Areas (unpaved and gravel roads)

Around Communities (playgrounds, ball fields, pathways, and gardens)

Limiting Naturally Occurring Asbestos Exposure To Workers

Beyond the miners who are tasked with extracting asbestos from rock, a number of other workers may be at risk for exposure to asbestos. The job fields that are most at risk to environmental asbestos exposure include construction workers, excavators, lumberjacks, gravel pit operators, farmers and landscapers. Basically, any professional that works in and around asbestos-laden soil is a potentially at risk for exposure. Local health agencies will help you follow Occupational Safety and Health Administration (OSHA) regulations to determine if asbestos is a health risk in your work area. Based on the level of asbestos identified by OSHA, employees may be required to wear Personal Protective Equipment (PPE) such as respirators. Other steps that can be taken to reduce asbestos exposure to workers include:

• Using wet methods when working with soil and asbestos-containing products
• Avoiding the use of compressed air or leaf blowers for cleaning purposes
• Avoiding eating, drinking and smoking in dusty areas
• Limiting access of unnecessary visitors to the worksite
• Showering and washing hair before leaving the worksite
• Changing out of and leaving work clothes at the work site*

In summary, too much is now known about risks to those who live or work closely with serpentine (NOA) rock, to ignore the guidance provided by responsible agencies who are charged with the protection of public health. Any work where these risks occur, should include appropriate risk abatement measures, and local agencies should continue to reinforce local regulation that emphasizes the safety of the public and our work force.

Using foresight now, to navigate the issues that will be crucial to you tomorrow – this is the ongoing philosophy of Impact Environmental. All our clients are concerned with future value and liability. Your values matter to us, and our values demand that we work hard to eliminate your concern. Call us now at 631-269-8800. Welcome to Solid Ground.

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