Statement by The Vermiculite Association

on the
Recently Released Government Studies
of Vermiculite and the Potential
Asbestos Exposure

May 2005

The Vermiculite Association

Whitegate Acre, Metheringham Fen
Lincoln, LN4 3AL
United Kingdom
In December 2004, the National Institute for Occupational Safety and Health (NIOSH),
Division of Respiratory Disease Studies, Field Studies Branch, released 10 site studies1
measuring asbestos exposure during the handling and expansion of vermiculite and the
use of vermiculite horticulture products. Study sites were selected to include the types
of vermiculite currently in use today. The concern about vermiculite and asbestos grew
out of asbestos problems at the W.R. Grace Libby, Montana mine. The Libby deposit
contained a unique type of vermiculite, which had asbestos as a co-mineral. This W.R.
Grace Libby, Montana mine closed in 1990.

Among the 10 sites studied were three greenhouses using a broad range of commercial
vermiculite growing mixes. The results of these NIOSH studies show that the use of
commercial vermiculite horticulture products presents no significant asbestos
exposure risk to commercial greenhouse or home horticulture users.

NIOSH conducted extensive air sampling on workers and of plant air. These air
monitoring test results were analyzed by three agencies: NIOSH, EPA and OSHA. The
results showed no violations of OSHA or MSHA exposure limits. All air tests showed air
borne asbestos to be below the detectable level of the test procedures utilized. The test
results are expressed as “Below Limit of Detection” (BLD) or below the “Minimum
Detectable Concentration” (MDC).

Bulk samples of vermiculite ore, expanded vermiculite, vermiculite product and

vermiculite waste material were tested for asbestos and none were found to be an
asbestos containing material (ACM). 45 (86%) of the 52 bulk samples were reported by
both EPA and OSHA to have no asbestos. EPA and OSHA disagreed on four bulk
samples where one lab reported no asbestos and the other reported a trace of
asbestos. Another three samples were found to have actinolite-tremolite which can
exist in massive (non-asbestos, i.e. ordinary rock or cleavage fragment, not regulated
as hazardous) form or in a true asbestos crystalline structure (regulated as hazardous).

1
NIOSH site visit reports 2002-0429, through 2002-0438.
The tests on these three samples were inconclusive as to whether or not the trace
actinolite-tremolite was of a massive or asbestos type.

The elongated particles identified in the air tests as asbestos by the phase contrast light
microscope test (PCM) were further analyzed by the more powerful electron microscope
(TEM). These particles had the width and length typical of “cleavage fragments” under
OSHA’s protocol 29 CFR 1926.1101 Appendix B2 and none of the particle widths were
less than 0.1 to 0.2 microns which is the reported diameter of true actinolite-tremolite
asbestos fibers.3 The fact that the particles identified as asbestos fiber were single
fibers and were never found in bundles by EPA, OSHA or NIOSH is a further indication
that the particles are likely to be cleavage fragments.4 Another test, the “Fibrosity
Index”,5 which is a statistical method to identify “cleavage fragments” from “true
asbestos”, shows these particles are cleavage fragments. The NIOSH reports did not
differentiate actinolite-tremolite cleavage fragments from true asbestos nor did they
calculate a Fibrosity Index.

Vermiculite is a general term for various sheet silicates that have inter-layered moisture
and expand with heat. Vermiculites are not all alike, as reported in EPA’s Report 910-
R-01-002.6 Different deposits have different source rocks that have melted or mixed
together to form sheet silicates that were then altered with moisture to form vermiculite.
The W.R. Grace Libby, Montana mine, which had asbestos as a co-mineral, was formed
from biotite pyroxenite and/or biotite rocks to soda rich alkaline pegmatites.7

2
Occupational Safety and Health Administration (OSHA), Department of Labor; 29 CFR 1910, et. al.
Occupational Exposure to Asbestos; Final Rule, August 10, 1994, pp. 41127 and 41145.
3
Selikoff, Irving J. and Lee, Douglas H.K., Asbestos and Disease, Academic Press, Inc., 1978, p. 44.
4
Schneider, Thomas etc. of Arbejdsmilijoinstituttet, AMI Kobenhavn; Davies, Laurie; etc. of the Institute of
Occupational Medicine, IOM, Edinbugh; Burdett, Garry; Health and Safety Executive HSE, Occupational
Medicine and Hygiene Laboratories, Sheffield; Templeman, Jan; TNO Milieu, Energie en procesinnovatie,
TNO, Delft; and Puledda, Salvatore of Isituto Superiore di Sanita, ISS, Laboratorio Igiene Ambientale,
Roma: “Development of a method for the determination of low contents of fibres in bulk material”,
European Community Contract No. MAT1-CT93-0003, November 1997, pp 11-12.
5
Wylie, A.E., “Discriminating Amphibole Cleavage Fragments From Asbestos: Rationale and
Methodology”, Proceedings of the VII International Pneumoconiosis Conference, Pittsburgh, PA, 1990.
6
Frank, David and Edmond, Lorraine; “Feasibility for Identifying Mineralogy and Geochemical Traces of
Vermiculite Ore Deposits”; EPA Report 910-R-01-002, February 2001, p. 5.
7
Ibid, pp 5-6.

2
None of the other Virginia or South Carolina vermiculite, in current use and tested in
these studies, has the geological mineral origins found in the abandoned Libby,
Montana mine.8

Of the 10 locations examined, three sites were government horticulture facilities utilizing
about seven commercial vermiculite horticulture products. The fibers identified and
reported using TEM were so few that they can be discussed individually. At the U.S.
Department of Agriculture, Agricultural Research Service in Beltsville, Maryland, where
two commercial vermiculite products were tested, neither OSHA or EPA identified any
potential asbestos fibers. At the U.S. Department of the Interior, National Park Service
Kenilworth Greenhouse in Washington, D.C., where four commercial vermiculite
products were tested, EPA found no potential asbestos fibers and NIOSH found one-
half of a chrysotile fiber. The test protocol counts a fiber as half, if half a fiber appears
in the microscope target area. However, chrysotile is of a serpentine mineral origin
used in brakes and in the past in spray-on fireproofing9 and not of sheet silicate or of
vermiculite origin.10 Asbestos levels in cities may be about 100 fibers per cubic meter11
(a cubic meter is about the amount of air that you breath in 1 hour).12

At the U.S. Forest Service Genetic Resource Center in Chico California, NIOSH
identified a 12.12 micron long by 5.05 micron wide particle as a fiber. This particle has
a 2.4 to 1 aspect ratio and is a non-fiber because it does not have a 3.0 to 1 aspect ratio
used in the protocol for this NIOSH study. EPA found a single actinolite-tremolite fiber
outdoors, not in the growing facility. The source of this outdoor fiber is not discussed.
Chico, California region is a known area to contain asbestiform minerals in its
bedrocks.13

8
Ibid, pp 9-10.
9
Selikoff, Irving J. and Lee, Douglas H.K., Asbestos and Disease, Academic Press, Inc., 1978, Chapters
One and Three.
10
Ibid, Chapter Two.
11
Agency for Toxic Substances and Disease Registry, Public Health Service, U.S. Department of Health
and Human Services, “Toxicology Profile for Asbestos (Update)”, September 2001, p. 3.
12
Ibid.
13
Campbell, W.J., Blake, R.L., Brown L.L., Cather, E.E. and Sjoberg, J.J. of the U.S. Department of
Interior, “Selected Silicate Minerals and Their Asbestiform Varieties”, Information Circular 8751, 1976, p.
8.

3
The Public Health Service has concluded “low levels of asbestos that present little, if
any, risk to your health can be detected in almost any air sample”.14 Vermiculite is not
the likely source for the chrysotile half-fiber found in Washington, D.C. or the fibers
found outdoors at the Chico, California facility.

Based on these new NIOSH studies of three horticulture facilities run by the U.S.
Government, the use of commercial vermiculite horticulture products for gardening
present no significant asbestos exposure risk to commercial greenhouse or home
horticulture users.

In summary, these new studies, with multi-agency testing and analysis, show air borne
asbestos levels are below detectable limits that pose little, if any, risk to worker health.
This finding applies to potential exposures from the handling, expansion and product
manufacture of vermiculite, including vermiculite gardening products. A previous EPA
study15 using glove boxes and other enclosures to simulate the use of vermiculite
products made several recommendations to consumers and raised the possibility that,
in an occupational setting, these products could present more serious risks. EPA’s
study had numerous analytical errors16 such as misidentifying hornblend and/or
diopside as actinolite-tremolite and not distinguishing non-asbestos forms from true
asbestos forms of minerals. These December 2004 NIOSH studies support the finding
of errors in the August 2000 EPA study, as identified by Chatfield in his November 2001
report and September 2003 Addendum 117.

14
Agency for Toxic Substances and Disease Registry, Public Health Service, U.S. Department of Health
and Human Services, “Toxicology Profile for Asbestos (Update)”, September 2001, p. 3.
15
Janrich, Jed and McDermott, Kevin; “Region 10 Investigation of Asbestos in Vermiculite”, EPA Report
744-R-00-010, August 2000. This report formed the basis for the NOSH follow up study critiqued here.
16
Chatfield, Eric J., “Review of Sampling and Analysis of Consumer Garden Products That Contain
Vermiculite”, EPA 744-R-00-010, presented at The Vermiculite Association Conference, November 11,
2001.
17
Chatfield, Eric J., “Addendum 1 to Review of: Sampling and Analysis of Consumer Garden Products
That Contain Vermiculite”, EPA 744-R-00-010, presented to The Vermiculite Association, September 1,
2003.