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Rick Kuhlman

Rick Kuhlman

Rick Kuhlman is the president and owner of HEPA Environmental Services, Inc. He has a bachelor of science from Florida Tech in Biological Oceanography, 1993. He has successfully run a full service asbestos abatement company for over 11 years. Most importantly he has helped people from all walks of life deal with their environmental problems in a safe and efficient manner and had a great time doing it.

Is asbestos falling through the cracks In Ohio?

A Crack in the Asbestos Detection Process

A subtle change in asbestos sampling and reporting has happened in Ohio and it’s allowing asbestos to “fall through the cracks.” It once was that during a typical survey, the licensed Evaluation Specialist (ES) would inspect areas such as finished drywall walls. This type of wall has mudded and taped joints and is made up of a mixture of layered materials that could include asbestos. The ES would identify the homogenous areas (HAs) in the wall, sample each HA, and analyze each layer for asbestos content.

But Ohio EPA no longer requires this detailed asbestos analysis. And this could allow dangerous asbestos to go undetected.

Why Ohio Regulatory Requirements Changed

In 2018, the Ohio Department of Health (ODH) merged with Ohio EPA to form one governing body for asbestos in Ohio. Before this, the ODH had used a combined regulatory approach (i.e., a mixture of OSHA and EPA regulations). After ODH was absorbed into Ohio EPA, they began following just EPA regulations. It’s the OSHA regulations, however, that require the analysis of layers for asbestos.

The Ohio EPA asbestos program includes what EPA calls “letters of interpretation.” One of these letters of interpretation says that when sampling a wall system, it’s fine to composite the layers. From the EPA website February 11, 2021:

“As stated in the January 5, 1994 Asbestos Sampling Bulletin clarification, joint compound and wallboard form a “wall system,” and the Environmental Protection Agency (EPA) therefore recommends the use of a composite analysis for this material. See 59 FR 542; see also 60 FR 65243 (1995). For joint compound (not skim coat), EPA recommends that an accredited inspector take a weighted average of the different wall system components to arrive at the final reportable number.”

Once Positive for Asbestos Can Now Be Negative?

When asbestos is found in drywall walls, it’s usually found in the joint compound and not in the wallboard. A sample of a finished layer of drywall will likely have a thin layer of joint compound and a much thicker layer of wallboard. So when compositing the two layers, there will be a much greater amount of wallboard than joint compound. When sampling by layer, analytical might show a quantity of asbestos greater than 1% in the joint compound but non-detect in the wallboard.

Before 2018 the wall system would have been positive for asbestos, but not now. Today a composite will likely yield a result of less than 1% or trace, which is less than EPA’s definition of asbestos-containing (i.e., greater than 1%).

OSHA Objects to Composite Asbestos Testing

Allowing higher levels of asbestos to stay in wall systems was probably not an evil plot on the EPA’s part, but rather an unintended consequence of the merger with ODH. OSHA, though, does not agree with this practice. The following is an excerpt of a letter from Mr. Stephen Mallinger, OSHA Acting Director, to Mr. Gary Thibodeaux of the National Service Cleaning Corporation:

“You ask whether the Occupational Safety and Health Administration (OSHA) considers sheetrock and joint compound to be a composite material that may be analyzed for asbestos content by collecting composite bulk samples. By interpretation of the definition of asbestos containing material (ACM) presented at 29 CFR 1910.1001(b), [29 CFR 1915.1001], and 29 CFR 1926.1101(b); OSHA regards sheetrock and joint compound as separate materials. Each of these materials that may contain asbestos must be analyzed separately for their asbestos content.”

It’s pretty clear that OSHA expects analysis by layer, not by composite.

What’s the Best Asbestos Testing Practice?

So what should happen now? Follow OSHA, test in layers, and move on. The defense that “the EPA made me do it” is probably not going to work if OSHA shows up asking why wall samples were composited. And how would hazards be properly communicated to an employee charged with removing that drywall? Or, more importantly, what to say to that employee’s lawyer?

Analyze by layer. Letting asbestos fall through the cracks due to a regulatory loophole is plain wrong.

For more information or to chat about this, contact Rick Kuhlman President of HEPA Environmental Services, Inc., rick@hepa1.net

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You came to the right place!

We have been removing asbestos for over 11 years and vermiculite has continued to grow as an asbestos issue.  We have climbed into many attics all over Ohio and I wanted to share what we have learned and help out as much as possible.

If you want to learn more general information about asbestos you can visit our FAQ page.  Below are some pictures of vermiculite from the US EPA website.


What is vermiculite?

Vermiculite is a loose fill insulation used mostly in attics and sometimes in walls.  A particular brand of vermiculite was mined in Libby Montana by W.R. Grace.  For several years, it was used as insulation in residential and industrial applications.  Several years later, after it was installed in thousands of attics,  it was found to contain naturally occurring asbestos.  Now many homeowners are faced with the question of what to do.  

To sample or not to sample?

We say "don't sample".  Why?  Well there are some fancy ways to sample vermiculite and some traditional methods but it is difficult at this point to tell which method is the best.  Some reports will tell you that you have less than 1% asbestos content (not regulated by EPA) and that is nice but it is also like being a little pregnant. 

If you have asbestos in your vermiculite, at any percentag,  then you have asbestos.  There is no safe level of asbestos in a material; there are only safe standards for how many fibers that can be in air. 

For example, if you had less than 1% asbestos content in the vermiculite and your friend uses a leaf blower in your attic to dust, this would create a major exposure.  Ok, that example is a little extreme but if you disturb the material it will become airborne.  You may feel better because it was less than 1% but that doesn't guarantee the fibers will not get into the air.  So the only safe bet is to assume there is asbestos and treat it accordingly.

To remove or not to remove?

I believe itdepends on what you are doing now and what you have planned in the future.  If you have vermiculite in the attic and you do not use the attic for storage or go into the attic, then leave it undisturbed.  Chances are unlikely that you will have an exposure above the Permissible Exposure Limit, PEL.  But, if you try to sell that home, the home inspector may discover it and you may have to remove it. It iis our experience that any environmental issue can complicate a real estate deal.  If you plan on renovating the space and the renovation process may disturb the material; then you need to abate the hazard prior to construction.

What if you store stuff in the attic but do not go up there that often?  This is the most difficult question, because I cannot answer this one; only you can.  You have to decide what your own personal level of concern is with respect to asbestos exposure.  We cannot say how much asbestos is ok to breathe.  OSHA was kind enough to set the PEL at 0.1 fibers per cubic centimeter but even that is set for an 8-hour work day not based on living in the home.          

How much does this cost?

This is a difficult question-unless we can see your attic, access, and the amount of  personal belongings stored there.  Typically, the low end is approximately $4,000.00 and on the high end $20,000.00.  We do understand, that is a big variance.  Email us some pictures, rough dimensions, and a picture of the access or description (for example do you have fold down stairs, access from the garage, or is it going to take quite a bit of prep to access the attic?).  You can email us from our Contacts Page.  We will access a ball park estimate and if you are still interested we will discuss the next step,  which would be a site visit and a formal written proposal.  

Zonolite Trust aka ZAI trust.

A trust has been formed by WR Grace to help pay for abatement of vermiculite but there are some tasks for you to complete in order to receive the money.  You will need to fill out some paperwork and submit a sample or proof that the vermiculite in the attic is their product.  To clarify, only the folks at the trust can decide if you are eligible for compensation so sending a sample to a lab will not help your get compensation.  I have confirmed that one client did receive compensation after submitting all of the samples and correct documentation.  I have a link at the end of this post where you can check out their website for more information.

How we do it.

We have invested in the safest, cleanest, and most efficient solution to vermiculite and we call it, a vermiculite eating machine.  We set your attic up as a containment with negative air pressure so what happens up there either stays up there or is filtered out.  We mobilize an enclosed trailer safely outside your home and pull a 100 foot hose into your attic though an attic vent, vacuum the material out though the hose.  This eliminates the need to bag the material and carry it through your home.


If you want the safest, cleanest, and most efficient removal of your vermiculite give us a call 330.818.0188.

ZAI Trust Link

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At least once a week we get a call from a home buyer who has just been informed that the home inspector just found asbestos in the house they want to buy.  I would assume since you are in the inspection phase of the process that you did want to buy this house and now you just need to get some perspective on asbestos.  It is not the end of the world and not the end of the deal.  The fact is: any house new or old may have asbestos in the building materials.  Does that mean every house has asbestos in it, no, but unless you sample every building material; you do not know for sure.  If you think asbestos is banned you need to refer to my earlier post “To test or not to test”.  So you may have asbestos in this house what now?  It can it be repaired, removed, enclosed, and in good condition left alone. 

Which option should I choose?  First, I would ask what your plans are for that space.  A common example and frequent call is about the grey/white duct tape or insulation on heating duct.  If the insulation is in good condition and is located in the basement and you wish to use that space for storage and do not plan to spend much time down there then I say; leave it alone.  If the material is in bad condition it will require removal or repair.  If you plan to change the heating system and renovate the space into a play room for the kids then I would recommend removal.                                              


You could encapsulate the insulation but I always say if a kid can hit it with a broom stick then get it out of there, if you do not have kids, good choice you have nothing to worry about it including college payments, just kidding.  Other materials can make for other decisions I would treat pipe insulation, floor tile, wall, and ceiling materials the same as the duct situation.  Vermiculite however is a different animal; it is loose fill material and can be disturbed with minimal activity so that makes it easier to create an exposure and brings in some real concerns about using the space for any reason.  For that reason we recommend removal of the vermiculite so that the space can be used, most of the time this is an attic and if you have a family you probably need storage space.

The cost of abatement varies based on access, location, type, and quantity so to help with perspective I am going to give you some typical costs.  Disclaimer: prices may vary based on your situation.  No two abatement projects are the same so it her it goes.  Duct insulation removal usually runs from $1,400.00 to $2,000.00, duct insulation repair is usually like $200.00 less than that.  For pipe insulation figure $250.00 to get there and $15.00 per foot for removal.  Floor tile might be $250.00 to get there plus $4.00 per square foot.  Vermiculite can be on the higher end about $4,000.00 to $8,000.00 and for really complicated attics I have seen that go north of $12,000.00.  I am sure someone will tell you that they can beat these prices, which is fine by me, I cannot promise that we will be the cheapest but I can promise you that no one in this business will care more about you and your customer experience than us. 

So finding asbestos is not the end of the world.  Be happy that someone was looking out for you, and now you know someone who can fix it! 

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“My house is newer so I don’t have to test for asbestos, right?”

WRONG! There is no magic date in which asbestos was no longer used.  In fact, asbestos is not completely banned in the United States. Only 10 asbestos containing products are currently banned; the other several thousand are legal.  If you go to your local building supply store and start sampling you may find materials containing asbestos on the shelf for sale.  Worst of all, many people still believe that asbestos is only an issue in old buildings.  That thought has led to another problem:  resistance to sampling for asbestos prior to a demolition or renovation.  The EPA regulation, NESHAP says that …the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, must thoroughly inspect the affected facility for the presence of asbestos…  There is no mention of a date; it just says an owner must thoroughly inspect.  The EPA is not the only agency that regulates asbestos, OSHA also regulates asbestos. OSHA has regulations to protect workers and the public from asbestos exposure, but how do you know if you need training or protection if you don’t even know if you have asbestos?  In order to comply with those regulations you must know if asbestos is present. In the asbestos world you have two options:   assume the material has asbestos or sample, test, and prove otherwise.  Now I have seen some people try the “I didn’t know any better” defense which didn’t work for me the other day when I was pulled over for speeding, and I am pretty sure it will not work with a pissed off government regulator. One of the biggest reasons people believe that newer construction doesn’t have asbestos is the belief that asbestos is or was banned.  Many asbestos products were banned in 1989 but that ruling was over turned in 1991 since the Fifth Circuit Court of Appeals found that EPA did not review economic effects on both sides of the case. They did manage to uphold the ban on thermal system insulation, fireproofing, spray applied surfacing, wall patching, corrugated paper, roll board, commercial paper, specialty paper, and flooring felt and any new uses of asbestos.  They are banned but that doesn’t mean they automatically disappear from all of the buildings in the United States or that other countries will follow the ban.  So it is here and still being installed in new construction. Below is an excerpt from a disturbing article by asbestosnetwork.com:

“Asbestos Found in Many Common Household Products”

…Products that were found to contain asbestos were turned up in children's toys, appliances, hardware, household goods, and home and garden items such as:

  • CSI Fingerprint Investigation Kit
  • Six colors of clay in Art Skills' Clay Bucket
  • Three varieties of Ja-Ru Toy Clay
  • DAP 33 window glazing, made in the USA, and purchased at Lowe's and Home Depot
  • DAP Crack Shot spackling paste, made in the USA, and purchased at Lowe's and Home Depot
  • Gardner Leak Stopper Roof Patch made in the USA, and purchased at Lowe's, Home Depot and Wal-Mart
  • Scotch Duct Tape: High Performance, made in Canada, and purchased at Wal-Mart.

So how do you protect yourself from liability at work or protect your family at home…Follow the law!  Find out if a material has asbestos in it before you disturb it.  

You need to ask yourself “….did I take the appropriate precautions to protect my employees, contractors, or family? 

Do I know for sure? ”Ignorance is not bliss; hire a professional to find out if you have asbestos and then have it abated before you have to explain it to a lawyer on the witness stand!

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It’s hard to watch late night TV without seeing one of those asbestos commercials from a law firm wanting to know if you are sick.  This has raised some awareness and has prompted some questions from clients and friends.  Awareness is a good thing, at least people are asking questions (ignorance is not bliss).  Most people think that asbestos is only in old buildings and some think it has been removed.  Not the case, it is still around and in many buildings, some old and some new.  So, I will try to explain what asbestos is and why you may want to know about it.

Asbestos is a naturally occurring fibrous mineral that has great properties like heat, chemical, and weather resistance.  These properties make it a great additive to building materials like plaster, flooring, and thermal system insulation.  There are actually thousands of uses for this mineral.  It actually was a good thing when used properly.  However, those properties that make it great for building materials also make it hard for the human body to deal with.  When asbestos containing materials (ACM) are disturbed they can release asbestos fibers into the air and you could inhale or ingest them.  In your lungs you have tiny air sacs call alveoli (they help in the transfer of oxygen into the blood stream).  That air sac can be punctured and since the physical shape of the fiber has a barbed end like a fish hook they are not swept out of the lungs like other fibers you inhale.  That punctured air sac dies and the body forms scar tissue around it and you have one less alveoli.  Enough exposure over a period time can lead to reduced lung function called asbestosis.  These abnormalities can later develop into lung cancer.  Mesothelioma is when that fiber works its way through the lung tissue and settles in the pleural lining of the chest cavity and cancer forms.   I am not a doctor, so that is my basic knowledge on asbestos health effects and I always tell people if you have specific questions about your health or asbestos health risks ask your doctor.

How do you protect yourself from this hazard?  There are many ways to prevent or limit exposure.  The big thing is: knowing where it is and where it isn’t.  If you are doing a renovation on your home or business; ask the question “did you test for asbestos?”  Not everyone will be happy about you asking questions, but if you want to be safe then ask.  Once you know where it is you can hire a licensed contractor to abate the hazard.  We have cleaned up some pretty big messes from other contractors who should have tested materials before disturbing them.  How many times have you thought “hindsight is 20/20”, probably thousands for me.  Do yourself a favor and test the materials, put a plan together to prevent problems, so you don’t make new ones. 

Don’t wait until you need a lawyer.  Do it now.

Tagged in: Asbestos 101
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