A_-_18841_Rome_AF_B-3_asbestos_lead.pdf

C O L D E N C O R P O R A T I O N | 5 8 4 2 H E R I T A G E L A N D I N G D R I V E | E A S T S Y R A C U S E , N Y 1 3 0 5 7

P H O N E : 3 1 5 . 4 4 5 . 0 8 4 7 | F A X : 3 1 5 . 4 4 5 . 0 9 5 1

W W W . C O L D E N . C O M

November 14, 2018

Mr. Daniel B. Heukrath, AIA, LEED AP, CEFPI, NCARB N.K. Bhandari Architecture & Engineering, P.C.

1005 West Fayette Street, Suite 4A Syracuse, NY 13204

Re: Asbestos and Lead Sampling Air Force Research Laboratory B-3 Building- C4 Restrooms and adjacent areas Pre-Renovation Survey Colden Project No. 18841

Dear Mr. Heukrath:

This letter and attachments will serve as our final report for the referenced project.

1.0 Introduction

Colden Corporation was retained by N.K. Bhandari to conduct pre-renovation asbestos and lead based paint sampling in the C4 bathrooms and adjacent areas at Building B-3 at the Air Force Research Laboratory, Rome Research Site located in Rome, New York. The areas surveyed were selected by N.K. Bhandari. Materials to be sampled were identified by Colden Corporation.

Joseph Cantone, CSP, an Industrial Hygienist with Colden, conducted the survey on October 24, 2018. A copy of his New York State Department of Labor (NYSDOL) asbestos inspector certificate and Colden’s NYSDOL asbestos license are provided in Attachment A.

2.0 Analytical Methods

Asbestos samples were submitted to and analyzed by AmeriSci Laboratories of New York, New York. The laboratory is certified for bulk asbestos analysis by the New York State Department of Health (NYSDOH) under the Environmental Laboratory Approval Program (ELAP). The Laboratory’s ELAP number is 11480. Friable bulk samples were analyzed for asbestos content using polarized light microscopy (PLM) in accordance with ELAP PLM Analysis Protocol

198.1. Non-friable asbestos samples were analyzed by PLM and by transmission electron microscopy (TEM) in accordance with ELAP PLM/TEM Analysis Protocol 198.6/198.4.

http://www.colden.com/

Mr. Dan Heukrath NK Bhandari

Building B-3

EMSL of Cinnaminson, New Jersey analyzed the paint chip sample for total lead content in accordance with the Occupational Safety and Health Administration’s (OSHA) Analytical Method OSHA ID-125G and EPA Analytical Method SW-846 6010C. The Laboratory is accredited by the AIHA (Laboratory ID Number 100194).

3.0 Results and Discussion

Sampling results are summarized and discussed in the following sections. A copy of the laboratory report is provided in Attachment B.

3.1 Asbestos Sampling Results

Asbestos sampling results are summarized in Table 1. Material conditions were listed as good, damaged, or significantly damaged in accordance with the U.S. Environmental Protection Agency (EPA) definitions noted below.

• Good – Material with no visible damage, or showing only very limited damage.

• Damaged – Less than one-tenth of the material is damaged if the damage is evenly distributed, or one-quarter of the material is damaged and the damage is localized.

• Significantly Damaged – One-tenth or more of the material is damaged if the damage is evenly distributed or one-quarter or more of the material is damaged and the damage is localized.

The EPA and the NYSDOL define Asbestos Containing Materials (ACM) as materials that contain greater than 1 percent asbestos.

Table 1 Summary of Asbestos Bulk Sampling Results

Sample No. Sample Location Material

Description NOB Condition Lab Result (percent asbestos)

18841-1A Men’s room- wall

Grout NA

NA No asbestos detected

18841-1B Women’s room- wall NA No asbestos detected

18841-2A Men’s room- ceiling 2’x4’ ceiling tiles with pinholes NA

NA No asbestos detected

18841-2B Maintenance office-ceiling NA No asbestos detected 18841-3A Storage room- wall

Sheetrock NA NA No asbestos detected 18841-3B Maintenance office-wall NA No asbestos detected

Sample No. Sample Location Material

Description NOB Condition Lab Result (percent asbestos)

18841-4A Storage room- wall Joint compound NA

NA No asbestos detected

18841-4B Maintenance office-wall NA No asbestos detected 18841-5A Janitor’s closet-abandoned pipe Tan pipe insulation NA

NA No asbestos detected

18841-5B Janitor’s closet-abandoned pipe NA No asbestos detected 18841-5C Janitor’s closet-abandoned pipe NA No asbestos detected

18841-6A Janitor’s closet-abandoned pipe

Gray elbow insulation No

Good 28.6 Chrysotile

18841-6B Janitor’s closet-abandoned pipe Good Not analyzed/ positive stop 18841-6C Janitor’s closet-abandoned pipe Good Not analyzed/ positive stop

18841-7A

Above the ceiling and above bathrooms, storage area and maintenance office- on pipe run with fiberglass insulation

Gray elbow insulation NA

NA No asbestos detected

18841-7B

Above the ceiling and above bathrooms, storage area and maintenance office- on pipe run with fiberglass insulation

NA No asbestos detected

18841-7C

Above the ceiling and above bathrooms, storage area and maintenance office- on pipe run with fiberglass insulation

NA No asbestos detected

18841-8A Men’s room wall behind ceramic tiles Gray tile adhesive NA

NA No asbestos detected

18841-8B Men’s room wall behind ceramic tiles NA No asbestos detected Bold- indicates an asbestos containing material (ACM) Trace – less than 1 percent NOB- non-friable organically bound NA- not applicable

As indicated in Table 1, the elbow insulation on the abandoned water pipes located in the janitors closet is an ACM. There are approximately six elbows in the closet (less than eight linear feet of material). The NYSDOL and the EPA define an asbestos containing material (ACM) as any material that contains greater than 1 percent asbestos.

3.2 Lead-Based Paint Sampling Results

The lead sampling results are summarized in Table 2.

Table 2. Summary of Lead-Based Paint Sampling Results

Sample No. Material Location Material Description Condition Lab Result (percent)

18841-Pb-01 Above ceiling-applied to cinder block wall

White paint Good 1.5

18841-Pb-01 Storage room- wall Pale yellow paint Good <0.0080

As indicated in Table 2, the yellow paint applied to the cinder blocks contains lead.

Employees must be protected from lead exposure in accordance with the OSHA Lead in Construction Standard, 29 CFR 1926.62. Copies of letters of interpretations issued by OSHA on bulk paint sampling are provided in Attachment C. Please note the following:

• OSHA does not recognize the EPA and the HUD definition of lead-based paint (paints containing lead in concentrations of 0.5 percent or greater). In a 1999 standard interpretation, OSHA states:

“The lead-in-construction standard was intended to apply to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon the method of removal and other work place conditions. Since these conditions can vary greatly, the lead-in-construction standard was written to require monitoring or the use of historical or objective data to ensure that employee exposures do not exceed the action level.”

• In a 2003 standard interpretation regarding the use of Lead Check or Lead Alert Test

Kits, OSHA states: “OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead to be acceptable for safely predicting employee exposure to airborne contaminants.”

If you have any questions or need additional information, please contact me at (315) 445-0847.

Sincerely, Colden Corporation

Joseph Cantone, CSP Project Manager

ATTACHMENT A

NYSDOL Certifications and License

C O L D E N C O R P O R A T I O N | 5 8 4 2 H E R I T A G E L A N D I N G D R I V E | E A S T S Y R A C U S E , N Y 1 3 0 5 7

NEW YORK STATE DEPT. OF LABOR HANDLING CERTIFICATE

CLASS C- AIR SAMPLING TECH

CLASS D- INSPECTOR

CLASS H- PROJECT MONITOR

CLASS I- PROJECT DESIGNER

(DOSH442)

C O L D E N C O R P O R A T I O N | 5 8 4 2 H E R I T A G E L A N D I N G D R I V E | E A S T S Y R A C U S E , N Y 1 3 0 5 7

NEW YORK STATE DEPT. OF LABOR HANDLING LICENSE

ATTACHMENT B

Lab Reports

Client Sample Description ConcentrationLab ID Analyzed Weight Lead

Collected

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 786-5974 http://www.EMSL.com cinnaminsonleadlab@emsl.com

Attn: Joe Cantone Colden Corporation 5842 Heritage Landing Drive East Syracuse, NY 13057

Received: 11/07/18 10:00 AM

18848

Fax:

Phone: (215) 496-9237

Project:

10/24/2018Collected:

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*

201812961 CustomerID: GOLD55 CustomerPO:

ProjectID:

EMSL Order:

0.2597 Site: B-3 Cinder Block Yellow Paint Chips

201812961-000118848-Pb-01 1.5 % wt11/13/2018 g10/24/2018

0.2544 Site: B3- Storage Room Yellow Paint Chips

201812961-000218848-Pb-02 <0.0080 % wt11/13/2018 g10/24/2018

Phillip Worby, Lead Laboratory Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 11/14/2018 10:00:23 AM

*Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.008 % wt based on the minimum sample weight per our SOP. Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities. Samples received in good condition unless otherwise noted. "<" (less than) result signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise.

Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

Initial report from 11/14/2018 10:00:23 http://www.EMSL.com mailto:cinnaminsonleadlab@emsl.com

OrderID: 201812961

ATTACHMENT C

OSHA Letters of Interpretation

03/01/1999 - Using X-ray fluorescence for analysis of lead in paint and applicability of other agencies lead levels.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22701[5/1/2013 12:18:00 PM]

Newsletter RSS Feeds Print This Page Text Size

What's New | Offices

Standard Interpretations - Table of Contents

• Standard Number: 1926.62; 1926.62(d); 1962(d)(2) ; 1926.62(d)(2)(i)(A)

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

March 1, 1999

Mr. Hsin H. Chou Project Manager Panacea Environmental Services 7699 9th Street, Suite 102 Buena Park, California 90621

Dear Mr. Chou:

Thank you for your letter of April 22, 1998, regarding the concentration of lead in paint which triggers the lead-in-construction standard, 29 CFR 1926.62. We regret this delay in responding.

The lead-in-construction standard was intended to apply to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon on the method of removal and other workplace conditions. Since these conditions can vary greatly, the lead-in-construction standard was written to require exposure monitoring or the use of historical or objective data to ensure that employee exposures do not exceed the action level. Historical data may be applied to all construction tasks involving lead. Objective data was intended to apply to all tasks other than those listed under paragraph 1926.62(d)(2) of the standard.

OSHA does not consider X-ray fluorescence (XRF) to be an acceptable method of analysis. As stated in your letter, XRF analyzers are generally considered accurate when concentrations of lead in paint exceed 1 mg/cm2. For the purposes of occupational health, these levels are considered substantial and may easily present an exposure hazard. Without having conducted monitoring, or without the benefit of historical or objective data, the employer has no assurance of the employee's exposure.

Other regulatory agencies, such as Housing and Urban Development, the Environmental Protection Agency, and the Consumer Products Safety Commission (CPSC) have designated levels of lead in paint, below which they consider the paint to be non-lead containing. The missions of these agencies differ from OSHA's, and for that reason, OSHA cannot recognize these levels as safe under workplace situations.

OSHA has recognized, however, that for certain workplace conditions, application of objective data to certain tasks listed in paragraph 1926.62(d)(2)(i)(A) may be warranted (specifically, power tool cleaning with dust collection systems, manual demolition of structures, manual scraping, and manual sanding). For these applications only, we have adopted the CPSC threshold under a very limited set of conditions.

Specifically, when a paint contains trace amounts of lead (e.g., 0.06% and below, as defined by the Consumer Products Safety Commission as non-lead containing, 16 CFR 1303), the employer may determine the concentration of lead in the air (i.e., employee exposure) by multiplying the total airborne concentration of dust times the percentage of lead in the paint. For example, if the concentration of total dust is 15 mg/m3 and the concentration of lead in paint is 0.06%, the airborne lead level will be (0.06%) x (15 mg/mm3) x (1000 µg/mg) = 9 µg/m3. Consequently, the airborne concentration of dust would have to be 50 mg/m3 before the action level of 30 µg/m3 would be reached. Arithmetically, this would read, (50 mg/m3 airborne paint) x (0.06% lead) x (1000 µg/mg) = 30 µg/m3 airborne lead.

OSHA wants to stress that this does not set 0.06% as a lower threshold for the concentration of lead in paint which would exempt the employer from the requirements of the standard. The employer must still follow all requirements of the standard and conduct an exposure assessment for the tasks involving lead. Additionally, we are not stating that the Consumer Products Safety Commission level is a "safe" concentration of lead in paint, since all tasks listed under 1926.62(d)(2) frequently entail exposures above the action level, even at extremely low concentrations of lead. We are simply stating that the application of objective data may be applied to the above-specified tasks in paragraph 1926.62(d)(2)(i)(A), under the conditions stated herein. As these are less aggressive, dust-generating methods of removal, this type of objective data may reasonably be applied.

We trust that this satisfactorily answers your concerns. If we may be of further assistance, please don't hesitate to contact the [Office of Health Enforcement] on 202-693-2190.

A to Z Index | En español | Contact Us | FAQs | About OSHA

OSHA Was this page helpful?

Home Workers Regulations Enforcement Data & Statistics Training Publications Newsroom Small Business http://www.osha.gov/as/opa/quicktakes/index.html http://www.osha.gov/rss/index.html javascript:window.print() http://www.osha.gov/whatsnew.html http://www.osha.gov/html/RAmap.html http://www.osha.gov/ http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=INTERPRETATIONS&src_unique_file=I19990301A&src_anchor_name=1926.62 http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=INTERPRETATIONS&src_unique_file=I19990301A&src_anchor_name=1926.62(d) http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=INTERPRETATIONS&src_unique_file=I19990301A&src_anchor_name=1926.62(d)(2)(i)(A) http://www.osha.gov/index.html http://www.dol.gov/ http://www.osha.gov/html/a-z-index.html http://www.osha.gov/as/opa/spanish/index.html http://www.osha.gov/html/Feed_Back.html http://www.osha.gov/OSHA_FAQs.html http://www.osha.gov/about.html http://www.osha.gov/index.html http://www.osha.gov/as/opa/quicktakes/index.html http://www.osha.gov/rss/index.html javascript:window.print() javascript:void(0) http://www.osha.gov/index.html http://www.osha.gov/workers.html http://www.osha.gov/law-regs.html http://www.osha.gov/dep/index.html http://www.osha.gov/oshstats/index.html http://www.osha.gov/dte/index.html http://www.osha.gov/pls/publications/publication.html http://www.osha.gov/briefing.html http://www.osha.gov/dcsp/smallbusiness/index.html

03/01/1999 - Using X-ray fluorescence for analysis of lead in paint and applicability of other agencies lead levels.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22701[5/1/2013 12:18:00 PM]

Freedom of Information Act | Privacy & Security Statement | Disclaimers | Important Web Site Notices | International | Contact Us

U.S. Department of Labor | Occupational Safety & Health Administration | 200 Constitution Ave., NW, Washington, DC 20210 Telephone: 800-321-OSHA (6742) | TTY: 877-889-5627 www.OSHA.gov

Sincerely, Richard E. Fairfax Director Directorate of Compliance Programs

[Corrected 9/24/2008]

Standard Interpretations - Table of Contents http://www.osha.gov/as/opa/foia/foia.html http://www.dol.gov/dol/privacynotice.htm http://www.dol.gov/dol/disclaim.htm http://www.dol.gov/dol/aboutdol/website-policies.htm http://www.osha.gov/international/index.html http://www.osha.gov/html/Feed_Back.html http://www.osha.gov/ http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT

07/18/2003 - Acceptability of rhodizonate-based spot test kits for determining the presence or absence of lead in paint coatings.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24601[5/1/2013 12:20:33 PM]

Newsletter RSS Feeds Print This Page Text Size

What's New | Offices

Standard Interpretations - Table of Contents

• Standard Number: 1910.1025; 1926.62

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

July 18, 2003

Mr. Charles Hyder, CIH 28 Bartlett Drive Schwenksville, PA 19473

Dear Mr. Hyder, This is in response to your letter of March 4, 2003, to Mr. Richard Fairfax, Director of Enforcement Programs for the Occupational Safety and Health Administration (OSHA). You asked about the acceptability of rhodizonate-based spot test kits for determining the presence or absence of lead in paint coatings. Your letter was forwarded to the Directorate of Science, Technology and Medicine for response. You wanted to know, specifically, whether a negative finding, obtained using either the Lead Check or Lead Alert test kits, would be sufficient to conclude that lead was not present for the purpose of complying with OSHA's Lead Standards, 29 CFR 1910.1025 and/or 29 CFR 1926.62.

OSHA's mission is to provide a safe and healthful working environment for American workers. To accomplish this task in the area of occupational exposure to lead, we require the employer to perform an initial determination which requires the employer to monitor workers' exposure unless the employer has objective or historical data that can reliably demonstrate that no employee will be exposed to lead at or above the action level. OSHA's does not consider any method that relies solely on the analysis of bulk materials or surface content of lead to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed at or above the action level during any process, operation, or activity), as required by 29 CFR 1910.1025 or 29 CFR 1926.62, the employer cannot rule out the possibility of excess worker exposure to airborne lead.

I trust that this satisfactorily answers your concerns. If we may be of further assistance, please don't hesitate to contact [the Office of Science and Technology Assessment at (202) 693-2095].

Sincerely, Ruth McCully Director Directorate of Science, Technology and Medicine

March 4, 2003

To: Mr. Richard Fairfax, Director Directorate of Compliance Programs U.S. Department of Labor Occupational Safety & Health Administration 200 Constitution Avenue Washington, D.C. 20210

From: Charles Hyder, CIH 28 Bartlett Drive Schwenksville, PA 19473

Dear Mr. Fairfax, Is the use of Rodizonate-based spot test kit acceptable for determining the presence or absence of lead in a paint coating in order to comply with 29 CFR 1926.62? In 1994 the OSHA Technical Center evaluated two commercially available kits:

A to Z Index | En español | Contact Us | FAQs | About OSHA

OSHA Was this page helpful?

Home Workers Regulations Enforcement Data & Statistics Training Publications Newsroom Small Business http://www.osha.gov/as/opa/quicktakes/index.html http://www.osha.gov/rss/index.html javascript:window.print() http://www.osha.gov/whatsnew.html http://www.osha.gov/html/RAmap.html http://www.osha.gov/ http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=INTERPRETATIONS&src_unique_file=I20030718&src_anchor_name=1910.1025 http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=INTERPRETATIONS&src_unique_file=I20030718&src_anchor_name=1926.62 http://www.osha.gov/index.html http://www.dol.gov/ http://www.osha.gov/html/a-z-index.html http://www.osha.gov/as/opa/spanish/index.html http://www.osha.gov/html/Feed_Back.html http://www.osha.gov/OSHA_FAQs.html http://www.osha.gov/about.html http://www.osha.gov/index.html http://www.osha.gov/as/opa/quicktakes/index.html http://www.osha.gov/rss/index.html javascript:window.print() javascript:void(0) http://www.osha.gov/index.html http://www.osha.gov/workers.html http://www.osha.gov/law-regs.html http://www.osha.gov/dep/index.html http://www.osha.gov/oshstats/index.html http://www.osha.gov/dte/index.html http://www.osha.gov/pls/publications/publication.html http://www.osha.gov/briefing.html http://www.osha.gov/dcsp/smallbusiness/index.html

07/18/2003 - Acceptability of rhodizonate-based spot test kits for determining the presence or absence of lead in paint coatings.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24601[5/1/2013 12:20:33 PM]

Freedom of Information Act | Privacy & Security Statement | Disclaimers | Important Web Site Notices | International | Contact Us

U.S. Department of Labor | Occupational Safety & Health Administration | 200 Constitution Ave., NW, Washington, DC 20210 Telephone: 800-321-OSHA (6742) | TTY: 877-889-5627 www.OSHA.gov

LEAD CHECK ™ Test Kit (HybriVet System, Inc.)

LEAD ALERT ™ All In One ™ Professional Kit (Sensidyne)

If either of these kits (or an equivalent) are used and a negative finding for lead is made, will this be sufficient to produce a determination that lead is not present for the purpose of complying with the Standard?

Regards, Charles Hyder, CIH

Standard Interpretations - Table of Contents http://www.osha.gov/as/opa/foia/foia.html http://www.dol.gov/dol/privacynotice.htm http://www.dol.gov/dol/disclaim.htm http://www.dol.gov/dol/aboutdol/website-policies.htm http://www.osha.gov/international/index.html http://www.osha.gov/html/Feed_Back.html http://www.osha.gov/ http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=&p_status=CURRENT