Artisanal And Small-Scale Gold Mining In Nigeria
Artisanal and Small-ScaleGold Mining in NigeriaRecommendations to Address Mercuryand Lead ExposureDATE(and any other info you want to add)November 2014
AcknowledgementsThis report was prepared by the Environmental Law Institute (ELI) with funding fromthe U.S. Department of State. The contents of this report do not necessarily represent theviews of the State Department, and no official endorsement of the report or its findingsby the State Department may be inferred.Principal ELI staff contributing to the project were Lisa Goldman, John Pendergrass,David Roche, Narayan Subramanian, and Judy Amsalem. Any errors and omissions aresolely the responsibility of ELI. The authors welcome additions, corrections, andclarifications for purposes of future updates to this report.About ELI Publications—ELI publishes Research Reports that present the analysis and conclusions of the policystudies ELI undertakes to improve environmental law and policy. In addition, ELIpublishes several periodicals—including the Environmental Law Reporter , TheEnvironmental Forum , and the National Wetlands Newsletter—and books, whichcontribute to education of the profession and disseminate diverse points of view andopinions to stimulate a robust and creative exchange of ideas. Those publications, whichexpress opinions of the authors and not necessarily those of the Institute, its Board ofDirectors, or funding organizations, exemplify ELI’s commitment to dialogue with allsectors. ELI welcomes suggestions for article and book topics and encourages thesubmission of draft manuscripts and book proposals.Artisanal and Small-Scale Gold Mining in Nigeria: Recommendations to AddressMercury and Lead ExposureCopyright 2014 Environmental Law Institute , Washington, D.C. All rights reserved.ELI Project No. 121001An electronic retrievable copy (PDF file) of this report may be obtained for no cost fromthe Environmental Law Institute website, www.eli.org. Click on ―ELI Publications,‖ andsearch for this report. [Note: ELI Terms of Use will apply and are available on thewebsite.](Environmental Law Institute , The Environmental Forum , and ELR – The EnvironmentalLaw Reporter are registered trademarks of the Environmental Law Institute.)Cover Photos:Top: Gold miners in Bagega, Zamfara State. 2013 Lisa Goldman/ELIBottom: Gold miners in Dareta, Zamfara State. 2012 Lisa Goldman/ELI
TABLE OF CONTENTSIntroduction . 1Part 1: Health, Environmental, and Gender Impacts of ASGM Activities . 3Health Impacts . 3Environmental Impacts . 4Gender Impacts . 5Part 2: Overview of Safer Mining Technologies . 9Part 3: Addressing Mercury and Lead Exposure: A Formalization Approach . 14Part 4: The Legal, Policy, and Institutional Framework Governing ASGM in Nigeria . 16Overview of Key Institutions . 16Mining Law, Policy, and Regulations. 17Federal Environmental Laws, Policies, and Regulations. 21International Law . 22State Environmental Laws and Policies . 25Part 5: Recommendations for Strengthening Nigeria’s Legal, Policy, and InstitutionalFrameworks Governing ASGM . 28Legal and Policy Recommendations . 29Priority 1: Address the Cooperative Barrier . 30Priority 2: Strengthen Access to Land . 33Priority 3: Improve the ASGM Licensing Process . 37Priority 4: Ensure Environmental Protection. 40Institutional Recommendations . 42Priority 5: Collect Royalties from Artisanal Mining Activities . 42Priority 6: Strengthen Extension Services and the Dissemination of Improved MiningTechnologies . 44Priority 7: Strengthen Community Education and Outreach . 46Priority 8: Improve Coordination Among Institutions and Stakeholders . 48Financial Recommendations . 50Priority 9: Improve Access to Markets . 50Priority 10: Strengthen Access to Credit . 54Part 6: Approaches for Implementation . 57Notes . 62
IntroductionArtisanal and small-scale gold mining (ASGM) has long been practiced in Nigeria and aroundthe world. Bolstered by historically high gold prices, a lack of viable alternative livelihoods, anda ready – if expensive – supply of mercury, there has been a resurgence of ASGM activities innorthern Nigeria in recent years. This resurgence, however, has come at a price – namely,devastating lead poisoning of children and others from lead-contaminated gold ore, in addition toextensive mercury exposure (whose effects have not yet fully materialized) and significantemissions of mercury into the air and soil. In 2010, unregulated small-scale mining in thenorthern state of Zamfara gave rise to an epidemic of childhood lead poisoning, with at least fourhundred children under the age of five dying within a six-month period (a number that rose toover 700 by 2013). Despite the efforts of development, medical, and environmental experts bothnationally and globally, lead contamination continues to afflict large numbers of children. Thepractice of mercury amalgamation at mining sites has also resulted in widespread contaminationof miners and others working near the mines.The use of mercury in ASGM has been identified as the single largest intentional-use source ofmercury pollution in the world. In most cases, nearly all of the mercury from the processing ofgold ore is either emitted into the air or dumped into the surrounding environment andwaterways, where it can be absorbed by living organisms. Mercury is released into theatmosphere when miners heat the mercury-gold amalgam, driving off the mercury as a gas that iseasily inhaled and poses a grave threat to human health. This exposure to mercury can causeserious damage to the central nervous system, including respiratory failure, nausea, vomiting,diarrhea, increases in blood pressure or heart rate, skin rashes, eye irritation, and kidney damage.In addition to these health impacts, ASGM is associated with significant environmentaldegradation, including toxic pollution of air, land, and water; destruction of flora and fauna;geological instability leading to landslides, flooding, erosion, and tremors; landscapedegradation; and radiation hazards.Unlike countries such as Ghana and Burkina Faso, Nigeria does not have a well-developed largescale mining sector, and the majority of gold mining in the country is carried out by artisanal andsmall-scale miners. Artisanal mining activities in Nigeria are almost by definition informal – thatis, operating outside current laws and regulations. While the current mining law and regulationsdo address artisanal and small-mining activities – mainly by focusing on the provision ofextension services – they do not provide meaningful incentives and assistance for ―formalizing‖miners. For example, the requirement that artisanal miners form cooperatives in order to receiveany technical assistance from the Ministry of Mines and Steel Development (MMSD) is asubstantial obstacle for many miners, and means that most will continue to operate informally. Italso means that these miners, in practice, are unable to seek a small-scale mining license -- theonly license available to them under the mining law. And even where miners have formedcooperatives, it is not clear that they are currently receiving technical assistance from theMinistry.Much research has been conducted on the factors contributing to the poor performance of theartisanal and small-scale mining sector. These include: the lack of simple and transparent legal1
and fiscal frameworks, weak institutional structures, a lack of capacity to implement existingregulations, and a lack of political will.1 In Nigeria, identified challenges include: 1) a lack oforganization and stability among miners; 2) improper mining regulations; 3) illiteracy; and 4) theneed for technical and financial assistance (particularly in the remote regions where minerswork).2 Perhaps most fundamentally, it is the lack of livelihood support for the artisanal goldmining sector that has driven the growth of unregulated mining activities in the region. 3While the pressing need to help miners move away from the use of mercury (as well as practicesthat expose people to lead) is clear, the solution is not. Any meaningful approach must addressthe economic motivations underpinning ASGM activities and present a viable alternative tomercury use. Appealing to public health concerns alone – especially when this appeal is directedat young men – is not sufficient to induce behavioral changes. In short, the current incentivestructure must be altered. As such, this paper addresses fundamental legal and policy constraintsthat are hindering the ability of miners to strengthen and scale up their operations (and in theprocess, transition toward safer mining technologies and practices that do not require the use ofmercury). Without addressing miners' need to access land, obtain permits, secure credit, formcooperatives or other associations, and obtain a better price for their gold, there is little chance ofhelping them transition away from the use of mercury during gold processing. The paper focuseson formalization of the ASGM sector as the framework for instituting these more fundamentalchanges, and presents recommendations that span a range of legal and policy reform measures.While new authority at the legal and regulatory level would certainly be useful – and thisassessment does include suggestions for strengthening the legal framework – therecommendations also focus on how to make the best use of Nigeria‘s existing authorities toaddress lead and mercury contamination, understanding that the process to change the law mightbe too onerous for timely action.In light of the challenges posed by Nigeria‘s deeply troubled petroleum sector, attention isturning to the potentially large role of solid minerals extraction in national (and local) economicdevelopment. Given the lack of large-scale mine operators and the prevalence of artisanal andsmall-scale miners, the time is ripe to ensure that ASGM operators are integrated into the formaleconomy. Such formalization of ASGM miners can benefit practically all actors in the goldmining sector – including the miners (by giving them the security and tools to invest in safer andmore productive mining practices, which should increase their revenue while protecting theirhealth), their communities (by reducing exposure to lead and mercury), medium- and large-scaleoperators (by reducing conflicts over access to mining lands), and the government (by capturinga portion of mining revenue in the form of royalties and taxes that is currently being lost). Thegovernment‘s stated interest in promoting mining as an alternative to oil production and inincorporating lessons learned from the petroleum sector about transparent natural resourceextraction makes this a key opportunity to improve the legal and policy framework. The recentsigning of the Minamata Convention on Mercury by Nigeria, the U.S., and 92 other countriesfurther reinforces the urgency and timeliness of addressing ASGM right now. And given thatartisanal miners are also extracting other solid minerals including wolframite, columbite, andtantalite, which may also expose them to other toxic chemicals, a strengthened legal andregulatory framework will help an even greater number of artisanal miners develop safer andmore productive mining practices.2
Part 1: Health, Environmental, and Gender Impactsof ASGM ActivitiesSince the 2010 lead poisoning outbreak in Zamfara, much attention has been given to thecollateral health and environmental impacts that arise from ASGM. While the Zamfara outbreakshifted much of the focus of the impacts of ASGM to lead, mercury poisoning is an equallyimportant concern. ASGM is currently the largest contributor towards global anthropogenicmercury emissions, responsible for 37% of all such emissions.4 These emissions are also rapidlygrowing; from 2005-2013, ASGM mercury emissions doubled, causing total land and wateremissions to exceed 800 tons per year. Factoring in air emissions, some estimates place the totalfigure as high as 1600 tons per year, although this may simply reflect more accurate reporting.5The very serious (even deadly) impacts of lead and mercury exposure are compounded by thewidespread poverty and general lack of access to health services in many ASGM regions.Adding to this are particular impacts on women and children as well as toxic releases to soils,water, and air. Addressing these health impacts is and will be quite expensive – current treatmentfor lead poisoning victims can run up to 1500/child.Health ImpactsThe health impacts of both lead and mercury are not immediately noticeable and manifestthemselves over time. A comprehensive review of scientific studies indicates that ASGMcommunities experience neurologic and kidney effects, as well as possibleimmunotoxic/autoimmune effects from mercury exposure.6 The most common effects ofmercury exposure are mental retardation, delayed development, seizures, and vision and hearingloss,7 with the cardiovascular and central nervous systems the most vulnerable. Many of thesesame effects occur with lead poisoning, in addition to nerve damage, reproductive problems,liver and kidney damage, and muscle coordination.8 For both mercury and lead poisoning, thehealth effects are more pronounced in young children. Extreme exposure can lead to coma oreven death.9 For women, exposure to mercury positively correlates with an increase inmalformations and miscarriages during pregnancy.10 Many women have also reported menstrualcycle disorders.11Although they both derive from artisanal mining practices, it is important to consider lead andmercury exposure pathways separately. Concentrated lead in the soil from which the gold ismined is the exclusive source of lead poisoning. Lead concentrations in the soil at some locationshave been measured to be greater than 100,000 ppm (or an astonishing 10 percent by weight),vastly exceeding US EPA‘s standards of 400 ppm.12 As the mined ores are mechanically groundand processed, lead dust is released into the air. Dry milling, which is commonly employedduring the processing stage, tends to magnify the level of dust produced.13 In many areas, leadprocessing was typically done within housing compounds, with women using the same mortarsand pestles used to prepare food. Even where this processing occurs outside of the village,miners often return home with clothes contaminated with lead. Children who traveled to the3
mines to sell food during the day are also exposed to lead and mercury contamination, andsimilarly facilitate cross-contamination by bringing unsold exposed food back into the village.Aside from the airborne transport of lead, the grinding and sluicing process often occurs nearvillage water sources, contaminating surface water with lead.Mercury is used in ASGM to amalgamate the gold and separate it from the fine-grained material.The residual mercury attached to the gold is later burned off and released in vapor form, whichcan be easily inhaled by people in the vicinity.14 This pathway can be particularly harmful,15especially since more mercury is absorbed through inhalation than through ingestion or dermalexposure. Some of the mercury runoff also enters waterways, where it is converted intomethylmercury by anaerobic organisms. This methylmercury is absorbed by phytoplankton andmakes its way up the food chain before it is ingested by downstream residents throughcontaminated fish. Methylmercury is known to be far more toxic than pure mercury.16Environmental ImpactsIn addition to the health impacts described above, mercury and lead also impose detrimentalenvironmental impacts. Up to 95% of mercury used in ASGM is released into the environment.17Since mercury air emissions are globally transported, ASGM practices have a global impact.18Dredging and sluicing during mining also cause severe land degradation and river siltation. Theincreases in suspended sediment from river siltation hinder the penetration of light into the waterand greatly affect the supply of nutrients.19 The suspended sediment also tends to carry highconcentrations of mercury. A recent UNEP report predicted that warmer temperatures inducedby global climate change would increase rates of organic productivity and bacterial activity inwater that could trigger a more rapid conversion of mercury to methylmercury, its more potentform.20Unlike mercury, lead dust does not travel very far, but dust that settles out on the ground caneasily contaminate the soil. During periods of heavy rain, the lead can leach into groundwatersystems, contaminating them in the process.21 Lead dust can also affect animals grazing nearbyin many of the same ways it affects humans.22 And, while not the focus of this paper, artisanalmining activities cause other environmental harms, such as the destruction of natural habitats atmining and waste disposal sites.Efforts to minimize the health and environmental impacts of ASGM have mainly focused on leadexposure due to the 2010 lead poisoning outbreak in Zamfara. Basic improvements in ASGMpractices, such as moving operations outside of household areas and villages, have alreadyreduced lead exposure for children and others. Miners are also being encouraged to wash theirhands and clothing before returning to their communities from the processing sites. The Nigeriangovernment has recently been promoting the use of wet milling machines over dry machines tominimize the production of lead dust. In September 2013, the federal government received adelivery of iGoli and wet milling machines from the South African government for the SaferMining Programme in Zamfara (these technologies are discussed further in Part 2).23 However,many areas are still using dry milling machines and other unsafe practices (including mercuryamalgamation) which are continuing to expose miners, their families, and their communities toharm.4
Gender ImpactsAround 30 percent of the global workforce of artisanal miners is composed of women, with thehighest percentage (40 to 100 percent) found in Africa.24 Studies have shown that the smaller thesize of the mining operation and the greater the degree of mechanization, the larger the roleplayed by women. Women‘s roles and responsibilities within gold mining communities varygreatly. While women may dig and carry ore, they are more commonly involved in theprocessing stage, which includes crushing, grinding, sieving, washing, panning, andamalgamation with mercury. (As will be discussed below, women do not appear to be involvedin mercury processing in Zamfara and possibly elsewhere in Nigeria). To a lesser extent, womenmay own mining concessions; serve as mine operators, dealers, or buying agents; or own miningequipment. Women also frequently provide goods and services to mining operations in the formof cooking and selling food, running shops, and sometimes working in the sex trade.Because of their involvement in artisanal gold mining, particularly gold processing, women andtheir children working in artisanal gold mining are susceptible to their own set of healthconcerns. Generally speaking, women face the greatest risks from carrying heavy materials,washing ore in contaminated water, and becoming exposed to chemicals when burning goldamalgam.25 Likely afflictions for women and children working in or around mines includegastroenteritis, lung inflammation, respiratory infections, spinal, joint, neck and back damage,frequent cuts and bruises,26 in addition to the extremely hazardous effects of exposure to mercuryand lead, as described below. These gender-differentiated impacts bring added challenges andconsiderations to addressing needs within the ASGM sector, as well as unique opportunities toimprove the quality of artisanal miners‘ life and health.Mercury ExposureExposure to mercury during the amalgamation process poses one of the greatest health threats towomen working in artisanal gold mining.27 While mercury exposure is dangerous for bothwomen and men, sociocultural factors often lead to greater exposure for women, and womensuffer more severe physical harm from such exposure. In a number of countries (though notnecessarily Nigeria), mercury amalgamation and amalgam decomposition are often carried outby women, putting them in direct contact with mercury. This process can frequently take place inthe home, especially in Muslim communities under Sharia law, where women typically must staywithin their family compounds. Direct open-air burning to separate mercury from the mercurygold amalgam may also take place in the home or small sheds near the mining site, leading tohigh exposure to mercury vapors in these enclosed spaces. The amalgamation process is alsosometimes carried out with cooking stoves and kitchen utensils, items with which women, as thepredominant food providers, frequently come into contact. Additionally, since women areusually responsible for caring for young children and babies, their participation in miningactivities is often done with babies tied to their backs or toddlers at their sides, exposing theirchildren to the same health hazards.5
While awareness of the risks associated with mercury is scarce among all miners, socioculturalinequities particularly hinder access to information for women, often leaving them unaware ofthe risks they and their children face with repeated mercury exposure.Lead ExposureIn addition to mercury, lead also poses significant health threats to women and their children. InZamfara, lead poisoning has claimed the lives of hundreds of children, and even those who weretreated and survived remain in danger. Exposure to the toxic effects of lead stems from the rockgrinding conducted with flour mills and mortars and pestles in the home (although processingactivities have now moved outside the housing compounds in at least some areas); the dust thatminers, young girls selling food to miners, and others transport back to their families on theirclothes and bodies; and the housing compounds‘ dirt floors and mud bricks, which contain leadcontaminated soil. Women spending considerable time with children inside the home experienceeven greater exposure. As girls between the ages of 6 and 15 marry and become pregnant, ―theirbodies will release lead stored like calcium in their bones,‖ according to the Columbia Universityprofessor who developed Succimer, the treatment for lead poisoning.28 This can causemiscarriages and reduced brain function of some form in their children.Other Health and Safety ConcernsOther serious health and safety concerns for women living and working in artisanal miningcommunities include violence and threats to sexual and reproductive health from prostitution andsexual violence.29 Illicit trade in drugs and prostitution, and the violence that often accompaniesit, may be more prevalent in communities established as part of a gold rush than in more wellestablished communities that have a stronger government presence, family ties, and socialcohesion. Nevertheless, violence against women in artisanal mining communities has beendocumented on a global scale. Along with such violence, the sex trade in artisanal miningcommunities leads to a high rate of infection with HIV/AIDS and other sexually transmitteddiseases. Complicating this situation is the fact that women often work longer hours than menbut earn less – studies have shown on average four times less – potentially leading them to seekother sources of income, even through such high-risk work as prostitution. Among the pooresthouseholds in rural communities are those in which the men have migrated to urban areas ormining centers, leaving the women as de facto heads of household. In these and othercommunities with few other options for generating revenue, women may work excessive hours,endangering their health and that of their children without benefits or security. Child prostitutioncan also occur in artisanal and small-scale mining communities, where virginity is held in highesteem and where fears of HIV/AIDS and other sexually transmitted diseases also exist.Addressing Women’s VulnerabilityBecause of their position and roles in the social framework of ASGM communities, women holdthe potential to induce positive change in their communities if their participation in gold miningis strengthened and they are taught safer mining practices.30 Women play a key role incommunity stability, cohesiveness, and morale, and can serve as primary change agents. In somemining communities, they have been identified as strong couriers of information who could help6
influence and improve the mining techniques practiced by their families. (Particular culturalchallenges in Nigeria that may affect this dynamic are noted in the next paragraph.) Whenorganized as a group, women are more likely to raise concerns about rights and safety and maybe more willing to adopt alternative technologies. Additionally, since women bear primaryresponsibility for food preparation, they are best able to respond to education about the healthrisks of consuming mercury-contaminated foods. Women can help change their family‘s foodhabits, such as by reducing consumption of carnivorous fish in areas where mercury is used, orby keeping gold amalgamation separate from cooking areas and utensils.Governments can also support policies and programs geared towards women in artisanal goldmining communities.31 Increased research on women‘s involvement in ASGM can help shedlight on areas where government programs can be most useful. Information can be gathered notonly through dedicated research programs, but also through gender-sensitive training of policeand health workers. Health and security conditions in the communities in which ASGM takesplace vary widely, and this research and information-gathering can help inform gender policiesthat take community-specific circumstances into account. Technical assistance and communitydevelopment programs can help promote employment opportunities for women, support theirparticipation in regional development, support women‘s organizations, incentivize use ofimproved technologies, and conduct public service announcements about the hidden health risksof mercury and lead exposure and the proper precautions miners should take. Training women inmarketing, management, bookkeeping, and other aspects of artisanal gold mining can alsoempower them to benefit more from their involvement in ASGM and help address genderinequities.One example of an approach to addressing gold mining and gender issues can be seen inMongolia, where the Sustainable Artisanal Mining Project – formed to help deliver reform to theartisanal and small-scale mining sector following a government resolution approving regulationof the sector – has incorporated gender considerations throughout its activities.32 The project hasdeveloped gender-sensitive training materials and approaches for use in implementing itsinitiatives. These initiatives, which include capacity building and the development of communityaction plans, must all be gender-sensitive and include proportional participation of women andmen. The project also conducts gender analysis on an ongoing basis to better understand genderbased inequities and demonstrate the link between gender roles and relations and thesustainability of artisanal and small-scale mining activities.ASGM and Gender in NigeriaAlthough it was difficult to obtain gender-specific information during the field visits in Zamfarain 2012-13, women are said to make up a percentage of the artisanal and small-scale miningworkforce (not limited to gold) in Nigeria overall.33 Women in Zamfara had previously taken anactive role processin
Jul 11, 2011 · scale mining sector, and the majority of gold mining in the country is carried out by artisanal and small-scale miners. Artisanal mining activities in Nigeria are almost by definition informal – that is, operating outside current laws and regulations. Whil
The Commercially Viable Conflict-Free Gold (CVCFG) Project, an artisanal mining initiative funded by the United States Agency for International Development (USAID), aims to establish a conflict-free artisanal and small-scale mining (ASM) gold supply chain origina
Sudan's Blue Nile state, which borders Ethiopia's Benishangul-Gumuz region on its eastern side, and South Sudan's Upper Nile region on its south-west frontier, has a long history of small-scale artisanal gold mining. Gold is found in the region's hills and in the alluvial planes south of the Blue Nile. In Blue Nile, artisanal gold .
.56 ohm R56 Green Blue Silver.68 ohm R68 Blue Gray Silver.82 ohm R82 Gray Red Silver 1.0 ohm 1R0 Brown Black Gold 1.1 ohm 1R1 Brown Brown Gold 1.5 ohm 1R5 Brown Green Gold 1.8 ohm 1R8 Gray Gold 2.2 ohm 2R2 Red Red Gold 2.7 ohm 2R7 Red Purple Gold 3.3 ohm 3R3 Orange Orange Gold 3.9 ohm 3R9 Orange White Gold 4.7 ohm 4R7 Yellow Purple Gold 5.6 ohm 5R6 Green Blue Gold 6.8 ohm 6R8 Blue Gray Gold 8 .
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Artisanal (ZEA) and mine there instead. This is set to happen at anro’s Namoya site, which is 225 kilometres southwest of Bukavu, just within the borders of Maniema province, where artisanal miners are supposed to relocate to nearby Matete to mine gold, and production is
CCC-466/SCALE 3 in 1985 CCC-725/SCALE 5 in 2004 CCC-545/SCALE 4.0 in 1990 CCC-732/SCALE 5.1 in 2006 SCALE 4.1 in 1992 CCC-750/SCALE 6.0 in 2009 SCALE 4.2 in 1994 CCC-785/SCALE 6.1 in 2011 SCALE 4.3 in 1995 CCC-834/SCALE 6.2 in 2016 The SCALE team is thankful for 40 years of sustaining support from NRC
UNITED HEALTHCARE INS. CO. SMALL GROUP 61021DE0060002 UHC Choice Gold 0 0-14 389.08 61021DE0060002 UHC Choice Gold 0 15 423.66 61021DE0060002 UHC Choice Gold 0 16 436.89 61021DE0060002 UHC Choice Gold 0 17 450.11 61021DE0060002 UHC Choice Gold 0 18 464.35 61021DE0060002 UHC Choice Gold 0 19 478.59 61021DE0060002 UHC Choice Gold 0 20 493.34
ASTM D 4255 In-Plane Shear Strength / Modulus (Rail Shear) ASTM D 4442 Moisture Content Measurement ASTM D 4585 Controlled Condenstaion Conditioning ASTM D 5229 Moisture Absorption ASTM D 5379 Shear Properties (V-Notch) ASTM D 5420 Gardner Drop Impact Test ASTM D 5467 Skin Compression by Beam Flexure ASTM D 5628 Drop Impact Test ASTM D 570 Water Absorption ASTM D 5766 Tensile Strength, Open .
