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Written By: Robert E. Sheriff, MS, CIH, CSP, President
June 19, 2017
Asbestos must be removed from a building before it can be demolished.
Asbestos must be identified in any institutional, commercial, or industrial building in the U.S. that is to be demolished. The regulation that requires the asbestos identification is the EPA-NESHAP regulation for asbestos to be found in 40CFR Part 61 Subpart M.
If the amount of asbestos equals or exceeds the specified amounts of Asbestos Containing Materials (ACM), the requirement under NESHAP includes a 10-day notice to the EPA and controlling state agency, and removal, in advance of other demolition, following asbestos abatement methods by a duly licensed asbestos removal contractor.
The limits are:
- 260 linear feet of piping insulation.
- 160 square feet of surface materials.
- 35 cubic feet of facility components where the linear footage or square footage cannot be determined.
The first step is to have the “building-to-be demolished”-surveyed for the presence of asbestos and quantity of asbestos containing materials (ACM). Since there are very specific procedures for surveys—and sampling asbestos—this should be done by an experienced and qualified organization.
Further, most demolition contractors are not licensed by the State for asbestos removal where the demolition project is located. Any removal of asbestos should be performed by a State Licensed Asbestos Removal Contractor. Each State maintains an open list of properly licensed removal contractors. Such lists are usually part of the State’s Environmental Protection Department (names of these departments can vary from state to state).
Another reason that asbestos must first be removed is that much-or-most demolition debris is recycled but asbestos cannot legally be recycled. In fact, many loads of demolition debris—especially from commercial buildings—are rejected by the recycle facility because of the presence of suspect asbestos containing materials (ACM).
The most obvious construction materials that may contain asbestos are from buildings constructed before 1981—but note that this is not absolute!! Floor tiles, caulking, and roofing and other materials were sold in the U.S. after 1981.
The following is a list of materials that have been found to have ACM:
- Piping insulation.
- Boiler and tank insulation.
- Boiler breeching.
- Gaskets and packing on old machinery including compressors.
- Ductwork (both external and internal insulation) including flexible connectors.
- Floor tiles (especially 9” x 9” floor tiles) and floor tile mastic.
- Roofing cements.
- Roofing flashing.
- Roofing felts.
- Roof shingles, roll roofing.
- Transite roofing and siding.
- Wall plaster.
- Wallboard compounds and joint compounds.
- Cooling towers.
- Spray-on fireproofing.
- Fire door cores.
- Laboratory hoods and countertops.
- Vermiculite and blown-in insulations.
- Acoustical plaster.
There are many other types of materials that could contain asbestos that are not building materials. Thus, beware of disposing of machinery or building contents without consideration from whether they contain asbestos.
Often the sampling organization will identify the quantity and condition of the materials found to contain asbestos—and even some cost estimates for removal prior to demolition.