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Written By: Gary P. Schwartz, CIH, CSP, CMC
January 16, 2020
EPA Issues Clarification on Asbestos Sampling in Newer Buildings
There is a common misconception in the environmental industry that buildings built after 1980 are not required to be inspected for asbestos. However, according to the United States Environmental Protection Agency’s (EPA) Natural Emission Standards for Hazardous Air Pollutants (NESHAP), the age of the building does not affect whether an inspection needs to be done prior to renovation or demolition.
What is Asbestos?
Asbestos refers to two groups of minerals that are naturally occurring in rock and soil. Due to its fiber strength and heat-resistant characteristics, asbestos is used in a wide variety of building materials. Asbestos containing materials (ACM) include, but are not limited to, floor tiles, roofing shingles, insulation, and plasters.
When asbestos fibers are disturbed, they can easily become airborne. These fibers are then inhaled and can cause fatal diseases including, but not limited to, lung cancer, asbestosis, and mesothelioma.
In January 2016, a letter was sent to the EPA asking for clarification regarding what documentation would be needed to identify building materials as non-ACM. According to the author, the following documentation had been commonly relied on by building owners to waive the inspection requirement under NESHAP:
– Safety Data Sheets (SDS) for installed building products
– Letters from each manufacturer certifying that their products do not contain ACM
– Letters from each installer certifying that the installed products are not ACM
The EPA replied to that letter, stating that the owner/operator, prior to a renovation or demolition, must conduct a thorough inspection of either the whole facility or the portion of the facility that will be affected by the renovation or demolition operation, except for residential structures of four or fewer dwelling units, regardless of the date of its construction.
The Issue with Documentation
The EPA further stated that obtaining documentation from manufacturers and installers is not a guarantee that ACM is not present. There have been several instances where follow-up testing found ACM in buildings built after 1980. Furthermore, the EPA currently allows for asbestos to be used in various types of building materials.
The EPA also mentions that the owner/operator may use certain forms of acceptable documentation to certify materials as non-ACM in lieu of an inspection, depending on the circumstances. Applicable documentation would need to provide an explanation on how the asbestos content or lack thereof was determined. Polarizing Light Microscopy (PLM) is the only method of analysis for asbestos that complies with the regulation.
In conclusion, there are three ways to comply with EPA’s Asbestos NESHAP regulations: conduct asbestos sampling and analysis prior to any renovation or demolition, obtain certain forms of acceptable documentation certifying that building materials are not ACM, or simply assume building materials are ACM and follow the applicable regulations accordingly.