Management of Nonfriable Asbestos-containing Materials

Air Pollution Control Program fact sheet
02/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB02156

Disclaimer: The statements in this document are intended solely as guidance. This document is not intended, nor can it be relied on, to create any rights enforceable by any party in litigation. This guidance may be revised without public notice to reflect changes in law, regulation or policy.

Introduction

This document is one in a series of fact sheets designed to assist you in becoming aware of the department’s asbestos requirements. This particular document contains information regarding how to properly remove and dispose of nonfriable asbestos-containing materials.

Categories of Asbestos-containing Materials
There are three categories of asbestos-containing materials (ACM). These materials should be identified by a certified inspector prior to any renovation or demolition activities. They are as follows:

Regulated Asbestos-containing Material includes friable asbestos-containing materials; category I nonfriable materials that have become or will become friable or have been subject to sanding, grinding, cutting, abrading or burning; or category II nonfriable materials that have a high probability of becoming or that have become crumbled, pulverized or reduced to powder due to the work practices used during the course of demolition or renovation.

Removal of Category I and II Nonfriable Materials
Most nonfriable materials are not regulated by the department, unless they are in poor condition or are rendered friable by improper work practices during demolition or renovation. Category I nonfriable materials can be left in place during demolition, provided the work practices used will not make the material friable. However, for certain types of category I materials, such as floor tile and linoleum, the department generally recommends their removal prior to demolition as these materials could easily be rendered friable during the demolition. Also, leaving these materials in place may increase the quantity of asbestos waste resulting in increased disposal costs. It should be noted that materials that contain or are coated with asbestos can not be used as clean fill materials. If Category I ACM is left in place, work practices must be implemented to ensure the material is not made friable during removal or demolition. Any activity that will result in the material being subject to sanding, grinding, cutting, abrading, or burning may cause the material to become subject to regulation, depending on the quantity of ACM involved.

If a threshold or regulated quantity of RACM, including Category II materials, will be impacted, they must be removed prior to demolition or renovation activities. Category II materials must be removed in a manner that does not render the material friable. Improper work practices or materials in poor condition are considered RACM. If the material is crumbled, pulverized or reduced to powder during demolition or removal activities, the material may become subject to regulation depending on the quantity of RACM involved.

Any project involving a threshold amount of RACM (160 square feet, 260 linear feet, or 35 cubic feet) must be performed by a registered asbestos abatement contractor. This includes situations where the material was originally nonfriable but is now in poor condition and situations where nonfriable materials will be made friable during demolition, renovation or removal.

Examples of Nonfriable Materials and Acceptable Removal Techniques

Disposal of Nonfriable Materials
Nonfriable asbestos-containing materials are not subject to the department’s asbestos waste disposal requirements. However, this material is still considered a solid waste and must be properly disposed of at an approved landfill or transfer facility in accordance with the Solid Waste Management Law. You should contact the facility where you plan to dispose of your asbestos waste prior to removal to determine any specific procedures for waste delivery such as packaging, wetting, and labeling.

Nonfriable materials that become RACM must be handled in strict accordance with the requirements for asbestos waste disposal. Projects involving RACM must be performed by registered asbestos abatement contractors who are trained in the provisions for proper handling, packaging and waste disposal. These requirements include packaging the material in leak tight containers or wrapping and properly marking and labeling the bags with an asbestos warning label and information identifying the generator of the waste. The material must be taken to an approved disposal facility, such as a sanitary landfill, that accepts asbestos-containing waste.

Notification Requirements
Provided the nonfriable ACM is in good condition and not made friable during the course of removal or demolition, there is no requirement for notification to be provided to the department prior to removal during renovation projects. However, the department encourages courtesy notifications to be submitted for these projects. Notification is required for all demolition projects involving regulated structures, regardless of asbestos content.
In the event that the nonfriable ACM is in poor condition (friable) or will be removed in a manner that will make it regulated as RACM, then notification must be provided 10 working days prior to the start of the project. This notice should be provided by the asbestos abatement contractor who is to perform the removal.

Minimizing Exposure
For individuals working with nonfriable asbestos-containing materials, respiratory protection consisting of high-efficiency particulate air (HEPA) filtered respirators is recommended. Disposable protective clothing is also advised. An amended water solution consisting of approximately one ounce of liquid detergent to one gallon of water should be used before and during removal to keep the material adequately wet to minimize fiber release. Amended water should not be used on roofing projects where fall hazards exist or near electrical sources. Waste materials should be promptly bagged or wrapped for disposal and taken to a permitted solid waste landfill or transfer station.

While the removal of nonfriable materials may not be regulated under the department’s asbestos requirements, the material can still pose a safety risk if handled improperly. For this reason, the Occupational Safety and Health Administration, or OSHA, also has requirements governing asbestos removal to ensure adequate protection of the workers performing the removal. For any project involving asbestos, whether regulated by the department or not, the department would recommend the use of trained asbestos professionals that are familiar with the OSHA standards for any asbestos removal work. To learn more about OSHA standards for asbestos removal, you may contact OSHA at one of the numbers listed below.

OSHA in St. Louis (eastern Missouri area) - 800-392-7743

OSHA in Kansas City (western Missouri area) – 816-483-9531

Asbestos Contact Information
For more information on the department’s asbestos requirements, you may contact the department’s Air Pollution Control Program or one of the department’s other offices:

Local Agencies
In Missouri, there are also two local agencies delegated by the department to enforce the asbestos requirements. These local agencies may also have more stringent local ordinances that they enforce as well. Prior to performing a project in one of the following jurisdictions, you should contact the appropriate local agency to determine if any additional requirements apply.

Jurisdiction Agency Telephone
Kansas City Kansas City Health Department
Air Quality Program
816-513-6314
St. Louis County St. Louis County Health Department 314-615-8924

Two additional local agencies do not enforce Missouri’s asbestos requirements but may have local ordinances concerning asbestos which they enforce:

Jurisdiction Agency Telephone
St. Louis (city) St. Louis Division of Air Pollution Control
Air Quality Program
314-613-7300
Springfield Springfield-Greene County Health Department of Environmental Services 417-864-1412

Prior to performing a project in one of these jurisdictions, you should contact the appropriate agency to determine if any additional requirements apply.

Missouri Department of Natural Resources
Air Pollution Control Program
P.O. Box 176
Jefferson City, MO 65102
573-751-4817
573-751-2706 fax
http://www.dnr.mo.gov/env/apcp/

Other Department Offices
Regional Offices

Kansas City Regional Office
500 NE Colbern Road
Lee's Summit, MO 64086-4710
816-251-0700
816-622-7044 fax

Northeast Regional Office
1709 Prospect Dr.
Macon, MO 63552-2602
660-385-8000
660-385-8090 fax

St. Louis Regional Office
7545 S. Lindbergh, Suite 210
St. Louis, MO 63125
314-416-2960
314-416-2970 fax

Southeast Regional Office
2155 N. Westwood Blvd.
Poplar Bluff, MO 63901
573-840-9750
573-840-9754 fax

Southwest Regional Office
2040 W. Woodland
Springfield, MO 65807-5912
417-891-4300
417-891-4399 fax

Environmental Services Office
Jefferson City, MO
800-361-4827

Additional Asbestos Related Guidance Documents
For more specific information about the department’s requirements in regard to asbestos, reference the additional guidance documents listed below or contact the department or appropriate local agency at the contact information found in this fact sheet.

These documents are available for free download from the department’s website at www.dnr.mo.gov/pubs/index.html.