Asbestos Requirements for Demolition and Renovation Projects
|Air Pollution Control Program fact sheet||
|Division of Environmental Quality Director: Ed Galbraith||
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.
This document is one in a series of fact sheets about the Missouri Department of Natural Resources’ asbestos requirements. This particular document contains information regarding how to determine if your demolition or renovation project is regulated by the department’s air pollution control requirements. It also will help explain the basic requirements for asbestos inspection and asbestos abatement as well as for notification of regulated demolition and renovation projects. In addition, it discusses requirements for disposing of asbestos waste.
Determining if Your Project Will Involve Regulated Structures
The first step in determining if your demolition or renovation project is regulated is to determine the type of structure that will be affected. The department regulates demolition and renovation projects involving institutional, commercial, public, industrial, or residential structures, installations or buildings. An exception to this regulation is a single residential structure that contains four or fewer dwelling units. Projects that involve two or more residential structures are not exempt. Two or more residential structures being demolished as part of an urban or rural renewal or an unsafe building abatement program are not exempt, regardless of their proximity to each other. Projects that involve demolition of two or more mobile homes are not exempt. If the structure has been used for any purpose other than residential, such as being converted from residential to commercial use or converted from commercial to residential use, it is not exempt. Any residential structure used in fire training exercises is not exempt.
Should a regulated structure be demolished by a catastrophic event, such as a tornado or accidental fire, the department’s Air Pollution Control Program should be contacted for guidance.
Prior to demolition or renovation activities, regulated structures or those areas that will be subject to demolition or renovation activities must be thoroughly inspected by a Missouri certified asbestos inspector to determine if any asbestos-containing materials are present. The inspector should identify all potential asbestos-containing (suspect) materials that may be disturbed by the demolition or renovation activity. Samples of the suspect materials should be collected and submitted for laboratory analysis to determine if they contain asbestos. The inspector should generate a report of his or her findings from the inspection. The report should identify all suspect materials present, and indicate the amount, location, category and condition of the suspect materials. The report should also include a copy of the analytical results and chain of custody for all samples collected.
If a regulated structure is structurally unsound, it may not be possible to thoroughly inspect the entire structure. An inspection should be performed in all areas of the structure where it is safe to do so. The final inspection report should clearly indicate what areas, if any, were not inspected. Areas of the building that were not inspected will require special handling during demolition.
A list of Missouri certified asbestos inspectors is available on the department’s website at www.dnr.mo.gov/env/apcp/asbestos.htm.
Categories of Asbestos-Containing Materials
There are three categories of asbestos-containing materials that may be identified by an inspector.
- Friable asbestos-containing material - Any material containing more than one percent
asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand
pressure. Examples include sprayed or troweled-on materials such as acoustical ceiling
spray or boiler insulation, paper pipe insulation and drop-in ceiling tile.
• Category I nonfriable asbestos-containing material - Asbestos-containing packings, gaskets, *resilient floor covering and asphalt roofing products containing more than one percent asbestos. *(Any asbestos-containing vapor barrier on resilient floor coverings such as sheet vinyl or tile is considered friable asbestos).
• Category II nonfriable asbestos-containing material - Any nonfriable material, other than Category I materials, containing more than one percent asbestos. Examples of Category II materials include asbestos cement wall or roof shingles and cement pipe.
Depending on the type or category of the asbestos-containing materials identified from the inspection and the forces that will eventually act upon them during demolition and renovation, the materials may or may not be regulated by the department’s asbestos requirements. To determine the applicability of the department’s asbestos requirements, you must determine if the asbestos from your project will meet the definition of regulated asbestos-containing material, or RACM.
RACM includes friable asbestos-containing materials; Category I nonfriable materials that have
become or will become friable, or have been subject to sanding, grinding, cutting, burning, or
abrading; or Category II nonfriable materials that have a high probability of becoming, or have
become, crumbled, pulverized or reduced to powder by the work practices used during the
course of demolition or renovation.
Requirements for Abatement of Regulated Asbestos-Containing Material
If the asbestos inspection determines 160 square feet, 260 linear feet, 35 cubic feet (threshold quantities), or more of RACM will be impacted by demolition or renovation activities, all of the RACM must be removed by a Missouri registered asbestos abatement contractor.
Abatement contractors are trained in the proper procedures for safely removing and disposing of asbestos-containing material and may only employ workers trained and subsequently, certified by the department to participate on a regulated project. A list of Missouri registered asbestos abatement contractors is available on the department’s website at www.dnr.mo.gov/env/apcp/asbestos.htm.
If a building is structurally unsound and unsafe to enter, there may be provisions that would allow the building to be demolished without being inspected or having the RACM removed. In this event contact the Air Pollution Control Program.
Requirements for Abatement of Nonfriable Asbestos-Containing Materials
Most nonfriable materials are not considered RACM unless they are in poor condition or are rendered into RACM by the work practices during demolition or renovation. Category I nonfriable materials can generally be left in place during demolition activities provided the method of demolition will not make the material into RACM. However, for certain types of Category I materials, such as floor tile and linoleum, the department generally recommends removal prior to demolition because these materials could easily be rendered into RACM during the demolition process. Also, leaving these materials in place may increase the amount of material considered as asbestos waste and the cost of disposal. If Category I ACM is left in place, work practices must be implemented to ensure the material is not made into RACM 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 involved.
If threshold quantities of Category II materials will be impacted, then they must be removed prior to demolition or renovation activities. This removal must be performed in a manner that does not render the material into RACM. If the material is crumbled, pulverized or reduced to powder during the demolition or removal process, the material may become subject to regulation depending on the quantity involved.
The Occupational Safety and Health Administration, or OSHA, has specific work practice standards for friable and nonfriable Category I and Category II asbestos-containing materials. While the removal of nonfriable materials may not be regulated by the department, the material can still pose a safety risk if handled improperly. For any project involving asbestos, whether regulated by the department or not, the use of trained asbestos professionals that are familiar with OSHA standards should be considered for any work involving asbestos.
There are two types of notifications required by the department in regard to demolition and renovation projects, asbestos abatement project notification and demolition project notification. Asbestos abatement project notifications must be submitted to the department at least 10 working days prior to the start of a regulated asbestos abatement project. A copy of the asbestos inspection report and laboratory analytical results must accompany the notification. The notification period allows the department time to inspect the project and ensure it is being performed in compliance with all of the applicable requirements. A $200 review fee is required for each notification of an asbestos abatement project.
Alternate notification provisions may apply in emergency situations. In this event contact the
Air Pollution Control Program.
The second type of notification is demolition notification. Demolition notifications must be provided to the department at least 10 working days prior to the demolition of any regulated structure. A $100 review fee is required for each demolition notification.
This notice is required even if there is no asbestos identified in the structure being demolished. This notification period provides the department the opportunity to inspect the structure prior to demolition to ensure all asbestos issues have been properly addressed. A copy of the asbestos inspection report and laboratory analytical results must accompany this notification. In the event a structure is in danger of imminent collapse and has been ordered demolished by a state or local government agency, the department can waive the 10 working day notification period. In this case, notice should be provided as early as possible before, but no later than the following working day. A copy of the government order must also be included with the notification.
It is the obligation of the owner and any contractors involved to ensure these notifications are provided to the department. Failure to submit the notification is a violation of the department’s requirements. The department will issue a notice of receipt letter for all asbestos abatement and demolition project notifications. The notice of receipt letter will list any deficiencies in the notification of abatement or demolition.
Copies of the required notification forms are available on the department’s website at www.dnr.mo.gov/env/apcp/asbestos.htm.
Asbestos Waste Disposal Requirements
Asbestos waste from regulated projects involving threshold quantities of RACM must be handled in strict accordance with the department’s requirements for asbestos waste disposal. Wastes from these projects must be transferred to an approved sanitary landfill or transfer station by registered asbestos abatement contractors, who are trained in the provisions for proper waste disposal.
Non-friable asbestos-containing materials that are not made into RACM are not regulated by the department’s asbestos requirements. However, this material is 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 for information on how the material should be packaged and delivered to their facility for disposal.
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:
In Missouri, there are two local agencies that have an agreement with the department to enforce Missouri’s asbestos requirements as well as local ordinances. These local agencies are:
Two additional local agencies do not enforce Missouri’s asbestos requirements but may have local ordinances concerning asbestos which they enforce:
|St. Louis (city)||St. Louis Division of Air Pollution Control
Air Quality Program
|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
Other Department Offices
Kansas City Regional Office
500 NE Colbern Road
Lee's Summit, MO 64086-4710
Northeast Regional Office
1709 Prospect Dr.
Macon, MO 63552-2602
St. Louis Regional Office
7545 S. Lindbergh, Suite 210
St. Louis, MO 63125
Southeast Regional Office
2155 N. Westwood Blvd.
Poplar Bluff, MO 63901
Southwest Regional Office
2040 W. Woodland
Springfield, MO 65807-5912
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.