Asbestos Requirements for Demolition and Renovation Projects in Schools
|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.
All schools are considered to be regulated facilities subject to the EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Asbestos Hazard Emergency Response Act (AHERA). Asbestos contained in building materials is considered to be a hazardous air pollutant. As such, the asbestos NESHAP applies to the disturbance and handling of asbestos-containing materials located in schools and school-owned facilities. These are considered to be regulated facilities.
The state of Missouri is delegated by the EPA to administer the asbestos NESHAP. Failure to comply with the requirements contained in the asbestos NESHAP is a violation of state and federal laws and regulations and can lead to the issuance of state or federal notices of violations and the imposition of monetary penalties. EPA is responsible for implementing the requirements of AHERA.
State NESHAP Requirements
Prior to demolition or renovation activities, regulated facilities or those areas that will be impacted by 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 must be collected and submitted for laboratory analysis to determine if they contain asbestos. The inspector should generate a report of 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.
A list of Missouri certified asbestos inspectors is available on the department’s website at dnr.mo.gov/env/apcp/asbestos/inspectors/index.php.
If the asbestos inspection determines that 160 square feet, 260 linear feet, 35 cubic feet (threshold quantities), or more of regulated asbestos containing material will be impacted by demolition or renovation activities, all of the regulated asbestos containing material 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. Prior to regulated removal of regulated asbestos containing material, Missouri regulations require that an Asbestos Project Notification be submitted to the department’s Air Pollution Control Program a minimum of 10 working days (typically two calendar weeks) prior to initiating the project. A copy of the asbestos inspection report and laboratory analytical results must accompany this notification.
A list of Missouri registered asbestos abatement contractors and the project notification form is available on the department’s website at dnr.mo.gov/env/apcp/asbestos/contractors/index.php.
Under the asbestos NESHAP, demolition is defined as “the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations …..”
Demolition notifications must be provided to the department at least 10 working days prior to the demolition of any regulated structure or portion thereof. A demolition notice is required even if there is no asbestos identified in the structure being demolished. A copy of the asbestos inspection report and laboratory analytical results must accompany this notification.
The demolition notification form is available on the department’s website at dnr.mo.gov/forms/780-1923-f.pdf.
Federal Asbestos Hazard Emergency Response Act Requirements
Public and non-profit private schools have distinct regulatory requirements to protect school children and school employees from asbestos exposure. Non-profit schools include charter schools and schools affiliated with religious institutions. The Asbestos Hazard Emergency Response Act (AHERA) and regulations require schools to:
- Inspect buildings for asbestos-containing building material.
- Prepare asbestos management plans and take action to prevent or reduce asbestos exposure.
The AHERA is a distinct body of regulation separate from the asbestos NESHAP. However, the provisions of each apply and must be complied with by schools in Missouri. The state of Missouri does not administer AHERA requirements. Any questions regarding AHERA requirements in Missouri should be addressed to the EPA’s region 7.
Environmental Protection Agency, Region 7
11201 Renner Blvd.
Lenexa, KS 66219
913-551-7122 or 800-223-0425
It is important to be aware that AHERA asbestos inspections seldom meet the NESHAP requirement to conduct a thorough asbestos inspection prior to renovation or demolition activity.
Asbestos Contact Information
For more information on the department’s asbestos requirements, school administrators may contact the department’s Air Pollution Control Program or one of the department’s other offices:
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
Prior to performing a project in one of these jurisdictions, you should contact the appropriate agency to determine if any additional requirements apply.
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:
Kansas City Health Department
St. Louis County
St. Louis County Health Department
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
Springfield-Greene County Health Department of Environmental Services
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 your appropriate local agency.
Asbestos - Related Forms
- Asbestos Inspection Report - Demolition/Renovation, Form--MO 780-2130
- Asbestos NESHAP Notification of Demolition and Renovation, Form--MO 780-1923 and Instructions
- Asbestos NESHAP Notification of Demolition and Renovation Amendment, Form--MO 780-1986
- Asbestos Notification Amendment, Form--MO 780-1556
- Asbestos Post-Notification, Form--MO 780-1225
- Asbestos Project Notification, Form--MO 780-1226
- Asbestos: Inspection Report Requirements, Fact Sheet--PUB2349
- Asbestos Requirements for Demolition and Renovation Projects, Fact Sheet--PUB2157
- Asbestos: What is it and why is it a concern?, Fact Sheet--PUB2077
- Environmental Regulations for Demolition Project Checklist, Fact Sheet--PUB2374
- Guide to Our Air Pollution Enforcement Process, Fact Sheet--PUB2059
- How to Handle Asbestos-Containing Debris, Fact Sheet--PUB2121
- Management of Nonfriable Asbestos-Containing Materials, Fact Sheet--PUB2156
Asbestos - Regulations
Missouri State Regulations 10 CSR 10-6.241 Asbestos Projects-Registration, Notification and Performance Requirements, and 10 CSR 10-6.250 Asbestos Abatement Projects - Certification, Accreditation and Business Exemption Requirements