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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.

Requesting Clarification

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.

Conclusion

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.

For more information, contact PHASE Associates at 973-597-0750 or www.phaseassociate.com. Our certified asbestos consultants have extensive experience providing turnkey asbestos services to a wide range of industries and companies in the private, public and academic sectors.

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Our Google Reviews

There was a team of people at E.H.C. that worked with dedication and care to make our home safe and healthy. Elio, Barb and Louis all played an important part in the scope of work in our home. I am thankful for their work, support and effort.
Jamie Sentz
Jamie Sentz
19:30 06 Jun 24
Elio was wonderful to work with, he returned my calls in a timely manner and was quick and efficient with his quote.Alex and Ryder were punctual, polite and professional. They communicated updates to me throughout the process and explain the next steps. They respected my home and did an excellent job cleaning up after themselves when they were finished. I would absolutly do business with EHC again in the future if the need arises.
Amber Bunting
Amber Bunting
14:02 29 Mar 24
Working with Alex on a project in Hershey. Alex goes the extra mile to make sure everything is done by the book. Very important in this field
Mark & Melissa Cabanas
Mark & Melissa Cabanas
18:31 04 Jan 24
Louis and his crew were professional, personable, and efficient! Great job!
Brandon Monaco
Brandon Monaco
19:21 20 Nov 23
The crew did a great job in removing the asbestos material. Pedro Aluane was great to work with, and he went the extra mile giving me a hand at end of day in installing a tarp over the work area in case it rained over night. Thanks
Ed Patches
Ed Patches
13:46 13 Nov 23
EHC remove the asbestos shingles from this building. Tall Shawn the foreman was great to work with, he communicated and did a good job in managing the project
Edwin Patches
Edwin Patches
13:39 13 Nov 23
Elio was responsive, the admin staff was communicative, Alex and the on-site folks were tidy and professional. Not inexpensive, but that's the nature of their business I suppose. Asbestos abatement isn't a DIY gig.
Shelby LaMar
Shelby LaMar
11:40 03 Nov 23
Alex Henriquez was the project manager for our project. We had some moisture coming in to the house from outside from an old AC unit. He took every precaution to help with removing and stabilizing the lead paint. Alex was also incredibly knowledgeable and was able to answer every question so I could understand exactly what caused the issue what they did and what needed to be done to prevent it in the future. Amazing job.
justin creal
justin creal
22:00 01 Nov 23
Can’t begin to express how great the service was from EHC. I had a wall torn out by a contractor who didn’t test for asbestos, potentially putting my home at risk. EHC came out the very next morning to test my wall and samples, and even provided a rush service making sure I had results the day after. Both the technician (apologies for a bad memory with names), and Colleen were so helpful and were able to set everyone’s minds at ease. I expected to pay a lot for the service, but it was incredibly affordable. Can’t say enough about how professional and helpful this company is. Thank you for caring about customers and proving incredible service!
Austin Good
Austin Good
19:10 20 Oct 23
Alex and his team were extremely professional. My experience with this company as a whole has been very positive. They made quick work of the asbestos insulated pipes and 100 year old boiler in my basement. My family and I are so relieved and thankful to have that stuff out of our home.
Taylor Dietrich
Taylor Dietrich
23:13 13 Oct 23
Would highly recommend ! Elio came to explain and educate on the importance of having our ducts cleaned, which made the decision to go with EHC very easy.Professional and efficient.
Klay Lee
Klay Lee
18:45 12 Oct 23
I had a mold issue in my basement and called EHC for assistance and I couldn't be more pleased with the service.From the beginning when Elio came out it was clear that he was exceptionally knowledgeable and friendly. His expertise was evident from the start, and he took the time to explain everything clearly. His approachability helped make the process less stressful.When it was time for the job to be done, Luis and the team did an outstanding job. They took the time to address any concerns and questions, ensuring that I was comfortable with every step of the process. I was also impressed by their efficiency.I wholeheartedly recommend the team from EHC for any mold remediation needs. Their professionalism, expertise, & friendliness are truly top notch.
Carlos Devers
Carlos Devers
15:44 05 Oct 23
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