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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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EHC Associates

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I cannot recommend EHC associates enough ! They came and remediated mold out of my attic and basement , and removed asbestos coated flooring . Elio was very knowledgeable about our situation regarding the mold and made the whole process as easy and cost effective as possible . Tomas and his crew were fantastic ! They were extremely professional , kind , and thorough throughout the whole remediation process . Tomas walked my wife and I through each step of the process each day and kept us very informed. We would HIGHLY recommend EHC associates to anyone who needs remediation done in their home !

Tom Beggs

15:13 05 Jul 26

I recently hired E.H.C. to remove hazardous material from the attic in my rental property. From start to finish the team was professional and completed the project in a timely manner. The project Manager, Alex H. was exceptional. I had concerns about the material that was being removed and he took the time to explain the process to me and answered all of my questions. I would highly recommend E.H.C. for any removal of hazardous material from any property you own.

Michele Hinkle-Evans

14:00 30 Jun 26

I contacted EHC to have asbestos removed from my attic. From start to finish, the process has been wonderful and I highly recommend this company to anyone needing hazards removed from their homes!!!My house was built in 1890 and spent 25 years being neglected until I purchased it (if you could imagine, it’s been a nightmare). One of the bigger projects to face was the attic that was filled with junk from the past and loads of asbestos from the original roof that I had replaced.Elio, their senior estimator, came out to view the attic very quickly after I called with my concerns. He was incredibly nice, professional, and educated us on what the process of abatement would look like.We received a very fair estimate cost in a timely manner, and scheduling/communication with Barb was very efficient and helpful!It took two days for Alex, Miguel, and the rest of their team to get my attic in a safe condition. Miguel & his guys removed probably 100 or more bags of contaminated items that were left in the space, and were very thorough with keeping the rest of my house free from debris. They communicated with me as they worked through their process, and once everything was done and we did the final walkthrough, they made sure everything was safe and that I was happy with their job. Everyone was so kind, respectful, hard-working, and professional!They took samples after they were finished to confirm that my attic was 100% free of asbestos. I’m sure this is standard practice, but I really appreciate them taking that step to assure that my home is safe!My project was not an easy one, and they truly went above and beyond to do a great job. I cannot thank them enough.I will definitely be using EHC in the future if I come across any needs in my home again!!

sharon miller

19:48 19 Jun 26

We are halfway through a large commercial asbestos abatement job and EHC has been great to work with. They have kept a tight schedule and their foreman Alex is the man.In phase 2 another trade sheared a sprinkler head off in another work area and Alex jumped right in with my team to contain and redirect the water within minutes. He has been back in phase 3 and makes all our meetings, puts safety first, and is always professional.

Wyatt McMartin

12:44 16 May 26

EHC did a ton of work at my home, it spanned several days, over a few weeks. Each time they arrived, Pedro and his team were extremely courteous, professional, safe, and CARING. We are incredibly happy with the work they did, and were consistently impressed how they balanced being friendly and helpful, while also not interrupting our daily life(i'm a stay at home mom with a very active kiddo and pets). We always felt safe with Pedro's team, we always felt cared for, and have already recommended EHC to several neighbors and friends. Thank you!

Melinda LaBeau

15:32 17 Mar 26

My company Emulous Tech Solutions recently had the privilege of working with EHC on a technical project. Their staff was knowledgable, helpful, and responsive. I greatly appreciate their working with us to complete the project. I would highly recommend for service. Thank you!!

Mike C

20:46 25 Feb 26

I had a nightmare experience with mold that was hidden throughout a home I purchased. Elio and his team performed an extensive inspection and remediation, and worked with me on scheduling to reduce my temporary dislocation expenses as much as possible. I asked questions almost every day for weeks, and all were answered patiently, and the team pivoted when necessary. Months later, I am still reaching out to Elio with questions about best practices for bringing items into my home, and he answers within minutes. I have recommended Elio to several friends, and one already has reached out.

Michele Burkholder

16:06 17 Feb 26

We want to thank the EHC team. We are so pleased with the final result of the removal of asbestos tiles and adhesive from our basement floor. Ernesto and his team were wonderful to work with. They were very professional and informative. When the job was completed, our basement floor looked like brand new concrete. EHC is definitely a first-class company! Thanks again! Best, Craig

Charlene Urban

22:52 12 Feb 26

Absolutely amazing staff and the job was done perfectly. Thank you to Barb, Connie, and the rest of the team! We highly recommend!

Elise Sipe

15:15 11 Feb 26

Just finished up an abatement for us, Alex and his crew were very efficient and knowledgeable in their craft. Great outfit to work with. Thanks Alex.

Chris Beck

23:50 21 Jan 26

We were very pleased with the whole process of having our home remediated from the ease of scheduling, the in dept inspection and the team that did our project. I highly recommend EHC!

Kelly Masteller

18:10 13 Dec 25

Alex and the EHC team were professional, prompt, and organized throughout their work on the Lincoln University Gymnasium Renovation project. Communication was clear, scheduling was efficient, and their crew maintained a safe and well-coordinated jobsite. They demonstrated strong attention to detail and delivered exactly as promised. I’d highly recommend EHC and Alex Henriquez for any future construction projects.

Abdramane traore

18:49 25 Oct 25

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