Demolition & Renovation

Demolition & Renovation

The National Emission Standards for Hazardous Air Pollutants (NESHAP) requires that a thorough inspection for asbestos must be conducted before any regulated facility is demolished or renovated. Inspections must include the collection and microscopic analysis of samples of all materials that might contain asbestos. These inspections must be conducted by a Cal-OSHA Certified Asbestos Consultant (CAC). 

Regulated Facilities

Facilities are generally defined as any man-made structure and most are subject to the NESHAP requirements unless exempted or excluded under specific circumstances. The NESHAP specifies facilities to include institutional, commercial, public, industrial or residential structures, installations, or buildings.

This regulation applies to all facilities, irrespective of when the structure was built.

Regulated Asbestos Containing Material (RACM)

Per the NESHAP, Regulated Asbestos Containing Material(RACM) is subject to the notification and abatement requirements prior to the commencement of regulated Demolition or Renovation projects.

This includes:

  • Friable asbestos-containing material (ACM), which is any material containing more than 1 percent asbestos, as determined by Polarized Light Microscopy (PLM) testing, which, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.
  • Category I Nonfriable ACM that is in poor condition and "has become friable" or "that has, or will be subjected to sanding, grinding, cutting, or abrading." (Category I Nonfriable ACM means "asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1 percent asbestos as determined by PLM testing that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.")
  • Category II Nonfriable ACM that has a high probability of becoming, or has become, crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation. (Category II Nonfriable ACM is "any asbestos-containing material, excluding Category I ACM, containing more than 1 percent asbestos as determined by PLM testing, that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.")