Who Should Perform an Asbestos Survey Before Renovation?
Who Should Perform an Asbestos Survey Before Renovation?
Who Should Perform an Asbestos Survey Before Renovation?
A renovation schedule can unravel quickly when asbestos questions are left until demolition day. Contractors arrive, suspect material is uncovered and nobody can confirm whether it was inspected or sampled. Work stops while the owner searches for records that should have been assembled before bids were accepted.
A proper asbestos survey is not a casual walk through. It identifies the materials that may be affected, documents sampling decisions and gives the owner and contractor information needed to plan the project lawfully.
Covered Projects Need a Thorough Inspection
The federal asbestos NESHAP requires a thorough inspection before covered demolition or renovation work begins. For commercial, institutional and industrial buildings, the inspection requirement applies to the area where the operation will occur. Demolition notification requirements can apply even when no asbestos is found.
Arizona guidance is more direct. ADEQ states that renovation or demolition at a regulated facility must first be inspected by an AHERA certified Building Inspector. The survey and laboratory results should remain available with the project records.
Waiting until construction starts creates more than a paperwork problem. When suspect material is discovered after ceilings, walls or flooring have been opened, the original scope, schedule and controls may no longer be suitable.
The Survey Must Match the Planned Work
A survey prepared for a roofing project may not cover flooring, pipe insulation or wall systems involved in a later renovation. Likewise, an old building report may describe common areas but not the individual suite being altered.
Give the inspector current drawings and a clear description of the planned disturbance. The inspector needs to know which rooms, systems and materials are involved. A targeted renovation survey can then focus on the affected area while still meeting applicable requirements.
Demolition surveys usually need broader access because materials hidden behind finishes may be disturbed when the structure comes down. EPA requires the affected facility or affected portion to be thoroughly inspected before covered work begins.
An AHERA Building Inspector Has Specific Training
EPA’s Model Accreditation Plan identifies the Building Inspector as one of the required asbestos disciplines. Inspector accreditation is used for asbestos inspections in schools and public or commercial buildings covered by the plan.
The Asbestos Institute’s twenty four hour Building Inspector Initial course covers suspect material identification, sampling systems, report preparation, protective equipment and applicable regulations. It is intended for people inspecting schools and public, commercial or industrial buildings.
Completing a training course is only part of the compliance picture. Some states issue separate licences or accreditations, and local agencies may add their own requirements. The person arranging the survey should verify that the inspector is authorised for the project location.
Laboratory Results Are Only Part of the Report
A list of sample results does not by itself explain the building. A useful survey identifies the material, records where it was found, describes its condition and connects the findings to the planned work.
Sampling must also be representative. One negative result from a convenient location does not automatically clear similar looking material throughout a building. The inspector should document homogeneous areas, sample locations and any limitations that prevented access. EPA’s AHERA guidance requires accredited inspectors to collect representative bulk samples from suspect homogeneous areas under the applicable inspection rules.
Owners should keep the complete report, laboratory documentation and later updates together. Contractors need the relevant findings before they price or disturb the work area.
Leave Time for Notification and Project Planning
In Arizona, notification timing depends on the project type, location and quantity of regulated asbestos containing material. ADEQ notes a ten business day notification period for covered work, with Maricopa, Pima and Pinal counties handling notifications within their jurisdictions.
The practical lesson is simple. Commission the survey early enough to review results, obtain bids, make notifications and arrange abatement when required. An inspection completed the day before demolition offers very little room to correct the plan.
Train for Professional Asbestos Inspection Work
The Asbestos Institute offers AHERA Building Inspector initial and refresher courses, along with training for workers, supervisors, management planners and project designers. To discuss inspector training, course formats or state acceptance, call 602 864 6564 and speak with the training team before registering.
Live References
EPA Overview of Asbestos NESHAP Requirements
EPA Asbestos Materials and Demolition Guidance
Arizona Department of Environmental Quality Asbestos Guidance