Asbestos exposure can lead to serious health problems, so it is important for demolition and renovation contractors to be aware of and in compliance with Ohio EPA’s asbestos requirements. This article provides an overview of some of the key asbestos requirements that you need to be aware of as a contractor.
Ohio EPA’s asbestos requirements apply to demolition and renovation activities that are conducted at a facility. A facility is any institutional, commercial, public or industrial structure, or any operation involving the demolition of multiple residential structures within a scheduled period of time. In addition, a residential structure where a business operated remains subject to Ohio EPA’s asbestos requirements. Activities at non-commercial residential buildings that have four or fewer dwellings are not subject to Ohio EPA’s asbestos requirements, unless the units are part of a larger installation or project.
Depending on the nature of the demolition or renovation project, Ohio EPA’s asbestos rules require you to:
- have an asbestos survey completed by a licensed asbestos inspector to determine the presence of asbestos;
- have a licensed asbestos abatement professional remove asbestos prior to demolition/renovation;
- submit a notification of demolition activity to Ohio EPA or your local air agency (a notification for renovation activities may also be required);
- use specific work practices to control the generation of asbestos-containing dust and debris; and
- ensure proper disposal of asbestos-containing material.
Failure to comply with the regulations can lead to violations and a penalty for the owners of the facility and the demolition or renovation contractor involved in the project.
A notification is a written notice of the intent to renovate or demolish. It is important for contractors to know that every demolition or renovation project at a facility requires an asbestos survey. In addition, every demolition project at a facility requires an asbestos survey and notification, regardless of whether asbestos is present. The notification requirement is different for facility renovation activities and is dependent upon the amount of regulated asbestos-containing material (RACM) at the site. For renovations, a notification must be submitted if the amount of RACM disturbed exceeds 260 linear feet of pipe insulation, 160 square feet of other materials or 35 cubic feet of building debris.
Ohio EPA has developed one notification form that is used for either demolition or renovation activities. The notification must be sent by mail (postmarked) or hand-delivered at least 10 working days (Monday-Friday including holidays) before demolition or renovation can begin. An asbestos inspection of the facility must be performed by a licensed Ohio Asbestos Hazard Evaluation Specialist in order for a written notification to be considered complete.
The notification form goes to either the Ohio EPA district office or local air pollution control office in your area. Phone and fax notifications are not acceptable for original notification. If information in the original notification changes, you may be required to inform the local office of these changes through a revised notification. Usually the asbestos abatement contractor submits the notification, however, the owner of the building or the demolition/renovation contractor can also submit the notification. Regardless who submits the notification, all parties can be held responsible if no notification or an inadequate notification is submitted.
For more information regarding Ohio EPA’s asbestos program, please visit epa.ohio.gov/asbestos or call our hotline at (800) 329-7518 for confidential assistance.