Before a facility or a portion of a facility is renovated or demolished, the owner/operator of the facility or renovation or demolition activity must ensure that the facility or portion of the facility being renovated or demolished has been thoroughly inspected for the presence of asbestos. The inspection must be performed by a person who has been trained and licensed as an Asbestos Building Inspector or management planner in accordance with State training and licensing requirements.
The inspector must identify, quantify, and assess the condition of all suspect asbestos-containing material, either friable or non-friable, on interior and exterior portions of the facility. The inspector must also comply with the procedures specified in Regulation 61-86.1 VI D. In addition, the inspector is required to prepare a written report detailing the findings of the inspection. At a minimum, the report must include information required in Regulation 61-86.1 VI C. A legible copy of the building inspection report must be provided to the Department prior to each demolition, and upon request for renovations. (Note: " BUILDING INSPECTIONS "can be consulted for a detailed explanation of the aforementioned sampling and reporting protocols.)
A building inspection will only be acceptable if performed within three years prior to the demolition or renovation. If an inspection report is more than three years old, then it must be confirmed and verified by a licensed Asbestos Building Inspector or Management Planner.
Building Inspection Report Directions (pdf)
As required by the National Emission Standard for Hazardous Air Pollutants (NESHAP) and Regulation 61-86.1, an owner/operator shall ensure that a building inspection, to detect the presence of asbestos-containing material (ACM), has been performed prior to any renovation or demolition activity at a regulated facility.
Under Regulation 61-86.1, Section VI.A.6., an inspection cannot have been performed more than three years prior to a renovation or demolition activity. If more than three years have elapsed since the most recent inspection, the previous inspection shall be confirmed and verified by a licensed building inspector and/or management planner.
Regulation 61-86.1 requires that all inspections be performed by persons trained and licensed as either a building inspector and/or management planner. In order to be licensed in these disciplines, persons must have successfully completed a DHEC approved initial training course specific to inspecting for ACM in a building and/or a course specific to management planning for ACM in a building. Persons must also have taken and passed an examination at the end of the course with a score of 70 percent or above.
In performing inspections, Regulation 61-86.1 requires that a building inspector and/or management planner comply with the requirements of Section VI, Asbestos Building Inspection Requirements. An inspection shall include samples from suspect friable and non-friable ACM on interior and exterior portions of a facility or its facility components.
In performing inspections, Regulation 61-86.1 requires that a building inspector and/or management planner follow specific sampling procedures. According to Section IV.B.3.a of the regulation, a building inspector and/or management planner shall comply with the procedures specified in 40 CFR 763.86 in determining sampling locations and the number of representative samples to be collected. An inspection shall include samples from suspect friable and non-friable ACM on interior and exterior portions of a facility or its facility components.
Under 40 CFR Part 763.86, suspect ACM are divided into three categories: surfacing materials, thermal system insulation (commonly referred to as TSI), and miscellaneous materials. Regulation 61-86.1, Section VI contains sampling procedures specific to each category of material.
Surfacing material includes, but is not limited to, joint compound, plaster, and painted, troweled on, or spray-applied textured material. To remain in compliance with Regulation 61-86.1, surfacing materials on exterior and interior portions of a facility shall be sampled according to procedures outlined in Regulation 61-86.1, Section VI.D.1. (a)-(c):
- A licensed asbestos inspector shall collect, in a statistically random manner, a minimum of three bulk samples from each homogeneous area of any surfacing that is not assumed to be ACM, and shall collect the samples as follows:
- At least three bulk samples shall be collected from each homogeneous area that is 1,000 or fewer square feet (sf) or linear feet (Lf) in size.
- At least five bulk samples shall be collected from each homogeneous area that is greater than 1,000 but fewer than or equal to 5,000 sf or Lf.
- At least seven bulk samples shall be collected from each homogeneous area that is greater than 5,000 sf or Lf.
Thermal System Insulation (TSI) is any material that is applied to pipes, fittings, boilers, breeching, tanks, ducts, or other facility components for the purpose of preventing heat loss or gain, water condensation, or for other purposes. Miscellaneous Material is any material that is not considered a surfacing material or thermal system insulation and includes, but is not limited to, flooring, roofing, mastics, gaskets, cementitious materials, caulkings, ceiling tiles, fire doors, wall boards, and flexible duct connections. To remain in compliance with Regulation 61-86.1, TSI and miscellaneous materials on exterior and interior portions of a facility shall be sampled in accordance with procedures outlined in Regulation 61-86.1, Section VI.D.2:
- A licensed asbestos inspector shall collect, in a statistically random manner, at least three bulk samples from each homogeneous area of TSI and any miscellaneous material that is not assumed to be ACM.
- In accordance with ASTM E2356, and any subsequent amendments and editions, negative results for non-friable organically bound material (NOB) shall be verified with at least one TEM analysis.
- NOBs include flooring, roofing, mastics, adhesives, caulks, and glazing.
- If an accredited inspector has determined the thermal system insulation to be fiberglass, foam glass, rubber, or other non-suspect material, then bulk samples are not required.
Regulation 61-86.1, Section VI.C requires that a building inspector and/or management planner prepare a written asbestos building inspection report to include the following:
A cover letter to the building owner or owner's representative that describes the purpose of the inspection; a general synopsis of the inspection and results; and the name, title, and signature of the inspector(s) and report writer, if different.
A detailed narrative of the physical description of the building or part of the building affected by the renovation or demolition operation that includes:
- The client's name, company, address, and telephone number, and the name and exact location of the facility inspected;
- the date the inspection was performed;
- the date the inspection report was written; and
- the printed name and telephone number of the inspector(s), and his or her affiliated company name, address, and telephone number.
An executive summary that details:
- The square footage of the building or part of the building affected by the renovation or demolition operation;
- The building materials used in the construction of the exterior, roof, interior, and basement or crawlspace of the building affected by the demolition or affected by the renovation materials operation;
- An estimated or exact quantity (square or linear feet) for all suspect materials whether sampled for or assumed to be asbestos that may be affected by the renovation or demolition operation;
- Also include a description of non-suspect materials excluding: glass, metals, kiln brick, cement, fiberglass, concrete, pressed wood, cinder block, and rubber.
For renovation and demolition operations, the inspector's determination that ACM is friable or non-friable.
Except when suspect ACM materials are assumed to be asbestos, include a complete, clear, legible copy of all laboratory bulk sample results.
Clear, legible drawings and/or photographs to clarify the scope of the renovation or demolition operation. Illustrate the exact location of each sample collected. For facilities that involve a trade secret or confidential component or an affected area process, a request for a variance may be submitted.
The printed name and signature of each accredited inspector who collected the samples, and a clear legible copy of his or her DHEC issued asbestos building inspector or management planner license.
- The type of suspect ACM (e.g., TSI, floor tile, mastic), total square or linear footage, and the total number of samples collected for each separate homogenous area affected by the renovation or demolition operation;
- The date of the inspection, type, condition, quantity, sample results, and exact location of ACM positively identified or assumed to be ACM in the part of the building affected by the renovation or demolition operation;
- A list of the homogeneous areas identified;
- Whether the material is accessible for the building or part of the building affected by the renovation or demolition operation; and (5) The material's potential for disturbance for the building or part of the building affected by the renovation or demolition operation.
Things to Note:
- At no time will negative assumptions about a suspect material's content be acceptable. There are only two acceptable options:
A homogenous area is considered not to contain ACM only if the results of all samples required to be collected from the area are one percent or less.
Bulk samples shall not be composited for analysis.
In a multi-unit building, each separate room in each part of the building or areas affected by the renovation or demolition operation shall be inspected to confirm and quantify ACM homogeneous areas for sampling purposes.
DHEC will not accept an asbestos building inspection or written report for any structure from an employee of an abatement company also involved in the removal of asbestos-containing materials from that structure, unless the licensed inspector is an employee of an entity regulated under Regulation 61-86.1, Section XX, Industrial Manufacturing and Electrical Generation Facilities.
An asbestos building inspector shall not participate in the analysis of the bulk samples he or she has collected.
Destructive sampling techniques shall be utilized.
Material Safety Data Sheets (MSDS), statements from the manufacturer, and architecture signoff will not be accepted as proof that a building product contains no asbestos, except in cases where the owner can verify the direct correlation of the building product to the MSDS, statements from the manufacturer, and/or architecture signoff documents. DHEC reserves the right to reject documentation that it deems unacceptable.
- Positive assumptions of suspect materials or
- Sampling of suspect materials per the procedures specified in 40 CFR 763.86