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Idaho Snow: Debris from Collapsed Buildings

What to know about EPA asbestos requirements before demolishing a building


Questions?

Is my building debris subject to EPA's asbestos regulations (NESHAP)?

  • If a building has been completely knocked to the ground and is wrecked as a result of a natural disaster such as a winter storm, then it is not considered a "demolition." Therefore, EPA’s asbestos National Emission Standards for Hazardous Air Pollutant (NESHAP) regulations do not apply and the debris can be hauled to the dump without being subject to the asbestos NESHAP program (40 Code of Federal Regulations Part 61, Subpart M). People handling the debris still need to protect themselves from hazards, for example, by keeping debris wet to avoid visible emissions of dust and ascertaining whether the building contains other environmental hazards.
  • Anyone hauling fallen building debris to the landfill which has not been surveyed for asbestos (for example, from a building collapsed from the snow) should call ahead to the landfill and make sure they will accept the waste. The landfill will want to anticipate what’s coming and may have additional local requirements.
  • Agricultural sheds are commercial buildings, and if they are still standing (partially caved in) the asbestos NESHAP requires an asbestos survey prior to demolition unless the buildings are structurally unsound and in danger of imminent collapse (structurally unsound). 

What if my building needs to be demolished?

  • Any building may contain asbestos. Inhalation exposure can occur when asbestos‑containing material is disturbed and fibers are released.
  • To the extent they can be safely accessed, buildings must be surveyed for asbestos. If structurally unsound, building owners need a letter from the city or State building department declaring it so, and ordering the demolition. An “ordered demolition” can proceed immediately and does not require abatement of asbestos.
  • In addition to an asbestos survey, the NESHAP also requires that, during any demolition or abatement of a commercial building that contains regulated asbestos containing material, a supervisor is on site who has been trained on how to comply with the asbestos NESHAP.
  • If regulated asbestos containing material is found on or in structurally sound buildings, it needs to be abated according to the regulatory requirements of the asbestos NESHAP regulation.
  • If regulated asbestos containing material is found on or in structurally unsound buildings, then follow the procedures in the asbestos NESHAP rule by keeping the debris wet.
  • In all cases, the asbestos waste must be hauled to an approved asbestos landfill. The waste hauler must provide a waste shipment record to the landfill manager, describing the contents of the asbestos waste.
  • Burning demolition debris with any asbestos is strictly prohibited by the asbestos NESHAP regulations. It can cause asbestos fibers and other hazardous materials to spread wide and far and impact the public.
  • Some asbestos-containing materials such as roofing shingles and flooring can be left in place during demolition if they are in good condition, because they are not expected to release asbestos fibers. These are referred to as “Category I nonfriable asbestos” materials. Just make sure the Category I materials are in good condition and not crushed, broken or crumbled into pieces.

This information only relates to requirements for asbestos. Other federal, state, and local environmental regulations may also apply.


EPA notification of demolition and renovation

Anyone demolishing a building will need to send EPA Region 10 a notification even if there is no asbestos identified. This informs EPA of the work and gives the agency a chance to inspect the project.

Notification forms should be mailed to:

Asbestos NESHAP Coordinator
U.S. EPA, Region 10 (OCE-101)
1200 Sixth Avenue, Suite 900
Seattle, WA 98101


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