Asbestos Renovations and Demolition Operations
The San Diego Air Pollution Control District is the local agency
responsible for enforcing the rules and regulations for asbestos
removal and demolition operations.
Asbestos occurs naturally in the environment around the world,
including Central and Northern California. The term asbestos refers to
several varieties of mineral fibers that are mined and processed for
commercial uses around the world. Because asbestos fibers are
microscopic, lightweight, and are extremely resistant to heat and
chemicals, asbestos became a valued building material throughout the
1900s. It has been used extensively in insulation products and for
providing fire resistance to buildings. After the late 1970s, asbestos
became widely recognized as a serious health hazard.
District Rules that Apply to Asbestos Removal and Demolitions
The Asbestos National
Emission Standard for Hazardous Air Pollutants (NESHAP), as specified
under Rule 40, CFR 61, Subpart M applies to asbestos removal and
demolitions and is enforced locally by the San Diego Air Pollution
Control District, under authority, per Regulation XI,
M- Rule 361.145 & 361.150.
Other Local Regulatory Agencies
County of San Diego
Department of Environmental Health (DEH)http://www.sdcounty.ca.gov/deh/
CA State Regulatory Agencies
Department of Toxic
Substances Control (DTSC) http://www.dtsc.ca.gov
Occupational Safety and Health (Cal-OSHA) http://www.osha.gov/SLTC/asbestos/index.html
Licensing Board (CSLB)
Resources Board http://www.arb.ca.gov/enf/asbestos/asbestos.htm
Federal Regulatory Agencies
Protection Agency (EPA) http://www2.epa.gov/enforcement
Department of Labor
Department of Health
and Human Services (DHHS) http://www.hhs.gov/
Regulated Asbestos-Containing Material (RACM)
The term Regulated
Asbestos-Containing Material (RACM) refers to materials containing
more than one percent asbestos and asbestos that is either
friable (can be crumbled, pulverized, or reduced to powder by hand
pressure), or non-friable that have become or are likely to become
friable (airborne) through the use of tools, work practices, or the
forces expected to act on the materials in the course of demolition
or renovation operations.
A Facility or "Regulated Structure"
The term “Facility”
is referenced many times in District Rules 361.145 & 361.150
detailing which structures are regulated. As defined in District
Rule 361.145, a "facility" is:
commercial, public, industrial or residential structure,
installation or building
including condominiums, or individual dwelling units operated
as a residential cooperative,
excluding residential buildings having four or fewer dwelling
units under one roof, any ships, or any active or inactive waste
Any structure subject
to the Asbestos NESHAP continues to be regulated under the Asbestos
NESHAP even if the use or function of that structure changes.
Regulated structures include government buildings, residential
facilities, buildings demolished for fire training, and buildings
demolished for urban renewal projects.
Regulation of Residential Facilities
A regulated residential facility is any building, condominium, or
apartment that contains more than four dwelling units. A regulated
residential facility is also a group of buildings located on the same
property and managed by a common entity, even when there are fewer
than four dwelling units in each building.
Removal Practices at Condominiums and Apartments is a District compliance
advisory that highlights residential facilities. These requirements
also apply to other commercial, institutional, and industrial facilities.
Demolition vs. Renovation at a Facility
"Demolition" and "Renovation" are defined in District
Rule 361.141 and
differ from some building department definitions.
You demolish a facility when you remove or wreck any load-supporting
structural member of that facility or perform any related operations.
You also "demolish" a facility when you burn it.
You renovate a facility when you alter any part of that facility in
any other manner. Renovation includes stripping or removing asbestos
from the facility.
Questionnaire may be required prior to
applying for a building permit from your local agency.
Applicability of Asbestos Regulations During Renovation Projects
Asbestos NESHAP regulations must be followed for all facility
renovations with at least
260 linear feet (80 linear meters) of regulated asbestos-containing
materials (RACM) on pipes, or
160 square feet (15 square meters) of regulated asbestos-containing
materials on other facility components, or
35 cubic feet (one cubic meter) of facility components where the
amount of RACM previously removed from pipes and other facility
components could not be measured before stripping.
These amounts are known as the "threshold" amounts. If
smaller scale projects collectively add up to the amounts listed
above, the entire scope of work is subject to the notification and
work practice standards of the NESHAP.
Applicability of Asbestos Regulations During Demolition Projects
All facility demolitions require notification of the appropriate
regulatory agency, even if no asbestos is present at the site. All
demolitions and renovations are "subject" to the Asbestos
NESHAP insofar as owners and operators must conduct a survey to
determine if and how much asbestos is present at the site.
Notice of Intention Form for Asbestos Renovation or Demolition
Renovation or Demolition Notice
of Intention form is required for anyone who has control over the:
Demolition of a
facility (commercial structures and residential buildings having
more than four dwelling units). They are required to submit to the
District a ten working-day advance written notification, whether or
not any asbestos was identified in the pre-project survey.
facilities involving at least 160 square feet, 260 linear feet (for
pipes), or 35 cubic feet of RACM. They are required to submit to the
District a ten working-day advance written notification.
emergency demolitions or emergency renovations may be eligible for
expedited notification provisions provided they qualify by meeting
must be completed on approved forms with all required information,
and must be submitted with required fees.
should be included in the Notice
of Intention form.
Failure to do so could
result in the issuance of a
In San Diego County, notify the County of San Diego Air Pollution
Control District for demolition or renovation operations subject to
the Asbestos NESHAP by mailing or hand-delivering the notification
form to the District at 10124 Old Grove Rd, San Diego, CA 92131. The
notification must be postmarked or delivered at least ten working days
before demolition, asbestos stripping, removal work or any other
activity begins (such as site preparation that would break up,
dislodge or similarly disturb asbestos material).
Appropriate fees must be included with all submitted notifications
and revisions. The
notification fees for demolitions and asbestos renovations are listed
40, Section (f)(2). The
District also accepts American Express and Discover with a 2.2%
service fee. For those paying by credit card, notifications can be
faxed to (858) 586-2651.
the Frequently Asked Questions(FAQs) for
Asbestos Removal and Demolition Operation FAQ
This information is intended to assist contractors, builder owners
and/or their agents to understand the requirements of the
notifications and to prevent inadvertent violations and penalties.
- When Can I Begin My Asbestos Removal or Demolition Project?
You must start on the date stated on the notification. You do not need to wait for an inspector to start work you can start at any time on the date stated in the notification.
For Demolitions “starting” means commencing the removal of the load bearing structural member.
For Asbestos removal “starting” means removing or disturbing asbestos containing material.
- If I Cannot Start My Project on the Start Date What Should I Do?
If you cannot start on the date on the notification you must contact the District as soon as possible but no later than the original start date. We must receive your revision no later than the close of business at 5:00 p.m. You can send in a change in start date notification by fax 858-586-2650 or by email firstname.lastname@example.org., in person to our office at 10124 Old Grove Road. You can also mail your notification however we must receive it by the original start date. The fee to change the start date is $49, payable by cash, check or credit card (American Express or Discover only). A 2.2% service fee is charged for credit card transactions.
If you need to revise your revised start date(s) the same requirements stated above apply.
- When Can I End my Asbestos Removal or Demolition Project?
You can finish your project by the date stated in the notification. If you finish earlier than the date stated no further notification is required. If you do not finish by the end date stated in the notification you can submit a revision notification as soon as possible but no later than the original end date (or subsequent revised end dates) to us by mail, email, in person or fax (information noted above) with the new end date. A fee is not required for changing the end date on the notification.
- What Happens if My Notification “Expires”?
If your project is not complete and the end date has passed and you have not submitted a revision to the end date, you must submit a new notification which includes the 10 working day waiting period.
- What Should I Do To Avoid a Violation?
Start your project on time!
Send in Revision Notifications Promptly.
Follow All Required Work Practices and Removal, Demolition Standards.
- What Information Should I Keep on My Project Site?
Keep a copy of the notification and any revisions, asbestos survey, training certificates as applicable.
- Where Do I Send My Notifications?
All notifications must be accompanied by the appropriate fees in order to be accepted. You can mail your notification to 10124 Old Grove Road, San Diego CA 92131. If paying by credit card you can email your notification to email@example.com or by fax at 858-586-2651.
If you have any questions please contact the Compliance Division at 858-586-2650 and ask for the inspector on duty.
Asbestos for Workers
Asbestos for Homeowners
Asbestos for Contractors
For more information on facility descriptions/exemptions, please
contact the Compliance Disvision at (858) 586-2650 or firstname.lastname@example.org.
You can mail your completed notifications to:
Air Pollution Control District
10124 Old Grove Road
Diego, CA 92131
If paying by credit card (American Express or Discover) fax your
notification to 858-586-2651 or by email.