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A notification is a written notice of intent to renovate or demolish. Notifications must contain certain specified information, including but not limited to, the scheduled starting and completion date of the work, the location of the site, the names of operators or asbestos removal contractors, methods of removal and the amount of asbestos, and whether the operation is a demolition or renovation.
Asbestos Notification Form (PDF)
The NESHAP regulation states that either the owner of the building or the operator of the demolition or renovation operation can submit the notification. Usually, the two parties decide together who will notify. If neither provides adequate notice, either or both parties can be held liable.
For demolition, the start date is the date that the removal or related activity begins. The demolition start date must be reported. The waiting period should be calculated based on the start date of the removal or the demolition if no removal is required. The waiting period is necessary to give inspectors time to visit the site before activity begins
The Asbestos NESHAP regulation specifies “working days.” Holidays that fall between Monday and Friday count as “working days.”
A notification must be revised if the information contained in the original notice has changed. For example, you must revise the notification if you change the start date of an operation. If the change relates to the amount of RACM involved, you need only revise the notification if the amount changes by more than 20 percent.
The age of a building does not exclude it from the requirements. A building being demolished or renovated must be inspected regardless of age. Asbestos-containing building materials are still made and available. Furthermore, the reuse of materials also increases the possibility that asbestos-containing materials may be in a newer building.
Yes, moving a building is considered demolition and requires an asbestos survey and filing of a demolition notification with the appropriate regulatory agency. Moving a portable structure, one that was factory-built and designed to be moved, is not subject to the NESHAP. Portable structures being renovated or demolished are subject to the NESHAP.