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When asbestos testing is required

IRIS Environmental Laboratories · 2 min read

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The four frameworks that trigger asbestos testing, AHERA, OSHA, NESHAP and waste disposal, and the test each one expects.

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Four regulatory frameworks drive most asbestos testing. Each has its own trigger, method and enforcing authority.

AHERA: schools

  • All K-12 schools must be inspected for ACM, and re-inspected every 3 years, under 40 CFR Part 763.
  • After abatement, air clearance by TEM (40 CFR 763 App. A) is required before reoccupancy. The clearance criterion is 70 s/mm².

OSHA: workers

  • 29 CFR 1926.1101 (construction) and 1910.1001 (general industry): PEL 0.1 f/cc TWA, AL 0.1 f/cc.
  • An initial exposure assessment is required when workers may disturb ACM or PACM.
  • PCM by NIOSH 7400 is the OSHA-accepted method. Results must be available within 5 working days.

NESHAP: demolition and renovation

  • EPA 40 CFR Part 61 Subpart M applies to all demolition and significant renovations.
  • The owner or operator must survey for RACM before demolition. Bulk PLM results drive the notification requirement.
  • RACM threshold: ≥160 sq ft friable, ≥260 linear ft, or ≥35 cubic ft.

Waste disposal: NJ and NY

  • Demolition waste containing ACM must be classified as hazardous or non-hazardous before disposal.
  • Waste classification submitted to NY DEC or NJ DEP needs NY ELAP accredited methods.
  • For non-friable material, NOB by PLM (Item 198.6) determines whether the friability threshold is exceeded.

Other common triggers

  • Renovating a pre-1980 building: identify ACM before work begins.
  • A litigation or insurance dispute: you need a defensible chain of custody and a PLM and TEM report.

Which test answers which rule

FrameworkTestIRIS accreditation
AHERATEM air clearance, bulk PLM surveysNVLAP 600211-0 and NY ELAP #12738
OSHAPCM air, NIOSH 7400NJ NELAP and NY ELAP
NESHAPBulk PLMNVLAP 600211-0
Waste disposalWaste solids by PLM or TEM, NOBNY ELAP #12738 and NJ NELAP

One lab, one chain of custody and one report can cover all four frameworks.

Next step

For help matching your project to a method, contact the lab or email support@irislaboratories.com.

Chain of custody

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