Wisconsin DNR Asbestos Program Frequently Asked Questions
- When do you need to inspect a building for asbestos?
- I am demolishing or renovating a relatively new building. Do I still need an asbestos inspection?
- Does the DNR require that you inspect and notify for the demolition of a house?
- Can you composite asbestos bulk samples?
- Can I round down if my lab results report asbestos content of less than 1.5 percent, but greater than 1.0 percent?
- When do you need to notify the DNR of a demolition or renovation?
- Why is there a 10 working day waiting period for the notification? What is the difference between a calendar day and a working day?
- When does a notification expire?
- Is there a fee for demolition by Fire Training burn?
- What do I need to do prior to demolishing a building?
- What do I need to do prior to renovating a building?
- When can the DNR issue citations?
- Which building materials contain asbestos?
- When is floor tile regulated?
- I have heard that Vermiculite can contain asbestos. How do I handle it and is it dangerous to have in my house?
- When do you need to inspect a building for asbestos?
- All structures must be inspected for the presence of asbestos prior to renovation or demolition, with the exception of a single, residential structure with 4 or fewer dwelling units.
- I am demolishing or renovating a relatively new building. Do I still need an asbestos inspection?
- The age of a building does not exclude it from the requirements of chapter NR 447 [exit DNR]. 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.
- Does the DNR require that you inspect and notify for the demolition of a house?
In Wisconsin Administrative Code, ch. NR 447, a "facility" is defined as "any institutional, commercial, public, industrial or residential structure, installation or building…excluding residential buildings having 4 or fewer dwelling units.
This means that a house (single residential structure with 4 or fewer dwelling units) would be exempt from complying with NR 447. However, multiple structures of any type that are part of a larger project would be considered an installation within the facility definition, and regulated under NR 447. So for example, two houses on a contiguous property being demolished would be regulated.
While the DNR would not require an asbestos inspection or notification for a single residential structure with 4 or fewer dwelling units, Waste & Materials Management regulations do require that the waste generated from the demolition be disposed of properly.
- Can you composite asbestos bulk samples?
Most asbestos bulk samples must be separated by layer. The one exception is the sampling of drywall joint compound that is located over nails and seams. It is the only suspect material that is allowed to be combined with its drywall substrate. The reporting of asbestos content can include the joint compound and drywall. This exception does not include compounds that cover the entire wall system.
Please note that the Occupational Safety and Health Administration (OSHA) does require that even drywall and joint compound be sampled separately by layer.
- Can I round down if my lab results report asbestos content of less than 1.5 percent, but greater than 1.0 percent?
A material is considered to be asbestos containing if the material contains greater than 1% asbestos. If the lab reports the amount of asbestos to be any amount greater than 1%, it is considered Asbestos Containing Material (ACM).
Therefore, a lab reporting results of 1.25% would be considered ACM. If lab results are reported as 1% and still meet regulatory requirements and scientific standards, then the material would not be considered ACM.
- When do you need to notify the DNR of a demolition or renovation?
All demolition projects must be notified to the DNR regardless of whether or not there is asbestos present in the building, with the exception of a single, isolated, residential structure with 4 or fewer dwelling units.
For renovations, a notification is required when the project involves the disturbance of 260 linear feet of asbestos pipe insulation, or 160 square feet of regulated asbestos containing material (RACM).
Please see the Pre-Demolition Environmental Checklist [PDF] for more information on hazardous materials in buildings.
- Why is there a 10 working day waiting period for the notification? What is the difference between a calendar day and a working day?
The 10 working day waiting period is in place for a number of reasons. It allows the notification to reach the DNR and provide ample time for review and processing. It also allows the DNR to respond to any concerns before the project begins. Finally, it allows the DNR inspectors to plan inspections for the regulated sites.
A working day means Monday through Friday, including holidays that fall on any of the days Monday through Friday.
- When does a notification expire?
A notification expires once the last end date provided on the notification passes. A notification can be revised to extend dates if the revision is postmarked prior to the original end date provided.
If a notification is allowed to expire, a new notification must be submitted including the 10 working day waiting period and necessary fees.
- Is there a fee for demolition by Fire Training burn?
If a single residential structure with 4 or fewer dwelling units will be demolished by fire training burn, a fee is not required with the demolition notification.
If multiple residential structures or any other structure meeting the definition of "facility" in NR 447 are to be demolished by fire training, then a fee must be submitted along with the demolition notification.
- What do I need to do before demolishing a building?
Inspect - Prior to any demolition the owner or operator must have the building inspected for the presence of asbestos. Depending on the type of asbestos present and the demolition methods used, some or all of the asbestos containing materials may have to be removed prior to beginning demolition activities.
Notify - The DNR requires a Notification of Demolition and/or Renovation (Form 4500-113) to be sent with applicable fees, 10 working days prior to the start of the project. The DNR requires this notification regardless of whether or not asbestos is present in the building.
- What do I need to do prior to renovating a building?
Inspect - Prior to any renovation the owner or operator must have all building materials affected by the renovation inspected for the presence of asbestos. Building materials that contain asbestos can only be removed by a certified asbestos worker. Some or all of the asbestos containing materials may have to be removed prior to beginning renovation activities.
Notify - If the project involves the disturbance of equal or greater than 260 linear feet of asbestos pipe insulation or equal to or greater than 160 square feet of other Regulated Asbestos Containing Material (RACM), than the DNR requires a Notification of Demolition and/or Renovation (Form 4500-113) to be sent with applicable fees, 10 working days prior to the start of the project.
- When can the DNR issue citations?
The DNR can issue citations for any of the following violations:
- Failure to notify the DNR of regulated demolition or renovation activities;
- Failure to conduct an inspection prior to demolition or renovation; or
- Not following asbestos landfill disposal requirements.
- Which building materials contain asbestos?
Over 3,000 different building materials are known to contain asbestos. Asbestos, a naturally occurring mineral, was used because it is heat resistant, an excellent insulator, a poor conductor, adds tensile strength, and is chemical resistant. An asbestos containing material is any material containing greater than 1 percent asbestos. Its uses include roofing materials, flooring, thermal insulation, wall systems, fire proofing, acoustical finishes, tile, and adhesives.
Because the number of materials containing asbestos is so great, and the materials are so varied, the Wisconsin Department of Health and Family Services (DHFS) [exit DNR] requires that any asbestos inspection be conducted by a DHFS Certified Asbestos Inspector.
- When is floor tile regulated?
The definition of Regulated Asbestos Containing Material (RACM) includes Category I nonfriable asbestos (including floor tile) that has become friable or has been subjected to sanding, grinding, cutting, or abrading.
This includes floor tile that is in poor condition and can be crumbled, pulverized or reduced to powder using hand pressure and floor tile that has been removed utilizing mechanical methods. However, the regulated status of the floor tile is not solely based on its condition prior to removal and method of removal, but also to its condition as a result of removal. For example, if the methods utilized cause the floor tile to become crumbled, pulverized, or reduced to powder, then the floor tile is considered RACM.
- I have heard that Vermiculite can contain asbestos. How do I handle it and is it dangerous to have in my house?
Vermiculite was used as insulation in houses as well as many other products. This same vermiculite is known to have been contaminated with asbestos during the mining process, and can present a health hazard.
The EPA has begun work to understand all of the risks related to vermiculite. The current recommendation is that if vermiculite asbestos is present in your home, it must not be disturbed. The vermiculite may not cause a health hazard if not disturbed. Disturbing the vermiculite increases the likelihood that asbestos fibers will be released into the air. For extensive information on vermiculite, visit the EPA Web page, Asbestos Contamination in Vermiculite [exit DNR]
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