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November 07, 2003
Does a contractor need to be EPA approved to remove transite asbestos siding from a building?

According to 40 CFR 61.145(c)(8), no regulated asbestos-containing material (RACM) can be stripped, removed, or otherwise handled or disturbed at a facility regulated by 40 CFR 61.145 unless at least one on-site representative, such as a foreman or management-level person or other authorized representative, is properly trained. Evidence of proper training is required to be on-site during the project.

1. Is transite asbestos siding RACM?

Transite boards or panels containing more than 1 percent asbestos are most likely considered Category II nonfriable asbestos-containing material (ACM). Category II nonfriable ACM is defined as RACM if it has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by 40 CFR 61.145.

2. Is the facility regulated by 40 CFR 61.145?

40 CFR 61.145(a)(4): In a facility being renovated (which includes the removal of RACM), all the requirements of 40 CFR 61.145(b) and (c) apply if the combined amount of RACM to be stripped, removed, dislodged, cut, drilled, or similarly disturbed is:

  • At least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components.
  • At least 1 cubic meter (35 cubic feet) of facility components where the length or area could not be measured previously.

Therefore, the answer to your question depends on:

  • The condition of the material at the time of demolition or renovation.
  • The nature of the operation to which the material will be subjected, and
  • The amount of ACM involved.
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