Why this matters now
EPA’s Asbestos NESHAP sets work practices that must be followed during demolition and renovation of facilities (institutional, commercial, industrial, public, and most multi-unit residential), with a limited exemption for residential buildings of four or fewer dwelling units. If you’re doing winter build-outs, you need a compliant plan before anyone opens a ceiling or cuts pipe insulation.
Step 1: Confirm if NESHAP applies to your project
Ask two quick questions:
- Is the structure a “facility”? (commercial/industrial/institutional, or multi-unit residential not exempt).
- Will demolition or renovation disturb suspect materials?
Single homes or duplexes may be exempt, but that exemption doesn’t apply if residences are demolished/renovated as part of a commercial or public project (e.g., urban renewal or redevelopment). When in doubt, treat it as covered and verify with your state agency.
Step 2: Order a pre-renovation asbestos survey by a licensed inspector
NESHAP requires a thorough inspection of the affected area to determine the presence of ACM before demolition or renovation. Your survey should identify locations, types, and quantities, with accredited lab analysis. Keep the report onsite for contractors and inspectors.
Step 3: File your state notifications on time
- Georgia (EPD): Submit your project notification in GEOS at least 10 business days before any demolition, renovation disturbing ACM, or asbestos abatement. Georgia notes that demolition notification is required regardless of whether ACM is present. For combined jobs (abatement + demo), Georgia directs separate notifications.
- South Carolina (DHEC): Follow Regulation 61-86.1for licensing, project design (where required), and pre-work written notifications to the state. DHEC also publishes a plain-English brochure on renovation/demolition requirements.
Tip: Submit early in winter. Weather windows are tight, and missing the 10-day clock can stall mobilization.
Step 4: Align your work practices with OSHA 29 CFR 1926.1101
NESHAP controls emissions and notifications; OSHA protects workers. Your contractors must comply with OSHA’s construction asbestos standard, including regulated areas, exposure assessment, controls, and a designated competent person on site. Keep exposures at or below the OSHA PEL and document training/medical surveillance where required.
Step 5: Specify abatement and sequencing
If ACM will be disturbed, plan abatement before general demo/renovation. Your project documents should define containment, negative pressure, wet methods, and clearance criteria. In South Carolina, certain projects require a project designer and licensed air sampling; coordinate these roles at bid time.
Step 6: Manage waste correctly
Package, label, and transport asbestos waste per NESHAP; use approved disposal sites and keep manifests with your close-out records. Your state notifications and contractor submittals should reflect these arrangements.
Step 7: Close out with verification
After abatement, obtain required visual inspection and air clearance (per your specs/state rules) before other trades re-enter. Keep survey, notifications, air results, and disposal manifests with the facility’s environmental files.
Quick Winter Checklist
- Confirm NESHAP applicability and any residential-exemption edge cases.
- Hire a state-licensed asbestos inspector; complete the survey.
- File GA GEOS or SC DHEC notifications ≥10 business days pre-start.
- Require OSHA 1926.1101 compliance and a competent person.
- Sequence abatement before demo/reno; document containment/clearance.
- Track waste manifests and final air results; archive everything.
FAQ managers ask us
Do I notify Georgia EPD for a demolition with no ACM?
Yes—Georgia states demolition notification is required regardless of ACM presence.
We’re clearing multiple small houses for a commercial project—are they exempt?
Probably not. The residential exemption for four-or-fewer units is limited and does not apply when demolition occurs for public/commercial projects.
Can we start early due to emergency conditions?
Emergency notifications exist, but you still must file promptly and justify the emergency to the agency; coordinate with EPD/DHEC before mobilizing.
EnviroPro 360: NESHAP-ready surveys and reports
As the Southeast’s premier environmental testing partner, EnviroPro 360 provides:
- Pre-renovation/demolition asbestos surveys by licensed inspectors
- Contractor-ready reports with drawings, sample logs, and quantities
- Notification support for GEOS (GA) and DHEC (SC)
- Coordination with licensed abatement teams and post-abatement clearance
- Add-on testing: mold/IAQ, radon, and leak detection
Final Thought
Planning a winter renovation or demo? Contact EnviroPro 360 to schedule a certified asbestos survey and keep your 2026 projects safe, legal, and on schedule.
