A property manager in Augusta schedules a contractor to renovate three units in a 1968 apartment building. The contractor starts demoing the bathroom tile on day one. On day two, the property manager gets a call — the material contains asbestos. The contractor walks off the job. The units are contaminated. Tenants can’t return. State notification is now overdue.
That scenario is avoidable with one step taken before work begins: a pre-renovation asbestos survey.
This checklist walks you through what Georgia and South Carolina require, what the survey process actually involves, and what to have in place before any contractor picks up a tool.
Why Every Renovation Needs an Asbestos Survey
Under EPA’s Asbestos NESHAP (National Emission Standards for Hazardous Air Pollutants), owners and operators must conduct a thorough inspection of any renovation or demolition area before work begins to determine the presence of asbestos-containing material (ACM). This applies to most commercial, institutional, industrial, and multi-unit residential projects — not just large-scale demolitions.
The regulatory exposure for skipping this step is real. But for property managers, the practical risks are often more immediate: a contaminated building you can’t turn over to tenants, a contractor who won’t proceed, a lease obligation you can’t fulfill, and liability that follows the property owner — not the contractor who walked away.
Georgia and South Carolina both operate asbestos programs alongside the federal NESHAP:
- Georgia EPD requires project notification at least 10 working days before demolition, renovation disturbing ACM, or asbestos abatement. Submittals are made through the GEOS portal.
- South Carolina DHEC (Regulation 61-86.1) sets licensing, project design, and notification requirements for asbestos projects. Written notification is required before work begins, and demolition projects require notification even when no ACM is identified.
The Property Manager’s Step-by-Step Checklist
1. Determine Whether a Survey Is Required
- Is the project demolition or renovation that will disturb suspect materials — ceilings, flooring, insulation, mastics, roofing, or cement board?
- Is the building a commercial, institutional, industrial, or multi-unit residential facility under NESHAP? If yes, a survey is required before work begins.
- Note: NESHAP excludes single residential buildings with four or fewer units, but this exemption does not apply when multiple small residences on one site are demolished by the same owner or for commercial redevelopment.
2. Hire the Right Professionals
- Retain a state-licensed asbestos inspector to perform a comprehensive survey of all suspect materials in the work area.
- Ensure bulk samples are analyzed by an accredited laboratory and reported with locations, types, and quantities of ACM.
- For projects that will disturb ACM, plan for a licensed abatement contractor and, where required, a project designer and air monitor per SC DHEC requirements.
3. Plan the Survey Scope
This is where many property managers underestimate the process. A thorough survey must include hidden spaces that renovation crews will encounter:
- Pipe chases and mechanical rooms
- Above drop ceilings and in plenums
- Underlayment beneath flooring
- Roofing layers and exterior transit panels
- Elevator shafts and utility corridors
Coordinate selective destructive testing as needed to access concealed materials, and build time for this into the project schedule before a contractor mobilizes.
4. Collect and Document Samples
- Ensure sample IDs match floor plans
- Maintain a chain of custody for all samples
- Keep the full survey report onsite for inspectors and contractors throughout the project
NESHAP compliance monitoring programs verify adherence at active sites. Incomplete documentation is treated the same as no survey.
5. File Required Notifications
- Georgia: Submit your GEOS notification at least 10 business days before demolition, renovation disturbing ACM, or abatement. Separate notifications may be required when abatement precedes demolition.
- South Carolina: Submit written notification to SC DHEC with project details and applicable fees before work begins. Demolition notices are required even when no ACM is identified.
If you manage multiple properties, build notification lead times into your renovation scheduling as a standard step — not a last-minute item.
6. Specify Work Practices
- Your abatement plan should define regulated areas, negative pressure containment, wet methods, waste handling, and air clearance procedures
- OSHA’s construction standard (29 CFR 1926.1101) requires employers to keep asbestos exposures at or below 0.1 fibers per cubic centimeter as an 8-hour TWA, with additional controls and medical surveillance requirements where applicable
7. Coordinate Trades
- Sequence abatement before general demolition or renovation that could disturb ACM
- Brief all subcontractors on restricted zones and access routes
- Do not allow other trades into abatement areas until clearance is confirmed in writing
This coordination step is frequently skipped when schedules are tight — and it’s the most common cause of accidental disturbance events on multi-trade projects.
8. Manage Waste and Transport
- Package and label regulated asbestos-containing material (RACM) per NESHAP requirements
- Retain waste shipment manifests
- Use disposal sites approved in your notification
9. Clearance and Close-Out
- Obtain required visual inspection and air clearance results before re-occupancy or re-entry by other trades
- Retain final reports, air clearance results, and manifests with your facility records permanently — these documents are required for future transactions and renovations
What to Expect From the Survey Process
A pre-renovation asbestos survey from a licensed inspector typically takes one to two site visits depending on building size and complexity. The inspector will:
- Walk the full renovation scope with you or your contractor
- Identify and sample all suspect materials — visible and concealed
- Coordinate selective destructive sampling for hidden areas as needed
- Submit samples to an accredited laboratory
- Deliver a written report with results, locations mapped to floor plans, and recommendations for each ACM identified
For a property manager, that report becomes your compliance baseline. It’s what your abatement contractor needs to bid the work, what the state agency receives in your notification, and what your records need to show if a question comes up after the fact.
Common Questions From Property Managers
“No ACM was found — do I still need to notify?”
In Georgia and South Carolina, demolition projects typically require notification even when no ACM is present. Verify with your state agency forms before assuming you’re exempt.
“Small residential buildings are exempt, right?”
NESHAP excludes single residential buildings with four or fewer units. But that exemption does not apply when multiple small residences on one site are demolished by the same owner or for commercial redevelopment. When in doubt, confirm with your state program.
“What if there’s an emergency?”
Emergency notifications are possible under both Georgia EPD and SC DHEC procedures, but both agencies still require prompt submittals and written justification. Emergency provisions adjust the timeline — they don’t eliminate the regulatory obligation.
A Note on Seasonal Project Timing
Renovation and capital project schedules in Georgia and South Carolina tend to stack up in fall and winter. A few things worth planning for:
- Submit state notifications early. The 10-business-day window doesn’t flex, and agency processing times can vary during busy periods.
- Older ACM like pipe insulation can degrade with temperature and moisture swings common in the CSRA. Build contingency into budgets for abatement scope discovered during selective demolition.
- Coordinate indoor air quality checks after abatement and before tenant turnover. A clearance report in your file protects you if a tenant raises concerns after move-in.
Final Thoughts
A pre-renovation asbestos survey isn’t an obstacle to getting a project done — it’s what keeps a project from stopping unexpectedly when asbestos is discovered mid-demo. For property managers overseeing multiple buildings in Georgia and South Carolina, building the survey into every pre-renovation workflow is the most straightforward way to stay compliant and keep contractors on schedule.
If you have questions about pre-renovation survey requirements or want to talk through an upcoming project, the EnviroPro 360 team is happy to help. Reach out any time.
