Click the following link to view the PDF of this paper: Asbestos Surveys – Highlighting Inconspicuous Materials
Joseph D. Grabowski
Asbestos Services Manager
Atlantic Testing Laboratories
Apart from owner-occupied one- to two-story dwellings where the owner performs work themselves, an asbestos survey must be completed whenever a project has the potential to disturb suspect asbestos-containing materials (ACM). This requirement applies to a wide range of activities that impact a building or structure. According to New York State’s Code Rule 56 (12 NYCRR Part 56), a Department of Labor-certified inspector must perform an asbestos survey if a project involves demolition, renovation, remodeling, or repair of all or part of a building structure.
Initially, it may seem clear which materials will be disturbed during planned work. There are exposed building materials in work areas that are easy to access, visually assess, and sample. There might be as-built drawings that help identify materials installed during construction. An experienced building representative familiar with the building’s history of demolition, renovation, and repairs could be helpful. Unfortunately, things are often more complicated. Not all materials are visible, as-built drawings are rarely fully up-to-date, and even the best memory can distort details.
Locating and identifying different materials becomes more complex as a building ages, especially after multiple renovations and repairs, as records become harder to find, and facility staff change. An asbestos survey should consider potential for unknowns based on the building’s history, including the presence of inconspicuous materials. The following list provides examples of inconspicuous suspect ACM commonly overlooked.
| Suspect ACM | Common Areas to Consider |
| Thermal System Insulation (TSI) (Pipe and HVAC) | Wet walls/wall chases, above ceiling systems, crawlspaces, light fixtures |
| Loose Fill Vermiculite Insulation | Concrete masonry unit walls, attic spaces below blown-in or batt insulation, greenhouse plant boxes, under mechanical equipment for absorption |
| Cloth Wire Jackets | Light fixtures, electrical conduits, elevator equipment, building electrical wiring within walls and above ceilings (sometimes abandoned) |
| Vapor Barriers | Under hardwood floors, concrete floor slabs, roof deck, bathroom built-in ceramic showers or shower basins, walk-in coolers (walls, floor, ceiling), gymnasium floors |
| Waterproofing | Exterior masonry walls (interior side of masonry wall within wall cavity), building foundations below grade, gymnasium floors |
| Textured Paint | Walls, floors, or ceilings (under newer paints or coatings) |
| Masonry Coating | Walls, floors, or ceilings (under newer paints or coatings) |
| Fire Door Insulation | Wood or metal doors (may or may not have a fire rating tag), boiler or electrical room doors |
| Fabric and/or Adhesive | Outdoor tracks, turf fields |
| Fireproofing | Older spray-applied fireproofing under newer spray-applied fireproofing above ceilings and behind walls |
| Flooring | Under fixed objects and partition walls |
| Various | Materials adjacent to direct impact of work activities that may have ancillary impact from vibrations, incidental contact, or installation of fasteners |
A thorough asbestos survey requires an inspector to have a clear scope of work and understanding of how the planned project will impact building areas, systems, and components. To the extent available, historical assessment reports and construction documents should be provided, and the asbestos consultant should be informed of any changes to the project scope that might require additional assessment. Sharing knowledge about access points, such as wet walls, pipe chases, ceiling hatches, electrical trenches, or other unique areas, is also important. This helps with considerations for locating and identifying inconspicuous suspect ACM, reducing the chance of schedule delays, cost overruns, or need for modifications during the project.
Even with the most careful asbestos survey, inconspicuous suspect ACM that is covered and/or inaccessible may inadvertently go unnoticed. If this occurs, New York State regulations (12 NYCRR Part 56) include a section called “Unidentified and Unassessed Asbestos,” stating that all activities that could disturb the material should cease, and the material should be treated as ACM unless proven otherwise through sampling and laboratory analysis.
Coordination and communication with certified asbestos professionals throughout planning and construction are essential for proper handling of ACM and regulatory compliance. If you have a project that might disturb asbestos materials, ATL has experienced, certified environmental professionals across New York State ready to provide consultation, and asbestos surveys and abatement design.
For more information, contact Joe Grabowski at 315-386-4578, info@atlantictesting.com, or visit www.AtlanticTesting.com.
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