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Common Questions and
Answers:
When and How to Notify
for
Renovation or Demolition Projects in Hillsborough County
What projects require notification?
What is Asbestos-Containing Material (ACM) and Regulated
Asbestos-Containing Material (RACM)?
What are the notification requirements?
When is an asbestos inspection required?
Who can remove asbestos-containing material?
Where do I send notification?
What are the county asbestos fee requirements?
If I obtain a
building permit, does this meet the federal asbestos notification
requirement?
What if I have an emergency project?
 What
projects require notification?
Only single, isolated, family
residential structures with four dwelling units or less are exempt
from the asbestos National Emission Standards for Hazardous Air
Pollutants (NESHAP) requirements for notification
(40 CFR 61, Subpart M). The residential exemption does not apply if
the house was ever used for commercial purposes in the past.
All other structures, or multiple
residences, demolished as part of a single project and located on one
site, are subject to the notification requirements for demolition
whether or not asbestos-containing material (ACM) is present. (See
also
Asbestos NESHAP Clarification of Intent - Residential Building Exemption)
Only renovation projects involving
regulated asbestos-containing material (RACM) above certain threshold
amounts require notification. Written notification is not required for
renovation projects where asbestos containing materials are not
disturbed or made regulated during the planned activity.
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What
is Asbestos-Containing Material (ACM) and Regulated Asbestos-Containing
Material?
ACM is any material containing more than 1% asbestos as determined using
Polarized Light Microscopy (PLM). There are two types of ACM. Category
I nonfriable ACM means asbestos-containing packings, gaskets, resilient
floor covering and asphalt roofing products. Category II nonfriable ACM
means any material, excluding Category I nonfriable ACM.
  RACM is any friable
asbestos-containing material containing more than 1% asbestos as
determined using PLM that can be crumbled, pulverized or reduced to
powder by hand pressure when dry. RACM also includes Category I or
Category II non-friable asbestos material that has become friable prior
to, or during, demolition or renovation operations.
Friable Ceiling Tile (left)
Friable Asbestos AirCell (right)
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Delaminating Category II cementitious
material (gray layer) applied to a concrete column
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 In addition, Category I or II ACM that has a high
probability of becoming RACM (crumbled, pulverized or reduced to powder)
during demolition must be removed prior to the start of the demolition
activity.
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What
are the notification requirements?
Written notification is to be mailed
or hand-delivered:
·
Ten (10) working days
prior to a demolition, even if there is no asbestos present
·
Ten (10) working days
prior to a renovation activity, if the amount of RACM to be
stripped, removed, dislodged, cut, drilled or disturbed is greater than
160 square feet (SF) on facility components or 260 linear feet (LF) on
pipes, or 35 cubic feet off facility components where the length or area
could not be measured previously
Written revisions, including changes
to the start date, may be faxed to our office at (813) 627-2660 and must
be submitted no later than the originally notified start date if the
activity will fall after the original start date. Otherwise the 10
working day requirement must be met for any proposed activities to start
earlier than the originally notified start date.
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 When is an asbestos inspection required?
Sample collection during inspection
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 A
thorough asbestos inspection (survey) is required by a state
Licensed Asbestos Consultant before any renovation or
demolition activity begins, regardless of the age of the building or the
building materials. This requirement also applies to buildings that are
damaged by fire or water. Attach a copy of the asbestos inspection or
asbestos survey report to all demolition notifications. In addition, a
copy of the asbestos (survey) report should be maintained at the job
site during all renovation or demolition activities. Top↑
Who can remove
asbestos-containing material?
A
Florida Licensed Asbestos Contractor must perform all activities
involving the removal or handling of ACM and RACM. Licensure is not
required if certain criteria are met for moving, removal, or
disposal of asbestos containing roofing materials, resilient flooring
materials, and exterior conduit or piping as specified under
Chapter 469.002, F.S.. Supervisors and/or workers must be trained
in accordance with
Florida Department of Business and Professional Regulation (DBPR)
requirements. All employers of workers who require employees to handle
asbestos must comply with
OSHA asbestos regulations (29
CFR Part 1910.1001 and
29 CFR Part 1926.1101). Top↑
Where do I send notification?
All asbestos notifications for projects to be performed in Hillsborough
County must be mailed or hand-delivered to the
Environmental Protection Commission (EPC). Include the appropriate
Hillsborough County fee and a copy of the asbestos inspection (survey)
report with the
notice:
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What are the county asbestos fee requirements?
Fees are due at the time of
notification. The fee may cover multiple structures, as long as the
structures are located on a single site and the project demolition or
renovation activities are not phased. For projects involving
renovation and demolition activities, separate fees are due for each
activity performed at the site. Make checks payable to the EPC.
The Hillsborough County
fee schedule for asbestos is as follows:
·
Demolition of
structure less than 50,000 SF:
$200.00
·
Demolition of
structure greater than or equal to 50,000 SF: $300.00
·
Renovation 160
SF/260 LF up to 1000 SF/LF: $300.00
·
Renovation greater
than 1000 SF/LF: $500.00
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If I obtain a building permit, does this meet the federal asbestos
notification requirement?
No, the receipt of a city or county permit is not the same as providing
the federally required asbestos notification to the EPC. A copy of the
state asbestos notification form [DEP 62-257.900(1)] can be obtained
from the EPC or from the following website address:
http://www.dep.state.fl.us/Air/forms.htm
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What if I have an
emergency project?
Notification is required as soon as possible before, but not later than
the following working day for any emergency renovation operation or
emergency demolition (if the building has been declared structurally
unsound and in danger of imminent collapse by a State or local
governmental agency). The asbestos NESHAP requirements for a thorough
asbestos inspection (survey) prior to the start of the demolition or
renovation activity and disposal of waste debris in an appropriate
landfill are still applicable for all emergency projects. If a thorough
asbestos inspection is not done prior to the start of the activity and a
means of complying with this requirement is not possible, then all of
the building waste materials must be treated as RACM and disposed of in
an appropriate regulated landfill per the provisions of
40 CFR 61.150. Contact our office for more information.
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