Asbestos: Inspection Report Requirements

Air Pollution Control Program fact sheet
02/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB02349

Disclaimer: The statements in this document are intended solely as guidance. This document is not intended, nor can it be relied on, to create any rights enforceable by any party in litigation. This guidance may be revised without public notice to reflect changes in law, regulation or policy.

This document is one in a series of fact sheets designed to assist you in becoming aware of the Missouri Department of Natural Resources’ asbestos requirements. This particular document contains general information about asbestos surveys or inspections.

Asbestos Inspection Requirements
Any regulated project subject to the National Emission Standard for Hazardous Air Pollutants (NESHAP), for Asbestos, 40 CFR Part 61, Subpart M will require an asbestos inspection. The year of construction or renovation of a regulated facility does not affect the inspection requirements. NESHAP requirements are discussed in the department’s fact sheet, Asbestos Requirements for Demolition and Renovation Projects, Fact Sheet--PUB2157. Additional asbestos information is available at dnr.mo.gov/env/apcp/Asbestos.htm.

An asbestos inspection occurs when a Missouri certified asbestos inspector inspects a building or facility for the presence of asbestos-containing material (ACM) or suspects ACM. Suspect ACM is any material potentially containing asbestos that has not been sampled and analyzed for asbestos content. An asbestos inspection also includes re-examining a building or facility to identify the presence or location of additional or existing ACM, suspected ACM or to determine the current condition of previously identified ACM following an event such as a fire or flood.

The following inspections or assessments do not normally qualify as thorough NESHAP asbestos inspections:

Asbestos Inspection Personnel
A person certified as an asbestos inspector by the department must conduct all inspections and assessments. A list of certified asbestos inspectors is available at dnr.mo.gov/env/apcp/Asbestos.htm.
The NESHAP requires thorough inspections be conducted. For renovation projects, inspections need only include those areas of a building impacted by the renovation work. For demolition work, thorough inspections should include destructive sampling and access to all areas of the building.

Total Number of Samples Required
No sampling is required if the certified inspector presumes that ACM is present and the owner or operator responsible for the project decides to treat it as ACM. However, for a suspect material to be considered as non-ACM, a minimum number of samples must be collected and analyzed. The department recommends inspectors follow, at a minimum, the 3-5-7 rule suggested in the Asbestos Hazard Emergency Response Act.

Inspectors should also note both the condition of the materials and their quantities in the report. If known, inspectors should comment on the potential work practice impacts on Category I and Category II nonfriable or stable ACM that have the potential to be left in-place during demolition or renovation projects.

Asbestos Sample Analysis Requirements
The department strongly recommends all asbestos analysis be conducted by either:

Asbestos Inspection Report Requirements
The written report should be provided to the person requesting the inspection. The asbestos inspection and assessment report should contain the following information:

Completed copies of asbestos inspection reports should accompany all NESHAP renovation and demolition notifications submitted to the department or local agencies.

Asbestos Contact Information
For more information on the department’s asbestos requirements, you may contact the department’s Air Pollution Control Program or one of the department’s other offices:

Local Agencies
In Missouri, there are two local agencies that have an agreement with the department to enforce Missouri’s asbestos requirements as well as local ordinances. These local agencies are:

Jurisdiction Agency Telephone
Kansas City Kansas City Health Department Air Quality Program 816-513-6314
St. Louis County St. Louis County Health Department 314-615-8924

Two additional local agencies do not enforce Missouri’s asbestos requirements but may have local ordinances concerning asbestos which they enforce:

Jurisdiction Agency Telephone
St. Louis (city) St. Louis Division of Air Pollution Control Air Quality Program 314-613-7300
Springfield Springfield-Greene County Health Department of Environmental Services 417-864-1412

Prior to performing a project in one of these jurisdictions, you should contact the appropriate agency to determine if any additional requirements apply.

Missouri Department of Natural Resources
Air Pollution Control Program
P.O. Box 176
Jefferson City, MO 65102
573-751-4817
573-751-2706 fax
http://www.dnr.mo.gov/env/apcp/

Other Department Offices
Regional Offices

Kansas City Regional Office
500 NE Colbern Road
Lee's Summit, MO 64086-4710
816-251-0700
816-622-7044 fax

Northeast Regional Office
1709 Prospect Dr.
Macon, MO 63552-2602
660-385-8000
660-385-8090 fax

St. Louis Regional Office
7545 S. Lindbergh, Suite 210
St. Louis, MO 63125
314-416-2960
314-416-2970 fax

Southeast Regional Office
2155 N. Westwood Blvd.
Poplar Bluff, MO 63901
573-840-9750
573-840-9754 fax

Southwest Regional Office
2040 W. Woodland
Springfield, MO 65807-5912
417-891-4300
417-891-4399 fax

Additional Asbestos Related Guidance Documents
For more specific information about the department’s requirements in regard to asbestos, reference the additional guidance documents listed below or contact the department or appropriate local agency at the contact information found in this fact sheet.

These documents are available for free download from the department’s website at www.dnr.mo.gov/pubs/index.html.