Guidance for ordered and asbestos containing demolitions
The Michigan Department of Environment, Great Lakes, and Energy's (EGLE) Air Quality Division (AQD) has posted guidance to remind stakeholders that ordered demolitions and asbestos containing demolitions are subject to and must comply with federal asbestos regulations. Asbestos is a known carcinogen that can have serious impacts on public health.
Ordered demolitions have a high probability of containing asbestos and should be treated as if asbestos is present with strategies to control emissions implemented. The US Environmental Protection Agency (USEPA) and EGLE expect reasonable efforts to be made to properly remove regulated asbestos containing material (RACM) hazards under controlled circumstances from all buildings prior to demolition if it is considered safe to do so.
EGLE AQD Ordered Demolition Guidance (July 2023)
What is required?
Ordered demolitions are rare and in the case they become necessary, they must:
- Comply with applicable portions of the National Emission Standard for Hazardous Air Pollutant (NESHAP), 40 CFR Part 61, Subpart M for Asbestos including meeting the definition of ordered demolition.
- Use unique work methods for either controlled demolition, “make-safe” shoring to allow for proper asbestos removal, or other such methods and provide this documentation with the notification. Any portion of a facility that can be safely entered should be thoroughly inspected and abated.
- Submit, when feasible, a 10-day notification prior to demolition. Notifications less than 10 days should be used only when necessary.
- Comply with adequately wet, no visible emissions and removal of asbestos-containing waste material provisions of the NESHAP at all times.
Other asbestos containing demolitions must:
- Comply with applicable portions of the NESHAP, 40 CFR Part 61, Subpart M for Asbestos.
- Submit, at a minimum, a 10-day notification prior to demolition.
- For facilities that may be structurally unsound, any portion of a facility that can be safely entered should be thoroughly inspected and abated prior to demolition. Use unique work methods for either controlled demolition, “make-safe” shoring to allow for proper asbestos removal, or other such methods and provide this documentation with the notification.
- The adequately wet, no visible emissions and removal of asbestos-containing waste material provisions of the NESHAP must be maintained at all times.
Need assistance?
The USEPA publication Asbestos/NESHAP Demolition Decision Tree (June 1994) can help with ensuring compliance during demolitions.
Contact Jeremy Howe, Supervisor, Technical Programs Unit, Air Quality Division, at 231-878-6687 or HoweJ1@Michigan.gov or your Regional Asbestos Staff with questions.
Visit Michigan.gov/Air and choose "Asbestos NESHAP" for more information.
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