Asbestos Compliance Basics
Asbestos requirements can be difficult to understand because different regulations use different terms and may apply based on the material, building type, work activity, employee exposure, condition of the material, and jurisdiction.
This section explains the fundamental terms you will encounter throughout the Asbestos Compliance Basics.
What is asbestos?
Asbestos is the name given to a group of naturally occurring fibrous minerals. OSHA's construction standard identifies asbestos as including chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, and actinolite asbestos.
Because asbestos fibers are strong, heat resistant, and durable, asbestos was historically incorporated into many building materials and manufactured products, including insulation, floor tile, roofing products, cement products, fireproofing materials, gaskets, coatings, and other construction materials.
The presence of asbestos in a building does not automatically mean that people are being exposed. The primary concern occurs when asbestos-containing material is damaged or disturbed and fibers become airborne where they can be inhaled.
Exposure to asbestos is associated with serious diseases, including lung cancer, mesothelioma, and asbestosis, and asbestos-related disease may develop many years after exposure.
What is asbestos-containing material (ACM)?
Under OSHA's construction asbestos standard, Asbestos-Containing Material (ACM) means:
Any material containing more than 1 percent asbestos.
Finding ACM does not automatically tell you exactly how that material must be handled.
Additional factors may need to be considered, including:
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Whether the material is friable or nonfriable
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The condition of the material
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What type of material it is
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Whether it will remain undisturbed
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Whether it will be removed, cut, sanded, ground, drilled, demolished, or otherwise disturbed
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The quantity involved
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Whether employees will perform the work
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The type of building or facility
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EPA, OSHA, state, and local requirements
ACM identifies asbestos content. It does not, by itself, answer every regulatory question about the material.
What does greater than 1% asbestos mean?
A material containing more than 1% asbestos meets OSHA's definition of Asbestos-Containing Material (ACM).
This percentage is important because many federal asbestos requirements use the greater-than-1% definition when determining whether a material is ACM.
However:
Greater than 1% does not automatically mean the material must immediately be removed.
The regulatory significance depends on what is happening to the material.
For example, an intact asbestos-containing floor tile that will remain undisturbed presents a very different situation from asbestos-containing material that will be aggressively removed during demolition.
EPA likewise distinguishes among friable ACM, Category I nonfriable ACM, Category II nonfriable ACM, and Regulated Asbestos-Containing Material (RACM) under the Asbestos NESHAP.
The percentage is therefore one important part of the evaluation—not the entire evaluation.
What does less than 1% asbestos mean?
A laboratory result reported as less than 1% asbestos means asbestos was identified in the material, but the reported concentration is below OSHA's greater-than-1% definition of ACM.
It does not mean that asbestos was not detected.
This distinction is particularly important for worker protection.
OSHA has specifically stated that it does not recognize 1% asbestos as a safe concentration. OSHA also recognizes that disturbing materials containing less than 1% asbestos may produce airborne asbestos concentrations exceeding occupational exposure limits.
Accordingly:
Less than 1% asbestos is not the same thing as No Asbestos Detected.
Certain enhanced asbestos requirements are triggered when materials contain more than 1%, but employers may still have obligations relating to employee asbestos exposure when materials containing less than 1% are disturbed.
For EPA NESHAP determinations, analytical methodology can also become important at low asbestos concentrations. The NESHAP regulatory framework includes point-count verification requirements for certain determinations reported below 10% using methods other than point counting.
The laboratory result, analytical method, work activity, and applicable regulation all matter.
Does “less than 1% asbestos” mean the material is asbestos-free?
No.
If a qualified laboratory identifies asbestos and reports the result as:
Chrysotile <1%
or another asbestos fiber at less than 1%, asbestos was detected in that sample.
It should not be described as:
No Asbestos Detected (NAD) Non Detect (ND)
simply because the concentration is below 1%.
The greater-than-1% threshold is a regulatory definition used for ACM. OSHA has specifically explained that the 1% level is not a health-based determination that concentrations below 1% are safe.
Disturbance of material containing less than 1% asbestos can still potentially generate airborne fibers, depending on factors such as the material, condition, work method, and intensity of disturbance.
Less than 1% means less than 1%. It does not mean zero.
What is Presumed Asbestos-Containing Material (PACM)?
Under OSHA's construction asbestos standard, Presumed Asbestos-Containing Material (PACM) specifically means:
Thermal system insulation and surfacing material found in buildings constructed no later than 1980.
Examples may include certain:
Thermal System Insulation
Pipe insulation, boiler insulation, fitting insulation, duct insulation, and other materials used to control heat loss or gain.
Surfacing Materials
Sprayed-on or troweled-on fireproofing, acoustical material, decorative surfacing, and similar applied materials.
PACM can be rebutted when the requirements of the OSHA standard for demonstrating that the material is not asbestos-containing are satisfied.
It is important to understand that:
PACM is not simply another word for every old or suspicious building material.
OSHA gives PACM a specific regulatory meaning.
OSHA also establishes a separate presumption involving certain asphalt and vinyl flooring installed no later than 1980 unless its asbestos-free status is established in accordance with the standard.
What is friable asbestos-containing material?
Under the EPA Asbestos NESHAP, friable asbestos material generally means material containing more than 1% asbestos that, when dry, can be:
Crumbled, pulverized, or reduced to powder by hand pressure.
Friability is important because materials that readily crumble can more easily release fibers when handled or disturbed.
Examples of materials that may be friable, depending on their composition and condition, include certain:
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Pipe and boiler insulation
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Sprayed-on fireproofing
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Acoustical surfacing
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Thermal system insulation
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Damaged plaster or surfacing materials
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Severely deteriorated asbestos-containing materials
A material that was originally nonfriable can also become friable through damage, deterioration, weathering, or aggressive disturbance.
Friability should therefore be evaluated based on the actual material and its condition, not simply its original product classification.
What is nonfriable asbestos-containing material?
Nonfriable ACM generally refers to material containing more than 1% asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Examples can include certain:
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Floor tile
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Sheet flooring
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Roofing products
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Gaskets
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Packings
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Cement board
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Transite siding
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Asbestos-cement products
However:
Nonfriable does not mean indestructible or incapable of releasing asbestos fibers.
Cutting, sanding, grinding, drilling, breaking, weathering, demolition, and other aggressive activities may damage nonfriable ACM and cause fiber release.
EPA's NESHAP therefore considers both the present condition of the material and what forces will act upon it during renovation or demolition.
What is RACM?
RACM means Regulated Asbestos-Containing Material under the EPA Asbestos NESHAP.
RACM includes:
Friable asbestos material;
Category I nonfriable ACM that has become friable;
Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; and
Category II nonfriable ACM that has a high probability of becoming, or has become, crumbled, pulverized, or reduced to powder by the forces expected during regulated demolition or renovation activities.
This distinction is extremely important.
ACM and RACM are not automatically interchangeable terms.
A material may be ACM because it contains more than 1% asbestos but its regulatory treatment under NESHAP may depend on its category, condition, and how it will be disturbed.
What are Category I and Category II nonfriable ACM?
EPA NESHAP divides certain nonfriable asbestos-containing materials into two categories.
Category I Nonfriable ACM
Category I includes asbestos-containing:
Packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos.
Depending upon its condition and how it is handled, Category I material may remain nonfriable or may become RACM.
For example, Category I material that will be sanded, ground, cut, or abraded can fall within the RACM definition.
Category II Nonfriable ACM
Category II includes other nonfriable ACM containing more than 1% asbestos that does not fall within the Category I definition and cannot be crumbled, pulverized, or reduced to powder by hand pressure when dry.
Examples can include certain asbestos-cement products such as:
Transite siding, asbestos-cement panels, shingles, and similar cementitious materials.
Category II material can become regulated when the forces expected during demolition or renovation have a high probability of causing the material to become crumbled, pulverized, or reduced to powder.
How the material will be disturbed matters.
What building materials commonly contain asbestos?
Asbestos was historically incorporated into many building products.
EPA and OSHA identify materials that have included asbestos such as:
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Pipe and boiler insulation
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Thermal system insulation
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Sprayed or troweled fireproofing
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Acoustical surfacing
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Floor tile
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Sheet flooring and backing
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Flooring mastics and adhesives
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Ceiling tile
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Roofing shingles and felts
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Siding shingles
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Asbestos-cement products
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Cement board and transite
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Textured coatings and patching compounds
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Drywall systems and certain joint compounds
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Gaskets and packings
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Heat-resistant materials
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Certain caulks and glazing compounds
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Other specialty construction materials
This is not a complete list.
Thousands of products and formulations have existed over time.
A material's appearance, trade name, color, or age should not be used as a substitute for proper identification and laboratory analysis when an asbestos determination is necessary.
Can asbestos be identified just by looking at a material?
No.
EPA states that you generally cannot determine whether a building material contains asbestos simply by looking at it.
A floor tile may look exactly like another floor tile that does not contain asbestos.
The same can be true for:
Drywall compounds, mastics, insulation, ceiling materials, roofing products, caulking, glazing, flooring systems, and many other building materials.
Color and appearance alone are not laboratory analysis.
When an asbestos determination is necessary, suspect material should be properly evaluated and, where appropriate, sampled by a qualified asbestos professional and analyzed by a qualified laboratory.
You cannot reliably see asbestos fibers with the naked eye and determine a material's asbestos content.
Does the age of a building determine whether asbestos is present?
No.
The construction date can provide useful information, but the age of a building alone does not establish whether a particular material contains asbestos.
OSHA does use specific dates for certain regulatory presumptions. For example, PACM includes thermal system insulation and surfacing material in buildings constructed no later than 1980.
But that does not mean:
“Anything built after 1980 is asbestos-free.”
Nor does it mean:
“Everything built before 1980 contains asbestos.”
A building may contain materials installed during different renovations, additions, repairs, roof replacements, flooring installations, mechanical upgrades, or previous remodeling projects.
For asbestos investigations:
Evaluate the material—not simply the birthday of the building.
Is asbestos banned in the United States?
The answer requires some historical context.
It is incorrect to assume that asbestos disappeared from the United States decades ago because it was completely banned.
EPA's 1989 Asbestos Ban and Phase-Out Rule attempted to prohibit many asbestos-containing products, but most of that rule was subsequently overturned by the courts. Certain product bans and restrictions remained in effect.
In March 2024, EPA finalized a rule prohibiting ongoing uses of chrysotile asbestos, the only form of asbestos then known to still be imported, processed, or distributed for use in the United States. The rule uses different phase-out deadlines depending on the particular use.
Most importantly for property owners:
The newer prohibition does not make asbestos already installed in millions of older buildings disappear.
EPA continues to evaluate and regulate legacy asbestos uses and associated disposal, including asbestos-containing materials remaining in existing buildings.
So when someone says:
“Asbestos was banned, so this building can't contain asbestos,”
that is not a reliable basis for an asbestos determination.
Does asbestos-containing material always have to be removed?
No.
The presence of asbestos does not automatically mean the material must immediately be removed.
EPA explains that asbestos-containing material that is in good condition and will not be disturbed is generally best left alone and properly managed.
Depending upon the building and circumstances, management options may include:
Leaving the material undisturbed, Operations and maintenance procedures, Repair, Encapsulation, Enclosure or Removal
The appropriate decision depends on factors such as the condition of the material, accessibility, occupancy, anticipated maintenance, renovation or demolition activities, and applicable regulatory requirements.
In some situations, improperly removing intact asbestos-containing material can create greater fiber release than properly managing it in place.
Finding asbestos and deciding what to do with asbestos are two separate questions.
When does asbestos become a potential exposure hazard?
Asbestos becomes a potential exposure concern when fibers are released into the air and can be inhaled.
EPA identifies disturbance and damage as major pathways for asbestos fibers to become airborne. Activities that may release fibers include:
Cutting, Drilling, Sanding, Grinding, Sawing, Scraping, Breaking, Removing, Demolishing
or otherwise disturbing asbestos-containing material.
The potential for fiber release can depend on:
Material type + condition + friability + work method + intensity of disturbance + environmental conditions.
An intact floor tile sitting undisturbed on a floor does not present the same potential for fiber release as the same material being aggressively sanded or mechanically ground.
This is one reason asbestos regulations focus heavily on work practices and controlling disturbance, rather than simply asking whether asbestos exists.
Who should collect asbestos bulk samples?
EPA recommends that asbestos samples be collected by a properly trained and accredited asbestos professional, rather than by an untrained property owner or worker. Improper sampling can disturb a material and unnecessarily release asbestos fibers.
For regulated schools and public and commercial buildings, EPA's Asbestos Model Accreditation Plan requires appropriately trained and accredited professionals for asbestos inspection work.
EPA has also clarified that asbestos workers and contractor/supervisors are not automatically qualified to conduct asbestos inspections merely because they possess worker or supervisor accreditation. Inspector accreditation is a separate discipline.
States may impose additional licensing, certification, accreditation, or sampling requirements.
For that reason:
The person collecting the sample should have the qualifications required for the building, jurisdiction, and purpose of the investigation.
What does “No Asbestos Detected” (NAD) Non Detect (ND) mean?
No Asbestos Detected (NAD) Non Detect (ND) generally means the laboratory did not identify asbestos in the particular sample analyzed using the laboratory's specified analytical method.
It does not automatically mean:
“This entire building is asbestos-free.”
A laboratory analyzes the sample submitted to it.
The usefulness of that result therefore depends on whether the inspector properly identified the material, homogeneous area, layers, locations, and sampling strategy.
For example, one negative floor-tile sample does not automatically characterize unrelated flooring elsewhere in a building.
Likewise, a negative sample collected from one wall system does not prove that concealed materials, additions, renovations, or different wall systems elsewhere are asbestos-free.
EPA emphasizes that the reliable way to determine whether a suspect material contains asbestos is through appropriate sampling and qualified laboratory analysis.
For reporting purposes, the most defensible statement is:
No asbestos was detected in the analyzed sample(s) representing the material or homogeneous area identified in the investigation.
Rather than:
“The building contains no asbestos.”