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ADU Policy

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Asbestos Surveys

If you are replacing an existing structure that was built before 1980 asbestos testing is required for the building permit.

The majority of counties do not, at this time, require an additional lead based paint survey. Berkeley does require a lead survey before a permit is issued.

If asbestos is discovered, a DOSH registered contractor is required to do the removal of the asbestos containing materials that are identified in the survey. 

Regardless whether asbestos is discovered or not a 10 day notice to BAAQM is required because bearing walls are being removed.

3-5-7 Rule

3-5-7 Rule to determine how many asbestos bulk samples are necessary. It is determined by the type of material, when it was installed and how square footage of the area.

Our report will give you all these details which, if asbestos above 1% is found, will be necessary for an asbestos abatement contractor to give you a written bid for the work.

  1. Identify homogenous areas of suspect surfacing Asbestos Containing Building Material (ACM).
  2. Quantify the area (square footage) of each homogenous area of suspect material.
  3.  Apply the 3, 5, 7 Rule which indicates the minimum number of samples as follows:

 

<1000 square feet

3 Samples

 

>1000 square feet, but <5000 square feet

5 Samples

 

>5000 square feet

7 Samples

For example, the homogenous area of suspect ceiling plaster measuring 4000 ft² would need to have five samples collected. These minimum number of samples required by AHERA and recommended by the “Pink Book” were created to minimize errors due to lack of uniformity in the distribution of asbestos throughout the material and laboratory error.

The majority of counties do not, at this time, require an additional lead based paint survey. Berkeley does require a lead survey before a permit is issued.

If asbestos is discovered, a DOSH registered contractor is required to do the removal of the asbestos containing materials that are identified in the survey. 

Regardless whether asbestos is discovered or not a 10 day notice to BAAQM is required because bearing walls are being removed.

The majority of counties do not, at this time, require an additional lead based paint survey. Berkeley does require a lead survey before a permit is issued.

If asbestos is discovered, a DOSH registered contractor is required to do the removal of the asbestos containing materials that are identified in the survey. 

Regardless whether asbestos is discovered or not a 10 day notice to BAAQM is required because bearing walls are being removed.

Asbestos Inspector Requirements

  • SST – Site Surveillance Technician is licensed to take asbestos samples under the supervision of a CAC.
  • CAC- California Asbestos Consultant has a J-Card License That Is Current. This license requires an annual update. This looks similar to a driver’s license.

The Biggest Concerns

Surfacing materials are the biggest concern of the AHERA Regulation because of their friability and/or presence in public areas. The EPA funded the production of a guidance document for sampling friable asbestos-containing materials that was published in 1985. This was years prior to the AHERA regulation. This document was entitled: “Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials.” This document is often referred to as the “Pink Book.” Many of the recommended practices in this document were adopted by the California AHERA Final Rule(Title 8) as regulations. The main recommendation adopted by AHERA (and thus OSHA by reference) was the number of samples to be taken for surfacing materials.

The “Simplified Sampling Scheme for Friable Surfacing Materials” recommends that the inspector takes 9 samples for every homogeneous area of the suspect material. The AHERA regulation did not make this recommendation mandatory for schools, realizing the costs involved in taking that many samples.

In addition to the required number of samples for surfacing materials based on their area, the “Pink Book” recommends taking quality control samples. These samples are to check the consistency of the results obtained from a laboratory. The inspector can obtain a quality control sample by taking two samples immediately adjacent to each other of the same homogenous material. These are given unique sample numbers so the laboratory analysts cannot readily identify the quality control sample. Any major discrepancy between the actual sample and the quality control sample will require additional quality assurance procedures – even more samples of the same material. The major discrepancy example would be a result of less than 1% of the actual sample and a result of 50% on the quality control sample. EPA’s “Pink Book” recommends that the inspector takes at least 1 quality control sample per building or one per 20 samples, whichever is larger. Because it is a laboratory check on the asbestos content of the material, it should be done per homogenous area of surfacing material.

If lead-based paint is discovered, then the site will require lead soil clearance testing upon completion.

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