Whether you’re managing a commercial property, planning a renovation, or steering demolition of an older facility, knowing when to get an asbestos survey is crucial. With legacy building materials lurking in walls, ceilings or insulation, overlooking an asbestos survey can expose your team, your company and your tenants to serious health and liability risks. In this article, we’ll walk through why, when and how to conduct an asbestos survey, covering federal and selected state regulations (California and Oregon), types of surveys, and practical guidance tailored for a professional audience. You’ll leave with the clarity you need to decide: Should you get an asbestos survey for your project?
Should You Get an Asbestos Survey or Not?
At first glance, you might think “My building looks fine, do I really need an asbestos survey?” The short answer: very often, yes. If your project involves renovation, demolition or building-component disturbance, especially in buildings built before the mid-1980s, an asbestos survey isn’t just prudent, it’s frequently required.
Here are the key reasons you should opt for a survey:
- Risk management: Asbestos-containing materials (ACM) may be hidden, and disturbance without identification can release fibers, posing health hazards and regulatory liability.
- Regulatory compliance: Multiple laws require identification of asbestos prior to certain activities. Failing to comply can result in significant fines, legal exposure and reputational damage.
- Project planning: A survey gives you a clear scope of ACM presence, enabling accurate budgeting, scheduling, contractor selection and health & safety planning.
So, if you’re about to disturb building material — think: renovation, retrofit, conversion, demolition, then treat the question of “survey or not?” as already leaning toward “yes”.
Why Are Asbestos Surveys Required?
Why does the regulatory world care so much about asbestos surveys? Because asbestos exposure remains a proven health hazard. According to the Occupational Safety and Health Administration (OSHA), asbestos is a known human carcinogen that can cause lung cancer, mesothelioma and asbestosis — and symptoms may take many years to appear.
On the regulatory side:
- The Asbestos Hazard Emergency Response Act (AHERA) and related rules require inspections in schools and some buildings.
- The Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) mandates a “thorough inspection” before demolition or renovation of commercial/industrial buildings.
- OSHA’s standards (29 CFR 1910.1001 and 1926.1101) set exposure limits and define “presumed asbestos-containing materials” (PACM) in buildings built before 1980.
In short: performing a survey protects health, ensures regulatory compliance, and supports responsible project execution.
Federal Requirements for Asbestos Surveys
Below is a breakdown of the primary federal frameworks that apply.
The Occupational Safety and Health Administration (OSHA)
Under OSHA:
- The General Industry standard 29 CFR 1910.1001 applies to workplace exposures of employees in buildings and facilities. It defines asbestos, PACM, exposure limits etc.
- The Construction standard 29 CFR 1926.1101 applies to work involving demolition, renovation, repair of structures containing asbestos. It specifies that employers must ensure exposures don’t exceed 0.1 fibers per cubic centimeter (8-hour TWA) and 1.0 fibers per cc over 30 minutes.
- OSHA has interpreted its rules to say that a full “comprehensive building survey” isn’t strictly required by its standards; instead it uses the concept of PACM and focuses on work practices for known or likely asbestos.
Thus, from an OSHA perspective, if your work is going to disturb materials that are likely to contain asbestos (especially in a facility built before 1980), you need to assess exposure risk and ensure proper controls. A survey becomes a key tool to do that.
The Asbestos Hazard Emergency Response Act (AHERA)
AHERA (under the Toxic Substances Control Act (TSCA) Title II) requires schools and educational agencies to inspect buildings for asbestos-containing building materials (ACBM), prepare management plans, and respond accordingly.
For many professional building managers, especially those working with institutional buildings, schools or public facilities, AHERA-type inspection models inform standard practice even for non-school buildings.
The Environmental Protection Agency (EPA)
The Environmental Protection Agency lists asbestos laws and regulations including AHERA, TSCA, NESHAP and others.
Specifically:
- The Asbestos NESHAP (40 CFR Part 61, Subpart M) mandates a “thorough inspection” for asbestos in all demolition/renovation of institutional, commercial or industrial buildings (regardless of building age) before beginning work.
- EPA’s Worker Protection Rule extends worker protection to state/local employees not covered by OSHA.
In short: at the federal level, surveying for asbestos before disturbance of suspect materials is a core requirement for renovation/demolition work, especially in regulated facilities.
What Do California Asbestos Regulations Require?
California has a more layered regulatory environment, between state-level occupational safety rules and local air-quality agency rules. Here are some key ones.
San Diego APCD Rule 1206
Under the San Diego County Air Pollution Control District Rule 1206:
- It applies to “facilities” (institutional, commercial, industrial or residential with 5 or more units) undergoing renovation or demolition.
- It requires a facility survey prior to commencing renovation or demolition, regardless of the age of the building. Suspect materials to be removed, stripped or disturbed must be sampled and analysed or assumed to be asbestos-containing.
- There’s a threshold: if the disturbance will affect ≥ 100 square feet of regulated asbestos-containing material (RACM) in any consecutive 365-day period (or 20 cubic feet where area cannot be measured) then the rule applies.
- Single-family homes with four or fewer dwelling units, or small projects under the threshold, are exempt from full survey/notification.
SCAQMD Rule 1403 (Greater Los Angeles Area)
The South Coast Air Quality Management District Rule 1403 requires that:
- For building demolition/renovation, a formal asbestos survey (by a certified asbestos consultant) must be conducted documenting materials that will be disturbed, and included in the survey report.
- The survey report must include scope, inspection findings, and certified declarations of which materials do not contain asbestos as well as those that do.
Sacramento & Bay Area Asbestos Regulations
In California’s Sacramento region and Bay Area, regional air-quality districts follow similar models: requiring the pre- disturbance survey, notification to the district, and retention of survey reports. (Although detailed rules vary by district, the common theme is: before renovation/demolition, survey and report.)
What Do Oregon Asbestos Regulations Require?
In Oregon, the regulations are clear and include specific survey and reporting requirements.
Reporting Requirements
Under the Oregon Department of Environmental Quality (DEQ) guidelines:
- Commercial buildings (regardless of construction date) and residential buildings built before Jan 1, 2004 must have an asbestos survey by an accredited inspector before demolition or renovation.
- The survey report must be kept on-site during the activity and be available to DEQ upon request.
- The survey must sample at least one bulk sample for each homogeneous material suspected of containing asbestos; for sprayed/troweled surfacing materials at least three random samples per homogeneous area.
- Rule OAR 340-248-0270 sets out detailed survey content requirements.
- In certain cases (owner-occupant single-family doing their own work) exemptions apply, but only under specified conditions.
What Does the Survey Involve?
The survey typically involves:
- A visual inspection of the building or the part where disturbance will occur
- Bulk sampling of suspected asbestos-containing materials
- Lab analysis of samples (with accredited lab)
- A written survey report including: date of inspection; inspector credentials; building description; construction date; sampling results; material locations; quantity; condition; friability; recommendations etc.
Who Can Perform the Survey?
In Oregon and similar states, only accredited asbestos inspectors/consultants (licensed by the state) may perform the survey and issue the formal report. The owner/operator still bears responsibility to confirm that the survey meets requirements.
Understanding When an Asbestos Survey is Required
Let’s unpack the trigger points for when you need to schedule an asbestos survey.
When Are Asbestos Surveys Required?
While the exact thresholds differ by jurisdiction, the common scenarios are:
- Renovation of any part of a building that will disturb materials (insulation, pipes, floor tiles, ceiling tiles, fireproofing coatings etc.).
- Demolition of a building (or part thereof), especially where load-bearing elements are removed or the structure is wrecked.
- Building conversion or change of use where significant structural work will occur.
- Projects in older buildings, especially those built before ~1980–1985 (when asbestos use was common).
- Even in newer buildings if suspect materials or hidden debris are present.
For example, Oregon rules require the survey before renovation/demolition in any commercial building regardless of age. California’s Rule 1206 mandates a facility survey “regardless of the age of the facility” when the threshold of material disturbance is met.
Does My Project Require an Asbestos Survey?
Ask the following questions:
- Is this a renovation or demolition?
- Even a targeted renovation (e.g., removing a wall, replacing piping) may qualify.
- Even a targeted renovation (e.g., removing a wall, replacing piping) may qualify.
- Will materials be disturbed, removed or altered?
- If yes, then suspect ACM — likely need a survey.
- If yes, then suspect ACM — likely need a survey.
- How old is the building or facility component?
- If built before ~1980–1985 (in many jurisdictions) — higher chance ACM is present.
- If built before ~1980–1985 (in many jurisdictions) — higher chance ACM is present.
- What is the scope of disturbance?
- Does it exceed thresholds (e.g., 100 ft² or 20 ft³ in some California districts)? If yes, stricter rules apply.
- Does it exceed thresholds (e.g., 100 ft² or 20 ft³ in some California districts)? If yes, stricter rules apply.
- Is the building regulated as a “facility” under local air-quality rules?
- E.g., commercial, institutional, residential with >4 units etc. If yes, a higher likelihood survey is required.
- E.g., commercial, institutional, residential with >4 units etc. If yes, a higher likelihood survey is required.
- Are local or state rules more stringent than federal?
- Yes, always review local district rules (such as APCD, SCAQMD).
- Yes, always review local district rules (such as APCD, SCAQMD).
If you answered “yes” to most of these questions, you likely need an asbestos survey before proceeding.
Types of Asbestos Surveys
There are two major types of surveys commonly used in professional practice.
Management Asbestos Survey
A management survey is typically conducted for ongoing operations and maintenance — not necessarily tied to imminent demolition or major renovation. It’s designed to locate, as far as reasonably possible, ACM in the building, assess condition, and help manage the materials in place.
What Properties Need a Management Asbestos Survey?
- Occupied commercial buildings, schools or multi-tenant offices where materials may be disturbed by maintenance.
- Buildings with known ACM but still in use — where removal is not yet planned but safety/monitoring is needed.
- Buildings subject to ongoing inspection or regulatory oversight (e.g., schools under AHERA).
While a management survey can satisfy certain regulatory requirements, most demolition/renovation rules prefer (or require) the more intensive “refurbishment/demolition” survey.
Refurbishment and Demolition Asbestos Survey
Also called a pre-demolition or pre-renovation survey — this is more comprehensive. It focuses on the exact building or portion to be disturbed, identifies all ACM that will be removed or disturbed, quantifies it, assesses condition, friability, and often produces a detailed report required by air-quality agencies.
What Properties Need a Refurbishment and Demolition Asbestos Survey?
- Any building undergoing demolition (whole or part) or major renovation where ACM disturbance is expected.
- Institutional/commercial/industrial buildings subject to NESHAP, state or local demolition rules.
- Projects where local air-quality district rules require survey and notification before work begins (e.g., California’s Rule 1206, SCAQMD Rule 1403).
Given the higher stakes (material disturbance, fiber release risk, regulatory scrutiny), the refurbishment/demolition survey is critical for large-scale works.
Conclusion
In professional facility-management practice, deciding when to get an asbestos survey isn’t optional, it’s a fundamental step in responsible project planning. Whether you’re in California, Oregon, or elsewhere, if your building work involves disturbance of materials in older or multi-tenant/regulated structures, you should assume a survey will be required. The cost of skipping it, in terms of health risk, regulatory fines and reputational damage, typically outweighs the investment in proper inspection and documentation.
By engaging certified professionals, understanding local thresholds (such as 100 ft² in California), keeping survey reports on-site, and integrating the survey into your project timeline, you enhance safety, simplify compliance and support efficient project execution.
Are you planning a specific project where you want to evaluate whether a survey is required, I can help you assess the triggers and timeline for that.
FAQs
Q1: Do I always need a full building asbestos survey?
A: Not always. Some rules recognize exemptions (e.g., small residential work under certain square-foot thresholds). But you should never assume exemption without reviewing the local rules. For example, under SDAPCD Rule 1206, remodeling less than 100 sq ft of material in a single-family home may be exempt.
Q2: Can I just assume materials contain asbestos instead of sampling?
A: In some jurisdictions you can assume suspect materials are ACM (and manage/treat accordingly) rather than sampling. But many regulations require sampling or certified survey documentation prior to issuing demolition/renovation notifications. For example, SCAQMD Rule 1403 insists on a certified asbestos consultant survey.
Q3: Who is qualified to perform an asbestos survey?
A: Typically an accredited or certified asbestos inspector/consultant per state/local rules. For example, Oregon requires an accredited inspector to perform the survey.
Q4: What’s the typical lead time for scheduling a survey?
A: As early as possible, ideally before your design phase or permit application. Many local air-quality districts require notification days in advance (e.g., 10 working days under some California rules). Q5: If the building was built after 2000, am I safe to skip a survey?
A: Not automatically. Some jurisdictions (for example California Rule 1206) require a facility survey regardless of age when thresholds are met.