Recordkeeping, Notification, and Reporting
Notification and recordkeeping questions test whether you can prove compliance after the work is done.
Notification
Michigan abatement notification goes to EGLE at least 10 working days before start and includes owner, contractor, location, dates, quantity, and work practices. Submit amendments if dates or scope change. Notification is not a permit and does not replace NESHAP notice.
Records
Maintain training and certification, medical surveillance, fit-test records, air-monitoring data, daily logs, waste shipment records, and clearance results. Federal NESHAP requires records for at least 2 years; OSHA exposure records are kept 30 years, and medical records for employment plus 30 years. Make records available to regulators on request.
Worked example
An EGLE inspector arrives after a school abatement and asks for the notification, daily pressure logs, personal air samples, waste shipment record, and clearance report. Missing pressure logs suggests the enclosure was not verified; missing WSR breaks the waste chain. Both are document violations even if the removal looked clean.
Traps
- Filing notification 10 calendar days ahead.
- Treating notification as a permit.
- Discarding records when the project closes.
- Failing to amend dates.
- No record of negative-pressure checks.