NH Asbestos Abatement cheat sheet

New Hampshire regulates asbestos abatement under state occupational health and environmental statutes administered by the NH Department of Environmental Services (NHDES) asbestos program; federal OSHA 29 CFR 1926.1101 and EPA NESHAP 40 CFR 61 Subpart M also apply, so the strictest applicable requirement governs.

A facility owner or operator must have a thorough inspection for asbestos, including bulk sampling by a qualified inspector, before any demolition or renovation that will disturb suspect material; presuming material is asbestos until sampling proves otherwise is the default rule.

Regulated asbestos-containing material (RACM) under NESHAP is material with more than 1 percent asbestos by area, or any material that will be crumbled, pulverized, or reduced to powder during handling; category I nonfriable (floor tile, roofing) and category II nonfriable (some cement products) are treated differently.

Notification: NHDES and the applicable EPA regional office require written notice of renovation or demolition at least 10 working days before work begins for projects involving threshold quantities of RACM; notice must be updated or cancelled if the schedule changes.

Class I work is removal of thermal system insulation and surfacing material (sprayed or troweled); Class II is removal of other asbestos-containing material such as floor tile, roofing, and siding; Class III is repair and maintenance likely to disturb asbestos; Class IV is maintenance and custodial work that contacts but does not significantly disturb ACM.

Training and certification tiers: abatement worker, contractor/supervisor, inspector, management planner, project designer, and in some states air sampling technician; refresher training is required annually to maintain certification, and workers must carry credentials on site.

Personal protective equipment and control: a half-mask or full-facepiece air-purifying respirator with P100 or HEPA filters for most abatement, supplied-air or powered air-purifying respirators for higher exposures; a negative-pressure enclosure with HEPA filtration, critical barriers, and decontamination unit with clean, shower, and dirty rooms.

Work practices: wet methods, amended water, HEPA vacuuming, sealed and labeled waste containers (6-mil or double-bagged poly), no dry sweeping or compressed air, and daily cleanup; clearance air sampling by an independent third party must meet the required fiber count before reoccupancy.

Waste handling: ACM waste is transported as asbestos waste with generator name, location, and quantity on the label; disposal at an approved landfill that accepts asbestos; keep manifests and disposal records for at least two years (longer for some state requirements).

Exposure limits and monitoring: OSHA permissible exposure limit is 0.1 fiber per cubic centimeter as an 8-hour time-weighted average, with an excursion limit of 1.0 f/cc over 30 minutes; initial exposure monitoring is required unless objective data show exposures stay below the PEL, and medical surveillance is required for workers above the PEL or in Class I work for 30 or more days per year.

Clearance criteria: visual inspection confirms no visible dust or debris, then air samples are collected inside the containment using aggressive or non-aggressive methods as the contract specifies; the PCM clearance threshold is typically 0.01 fibers per cubic centimeter, with TEM used when the project requires it.

A containment fails clearance if the fiber count exceeds the threshold or if visible residue remains; the contractor must reclean, re-wet, HEPA vacuum, and re-sample before the containment is taken down.

Independent oversight: the air monitor or third-party consultant who performs clearance sampling must not be employed by or under the control of the abatement contractor, to preserve independence of the result.

Recordkeeping: the contractor keeps training certificates, respirator fit-test records, medical surveillance clearances, exposure monitoring results, daily logs, waste manifests, and clearance reports; OSHA requires exposure records be kept for 30 years and medical records for the duration of employment plus 30 years.

Project designer responsibilities: the designer writes the abatement specification, selects engineering controls and work practices, and sets clearance and monitoring requirements before the contractor bids; the management planner interprets inspection findings and recommends response actions.

Emergency and unexpected situations: if unexpected RACM is discovered, stop work, isolate the area, notify the owner and NHDES, and amend the notification before resuming; do not proceed on the assumption that the original scope covers it.

Violation consequences: NHDES may issue notices of violation, administrative fines, stop-work orders, and require corrective action; knowing violations of NESHAP can carry criminal penalties, and falsified air samples or training certificates are treated as serious fraud.

Decision rules: if material is friable and will be disturbed, removal is generally required before demolition; if it is nonfriable and will remain undisturbed, it may be left in place with an operations and maintenance plan; if the project is below the RACM threshold, notification may still be required by state rule.

Contractor licensing: NH requires asbestos abatement contractors to be licensed by the state and to employ certified workers; verify current certification of every worker before allowing them into the containment, and keep a site roster with credential numbers.