An Inside Job: Checking for Asbestos, Lead, Radon and Hazardous Materials
Most developers are familiar with the “outside” environmental compliance issues on a job site – testing for possible pollutants in the soil, groundwater and air. But some are surprised to learn that when there is an existing building on the site, they must also address the structure’s “indoor” environmental concerns – even if they plan to tear it down and build something new in its place.
Here, we outline the common steps taken to detect, quantify and report the presence of the four main environmental concerns that may be lingering within a building targeted for renovation or demolition: asbestos, lead, radon and hazardous materials.
Probably the most common misconception in the construction industry is that newer structures, those built after 1980, pose no asbestos risks.
In truth, some building materials used since then may have been manufactured with asbestos. There is no magic cutoff date to stop being concerned about asbestos.
An asbestos survey is required by the Environmental Protection Agency (EPA) in advance of any commercial or industrial building renovation or demolition. This is true regardless of when the building was constructed, or whether the project involves renovating a single room or demolishing the structure entirely.
A survey involves collecting samples for laboratory analysis from ceilings and walls (plaster or drywall), flooring (tile, sheet flooring, etc.), ceiling tiles (glued-on or suspended ceiling tiles), insulation associated with mechanical plumbing or heating systems, and many other interior and exterior building components.
In a pre-renovation survey, the scope of work is defined by the client’s project or needs. For example, in a renovation project that does not involve removing walls, but only involves replacement of flooring or ceiling materials, the survey activities may not include disturbing the walls of a space or area. A pre-demolition survey includes the interior and exterior of a building prior to demolition activities.
How a structure will be used is the major determinant of whether and what type of lead investigation is needed. If the building was constructed prior to 1978 and is being developed for multi-family housing, or to provide any child-related services, such as a preschool or day care facility, you may need to test for the presence of lead.
The first level of testing is the lead-based paint inspection, which locates any lead-based paint in a building. A hand-held device called an X-ray fluorescence spectrometer (XRF) is touched to every painted component, providing an instant read of its lead concentration. EPA guidelines determine when lead content exceeds an allowable threshold.
A lead-based paint risk assessment provides a more in-depth read on potential lead hazards. It builds on the lead inspection, gathering samples for lab analysis in any areas where lead paint has been disturbed, such as in dust collected inside the building and soil collected outside.
Both a lead-based paint inspection and a risk assessment can be performed in buildings constructed prior to 1978 that are intended for multi-occupant housing, or child-occupied enterprises.
However, just because a building is not slated for one of those purposes, don’t assume you’re in the clear when it comes to looking for lead. The safety of workers involved in renovation or demolition must also be considered. That’s the job of the U.S. Occupational Safety and Health Administration (OSHA). OSHA recommends a lead paint survey before beginning any industrial, commercial or municipal building project.
A lead paint survey is different from a lead-based paint inspection. OSHA does not consider XRF technology sensitive enough to fully capture the potential exposure risk for workers. Instead, a lead paint survey involves collecting paint samples and sending them to a laboratory for analysis.
A word about the City of Detroit
Considering both the age and condition of many of the current buildings and buildings targeted for redevelopment, city leaders enacted their own lead ordinance in 2010. Owners and developers of rental properties built before 1978 must now have a lead-based paint inspection and risk assessment performed to receive a Certificate of Compliance and Rental Registration from the City. Lead clearances and periodic follow-up assessments are required if lead-based paint is found.
Learn more about the City of Detroit’s Lead Ordinance here.
Radon is a colorless, odorless, tasteless and invisible gas produced by the decay of naturally occurring uranium in soil and water. Radon typically migrates into buildings through cracks or holes in the foundation. Once trapped inside, it can build up. While groundwater poses some exposure risk, the risk of inhaling radon in the air is much greater; it is the second leading cause of lung cancer in the U.S.
The primary factor driving whether radon testing is required in a commercial or residential development is the funding source for the project. For example, housing projects subsidized by federal agencies like the U.S. Department of Housing and Urban Development (HUD) or state agencies like the Michigan State Housing Development Authority (MSHDA) often specify that radon testing be performed in existing buildings or following renovation or new-build activities.
Radon testing utilizes several forms of short- and long-term testing devices. A common short-term device used is the activated charcoal test kit. This kit is positioned in the lowest occupied level of a structure for 2-3 days, then retrieved and sent to a lab for analysis. Specific closed building conditions are required for radon testing to ensure the devices are providing unbiased data.
Another common misconception is that all construction waste is created equal, and that anything and everything can be hauled away in the same dumpster.
In fact, a number of materials used in industrial, commercial and residential buildings may trigger special handling and disposal requirements prior to renovation or demolition activities.
Materials known as universal waste can include commercial fluorescent light bulbs that contain mercury vapor; fluorescent light ballasts which may contain PCBs; cans of paint with potential chemicals of environmental interest; containers of oil containing PCBs; smoke detectors with low levels of radioactive material; and outdated electronics containing heavy metals.
The process of identifying these types of materials begins with a hazardous materials survey, during which trained experts systematically identify and quantify universal waste for proper disposal.
Work with the experts.
PM Environmental is ready to assist in any way, from a single on-site test to total project management. Our services include the preparation of bidding specifications, management of the bidding process, oversight of removal activities, worker exposure air monitoring, and documentation of compliance with local, state and federal regulations. Our team of specialists includes certified industrial hygienists, licensed asbestos inspectors and technicians certified in asbestos fiber counting, and certified radon inspectors, as well as management planners, project designers and contractor supervisors.
Whatever the environmental challenge – inside or out – you can rely on PM Environmental.
PM Environmental Industrial Hygiene Services team members Jon M. Balsamo, Tyler Maraskine, and Richard Michalski contributed to this article.