Asbestos in Old Resilient Floors and Adhesive

Why this matters

Flooring crews uncover more asbestos than almost any other residential trade, because the materials sit in the layer they are hired to remove: old vinyl and asphalt tile, felt-backed sheet vinyl, and the black adhesive under both. Intact and left alone, these are low-risk. Sanded, ground, dry-scraped or swept, they put fibers in the air the crew breathes and the family lives in, and the fibers travel home on clothes. The decision that matters is made in the first five minutes after a carpet comes up, and this card is the library's owner of the flooring rules. Other flooring cards cite it rather than restating them.

The first action: stop disturbing it

When a resilient floor or a black adhesive of unknown age is exposed, the shop default is that it contains asbestos until a lab says otherwise. Before anything else:

• Stop any removal, scraping or cutting on it. Do not sand, dry sweep, dry scrape, bead blast or grind it, and do not run a floor machine over it.
• Leave broken pieces where they are; mist any loose debris lightly with water rather than sweeping it, and keep people and pets off the area.
• Shut down HVAC returns drawing from the room if debris is already loose.
• Tell the customer what was found and that the job pauses for testing.

The discovery steps, including what to say and who to call, are in Job Site Asbestos Discovery Stop Work Protocol.

Which flooring materials are suspect

Where else asbestos hides in a house, beyond the floor, is in Asbestos-Suspect Materials by Location in a House.

The rules, by layer

OSHA, for the shop's employees (construction). 29 CFR 1926.1101 governs asbestos work in construction, which includes flooring removal and renovation. Two parts reach every flooring shop:

• The presumption. Asphalt and vinyl flooring installed no later than 1980 must be treated as asbestos-containing unless the employer shows otherwise through testing or records. The shop default above goes further on purpose: an unknown install date is treated the same way, because nobody on a job can prove a floor's age by looking at it.
• The work practices. In substance, the standard's flooring practices forbid sanding asbestos-containing flooring, forbid dry sweeping, require wet methods when scraping residual adhesive or backing, prohibit ripping up resilient sheet flooring (it is removed by cutting, with the cut and the delamination wetted), call for tiles to come up intact where practical, and allow mechanical chipping only inside a negative-pressure enclosure. Removal is Class II asbestos work, with training, a competent person, and exposure monitoring or a negative exposure assessment. Check the current text of 1926.1101 for the exact requirements before any crew performs this work; this card does not authorize it.

EPA, for buildings (NESHAP). 40 CFR 61 Subpart M covers renovation and demolition of facilities: commercial and institutional buildings and apartment buildings with more than four units, not a stand-alone single-family house (which can be pulled in when it is part of a larger project). Intact resilient flooring is Category I nonfriable asbestos material. Sanding, grinding, cutting or abrading it makes it regulated asbestos material, and on a facility that brings notification and handling requirements keyed to quantity. On commercial work this is the abatement contractor's and the building owner's process, and the flooring crew does not touch the material until it has run.

States and localities. Many states license asbestos contractors and workers, some require a licensed abatement contractor for any removal in certain buildings, some require an asbestos survey before renovation, and some regulate who may take samples. Disposal rules and landfill acceptance are state and local. The shop rule is: where your state requires licensed abatement, removal goes to a licensed abatement contractor, full stop. Find your state program's requirements before the first job, not on the day you find tile.

Testing: one sample per material

• Who samples. Where the state requires an accredited inspector to take samples, that inspector does. Where it does not, the sampler wets the spot, takes a small piece of each material with minimal breakage, bags and labels each separately, and patches the hole, wearing a respirator under the shop's written respiratory protection program (29 CFR 1910.134, which 1926.1101's respirator provisions invoke) and disposable coveralls that come off and are bagged on site, so fibers do not ride home.
• One material, one sample. Tile, the adhesive under it, a sheet vinyl backing and a leveling layer are four materials. A single chunk that mixes tile and adhesive gives one blended result that answers nothing.
• The lab and the method. Use a lab accredited for bulk asbestos analysis (NVLAP). Polarized light microscopy (PLM) is the standard first test, but floor tile and mastic bind fibers in an organic matrix that can hide them, so a PLM "none detected" on these materials is commonly confirmed by transmission electron microscopy (TEM) before it is relied on.
• The threshold. EPA and OSHA define asbestos-containing material as more than 1 percent asbestos. Some states regulate material below 1 percent; check your state program.

What does not clear a floor

• Its look or feel. Asbestos and non-asbestos tile of the same era look identical, and so do the adhesives.
• The house's age. A newer house can carry an older floor laid from old stock, and a later addition can sit on an original slab with original tile under a newer floor.
• The customer's word or a sale disclosure. "We had it tested" means a lab report for that material, in the job file, or it means nothing.
• A result for one material. A clean tile result says nothing about the adhesive under it.
• A previous contractor having removed some of it. Black adhesive left on a slab after tile came up is still the adhesive, and still sampled.

Worked example: three layers in a 1962 kitchen

The customer wants luxury vinyl plank in a 150 sq ft kitchen. The old carpet comes up and shows felt-backed sheet vinyl; a corner lifted at the dishwasher shows 9 in tile under the sheet, and black adhesive under the tile.

Stop. Work stops. Nothing is pulled further; the lifted corner is misted and covered.

Sample. Three materials, three samples: sheet vinyl backing, 9 in tile, black adhesive. Say the results come back (illustrative): sheet backing, chrysotile 15 percent by PLM; tile, chrysotile 3 percent by PLM; adhesive, none detected by PLM, then chrysotile 2 percent by TEM. Every material is over 1 percent, so all three are asbestos-containing. The adhesive result shows why the TEM confirmation is ordered: by PLM alone, the adhesive would have been cleared and scraped.

Option A: cover in place. Leave all three layers, fasten a plywood underlayment over them and install the LVP on the underlayment (see related: How to Install Plywood Underlayment for Resilient Flooring). Nothing is removed, sanded or scraped. The fasteners puncture the old floor, so the job is planned so that no tile or sheet is cut, broken or lifted; any cut that cannot be avoided (a doorway, a toe kick) is asbestos work under the rules above, not a utility-knife task. Height check first: 1/4 in underlayment plus a plank of about 5 mm (about 3/16 in) raises the floor about 7/16 in. That height goes into the transition at the hall (see related: Transition Profiles and the Accessible Level Change), and it can trap the dishwasher under the counter, so the dishwasher opening is measured before the option is sold.

Option B: remove. Where the state requires licensed abatement, a licensed contractor removes all three layers, with clearance per that state's rules, and the flooring crew returns to a bare subfloor. Where the state allows a trained crew under OSHA Class II and the shop has that program, the same work practices apply.

The call. The dishwasher opening measures enough to clear 7/16 in and the hall transition works, so Option A goes ahead. The test results, the option chosen and the customer's written acknowledgment go in the job file, because the next contractor in that kitchen needs to know what is under the new floor.

What changes the answer

• The floor is coming up anyway (water damage, rotten subfloor, a structural repair underneath): covering in place is off the table, and removal goes to abatement.
• Commercial or multifamily building. NESHAP and often a state survey requirement apply; the owner's abatement process runs first.
• Lab results under 1 percent on every material, with TEM confirmation on the tile and adhesive. The material is not asbestos-containing under the federal definition (check any lower state threshold), and normal removal proceeds with dust control. Silica from grinding any concrete underneath is its own hazard: see Silica Dust in Flooring Work.

References

• OSHA 29 CFR 1926.1101, Asbestos (construction), including the flooring work practices and the presumption for flooring installed no later than 1980
• EPA 40 CFR 61 Subpart M, National Emission Standard for Asbestos (NESHAP)
• Your state's asbestos licensing, survey and disposal program
• See related: Nine-Inch Floor Tile and Black Mastic; Asbestos-Suspect Materials by Location in a House; Job Site Asbestos Discovery Stop Work Protocol; The Black Mastic Under the Old Carpet