Asbestos-Suspect Materials by Location in a House

Why this matters

Most trades meet asbestos not as a material they were hired to touch but as something in the way: the tile under the toilet, the texture on the ceiling where the fan goes, the siding the line set has to pass through. A tech who knows where in a house these materials were used can look at a work order and see, before arriving, which of the day's cuts and drills land in suspect material. That turns a mid-job stop into a line on the quote. This card is the map; the rule for what to do with what you find is its own card. See related: Recognize, Record, Route: The Rule for Legacy Materials.

Two rules that frame the map

Presume until tested. No material on this map is asbestos-containing because it is on the map, and none is safe because it looks new or clean. Only a lab analysis of a sample settles it. Asbestos-containing material, for federal purposes, means more than 1 percent asbestos by the lab method. Until a result says otherwise, treat a suspect material as if it contains asbestos.

A date is a likelihood, not a guarantee. Use of asbestos in building products fell off steeply through the 1970s and 1980s, but the United States never had a clean, complete ban on asbestos in building products, and old stock was installed after it stopped being made. Pre-1981 construction is the high-likelihood band; a later house is not proof of absence. The era timeline belongs to another card. See related: Dating a House by What You Find in It.

Which law reaches whom

Get this right before you tell a customer or an employee anything about rules.

• Federal NESHAP (the Clean Air Act asbestos rule, 40 CFR Part 61 Subpart M) governs demolition and renovation notifications and work practices, but it generally excludes residential buildings with four or fewer dwelling units. That is the exclusion people mean when they say "homes are exempt."
• States often reach further. Many state asbestos programs license abatement contractors and inspectors and apply rules to single-family homes that the federal NESHAP does not; some require a licensed inspection before any renovation that disturbs suspect material. California and New York, for instance, run their own asbestos programs with requirements beyond the federal floor, and your state's environmental or health agency says what applies to you.
• OSHA reaches your employees in every building. 29 CFR 1926.1101 covers construction work, including renovation, repair and maintenance, that disturbs asbestos or presumed asbestos-containing material. It does not care that the building is a single-family home. It presumes thermal system insulation and surfacing material in buildings constructed no later than 1980 to be asbestos-containing, and it directs that asphalt and vinyl flooring installed no later than 1980 be treated the same way, unless the employer shows otherwise.

So "homes are exempt" is a statement about one federal rule, not about your crew. This is not legal advice; your state program and your own counsel answer the specific question.

The map

      HOUSE SECTION: WHERE SUSPECT MATERIALS SIT

   roof:   shingles, felt, flashing cement
   ------------------------------------------
   attic:  vermiculite fill, duct wrap,
           flue pipe through attic
   ------------------------------------------
   living: textured ceiling, joint compound,
           plaster, window putty, caulk
   ------------------------------------------
   kitchen/bath: 9x9 tile, black mastic,
           sheet vinyl backing, sink coating
   ------------------------------------------
   basement: pipe and boiler lagging, duct
           tape and wrap, furnace gaskets,
           cement flue pipe, floor tile
   ------------------------------------------
   exterior walls: cement siding shingles,
           cement panels, putty, caulk

What each zone holds, and the act that disturbs it:

Basement and mechanical room. Pipe lagging (white or gray corrugated paper, chalky preformed sections, hard plaster-like elbows), boiler jackets, the wrap and seam tape on warm-air ducts, rope and gaskets at furnace and boiler doors, cement flue pipe from a water heater or furnace to the chimney, and floor tile. Disturbed by: cutting pipe, removing a boiler or furnace, cutting ducts, pulling a flue connector. See related: Gravity Furnaces and the Octopus in the Basement; Cement Flue Pipe and Cement Board Products.

Attic. Vermiculite loose fill (pebble-like, gray-brown to gold), wrap on ducts running through the attic, and flue or vent pipe. Disturbed by: walking on the joists, pulling cable, setting equipment, cutting a ceiling hole from below. See related: Vermiculite Attic Insulation and the Do-Not-Disturb Rule.

Living areas. Textured or "popcorn" ceilings, older joint compound and some wall texture, some plaster, window glazing putty, and caulk. Disturbed by: drilling or cutting a ceiling or wall, scraping texture, sanding patches, removing a window sash. See related: Textured Ceilings and Old Joint Compound.

Kitchens, baths and other floors. 9-by-9 inch tile, black cutback adhesive under tile, the backing layer of some old sheet vinyl, and undercoating on some steel sinks. Disturbed by: pulling a toilet flange, scraping or sanding a floor, cutting floor for a register or drain, removing a dishwasher over old flooring. See related: Nine-Inch Floor Tile and Black Mastic.

Exterior. Cement siding shingles and panels, cement roofing shingles, older roofing felts and flashing cements, and window putty and caulk. Disturbed by: drilling or cutting siding for a penetration, removing shingles, tearing off old roofing, scraping or sanding window frames.

Appliances and equipment. Gaskets and insulation inside some old ranges, dryers and heaters, and old heat-shield boards behind stoves. Disturbed by: opening and dismantling them, and by breaking a heat shield to remove it.

Map the job, not the house

The map is only useful when you lay the day's work over it. For each task on the work order, ask two questions: what material does this cut, drill, pull or scrape through, and is that material on the map for a house of this age? The answer is a list of intersections, and each one either gets planned around, gets tested first, or gets scoped out.

The worked example: three small tasks in a 1962 house

The work order. A handyman shop quotes three tasks in a 1962 ranch house: replace a dishwasher, add a range hood ducted through the exterior wall, and install a bathroom exhaust fan.

Laying each task over the map.

• Dishwasher. The old unit sits on a floor of 9-by-9 tile that runs under the cabinets. Sliding the old unit out over the tile is not a disturbance. Prying up loose tile at the opening, or scraping adhesive to level the floor for the new unit, would be. Intersection: floor tile and mastic, only if the floor has to be worked.
• Range hood. A 7-inch duct passes through the kitchen wall and out through the siding. The interior wall is plaster or drywall with joint compound; the exterior is cement siding shingles. Intersections: wall finish (cutting the interior hole) and cement siding (cutting the exterior hole).
• Bath fan. The bath ceiling is textured. A new fan means a ceiling cut and attic access. Intersections: textured ceiling, and whatever insulation is in the attic over the bath.

Counting what the map produced. Three tasks, five intersections: one for the dishwasher (floor tile and mastic), two for the range hood (wall finish, cement siding), two for the bath fan (textured ceiling, attic insulation). Of the five, one (the floor) only becomes a disturbance if the floor has to be worked; the other four are disturbances the task cannot avoid.

What the estimator does with that.

• Dishwasher: quoted as-is, with a written condition: if the floor at the opening needs leveling or tile removal, work stops for a test. The new unit is chosen and shimmed to suit the existing floor.
• Range hood: the estimator proposes recirculating rather than ducted, which removes both wall intersections, and prices the ducted option as conditional on testing the siding and wall finish. The owner chooses to test; that adds one inspector visit before the hood job.
• Bath fan: the estimator looks into the attic from the hatch with a flashlight, without entering, and sees ordinary fiberglass batts, not loose fill. The textured ceiling stays an intersection. Testing the ceiling texture is added to the same inspector visit as the wall and siding.

Re-checking the count against the plan. Five intersections. One handled by a stop condition (floor). Three sent to a single inspector visit (wall finish, siding, ceiling texture). One cleared by observation (attic insulation is batts, not vermiculite). One plus three plus one is five, so every intersection has an owner on the quote.

What changes the answer. A house built in 1995 would still carry the same intersections on paper, but the likelihood behind each is lower and an owner may reasonably decline testing for a single small drill hole; that is the owner's decision with the facts, and your employees' protection does not change with it. A positive result on the ceiling texture would change the bath fan from "cut a hole" to "a licensed contractor makes the opening under controls first," or to replacing the fan within the old housing without enlarging the ceiling opening. In a state that requires a licensed inspection before renovation of suspect material in a home, the inspector visit is not optional for any of the three.

The failure mode. The shop that quotes from the work order without the map finds the intersections on the day, one at a time, with the drill in hand. Each one becomes a stop, a reschedule and an awkward conversation, and the job that was three small tasks costs three visits.

How to verify you got this right

Every task on the work order has its intersections listed, including the ones you decided were not disturbances and why.

Every intersection has an owner on the quote: planned around, tested first, scoped as a stop condition, or cleared by what you actually saw.

Observation and assumption are labeled differently. "Attic insulation appears to be fiberglass batts, seen from hatch" is an observation. "Siding is probably fine" is not on the record at all.

Nothing on the map was sampled by your crew. Sampling is the inspector's work. See related: How to Get a Suspect Material Tested Without Becoming the Sampler.

References

• 29 CFR 1926.1101, OSHA construction asbestos standard, for presumed asbestos-containing material and employer duties.
• 40 CFR Part 61 Subpart M, the asbestos NESHAP, including its residential exclusion.
• Your state's asbestos program for inspection and licensing rules in single-family homes.
• See related: Asbestos + Lead Paint Safety Reference; Job Site Asbestos Discovery Stop Work Protocol.
• See related: Recognize, Record, Route: The Rule for Legacy Materials.