Asbestos Roof Removal: What the Rules Require

Roofing is one of the few materials OSHA gives two separate compliance routes. The standard roofing work practices sit at 29 CFR 1926.1101(g)(8)(ii), and an alternative route for certain intact materials sits at paragraph (g)(11) of the same section.

Which route applies is not a preference. If an employer does not comply with all provisions of (g)(11), or if during the course of the job the roofing does not remain intact, the provisions of paragraph (g)(8) apply instead.

No federal body publishes composition percentages for roofing products, so none appear here. The regulatory line is one percent asbestos under 40 CFR 61.141, determined by polarized light microscopy at appendix E, subpart E, 40 CFR part 763, section 1. Every figure below names the rule that carries it.

Removal of roofing and siding shingles is Class II asbestos work under 29 CFR 1926.1101. The asbestos shingles guide covers the material itself and how EPA categorizes it. Which route a job runs under is worth asking about before it starts.

How Roofing Material Is Classified

The category split for roofing runs through EPA's interpretive rule. Appendix A to subpart M of 40 CFR part 61 places asphalt roofing products in Category I nonfriable asbestos-containing material, and asbestos-cement shingles and tiles in Category II. That appendix is an interpretive rule, so it states EPA's reading of how the categories apply to roofs specifically.

The same appendix explains the consequence of that split. Category II material is more likely to become friable when damaged than Category I material, which is why the two are handled differently once work begins. That difference in likelihood is the reason the two categories are not handled the same way once work begins.

Both are nonfriable classes. The term that triggers the federal requirements is regulated asbestos-containing material. At 40 CFR 61.141 that reaches Category I material which will be or has been subjected to sanding, grinding, cutting, or abrading, and Category II material likely to be reduced to powder by the forces expected during demolition or renovation.

What is on a specific roof is a laboratory question. Generally you cannot tell whether a material contains asbestos simply by looking at it, EPA says, unless it is labeled, and if in doubt the instruction is to treat it as asbestos-containing and leave it alone. Format, color, and era shift the odds of a positive result and settle nothing.

Some controls apply to every asbestos operation regardless of exposure level. 29 CFR 1926.1101(g)(1) requires HEPA-filtered vacuum cleaners for debris and dust, wet methods or wetting agents during handling and cleanup, and prompt disposal of waste in leak-tight containers. The asbestos remediation cost guide covers what those controls do to a project's scope.

The Standard Roofing Work Practices

The standard route sets practices written specifically for roofs. Under 29 CFR 1926.1101(g)(8)(ii)(A), roofing material shall be removed in an intact state to the extent feasible.

Wetting attaches to whatever is not intact. Wet methods must be used to remove roofing materials that are not intact, or that will be rendered not intact during removal, unless wet methods are not feasible or will create safety hazards. Feasibility is the operative word, and it is assessed on the job rather than assumed in advance.

Cutting equipment carries its own requirement. Cutting machines shall be continuously misted during use, per (g)(8)(ii)(C), unless a competent person determines that misting substantially decreases worker safety.

Power cutting of built-up roofs is addressed in detail. Where a power roof cutter is used on asbestos-containing roofing felts with an aggregate surface, all dust from the cutting operation must be collected by a HEPA dust collector or HEPA vacuumed along the cut line. A smooth-surface variant permits careful wiping of still-wet dust and debris instead, which is then immediately bagged or placed in covered containers. Misting is a continuous requirement during use rather than a step at the start.

The alternative route is narrower than it first appears, and its scope is defined by material. Paragraph (g)(11) covers installing, removing, repairing, or maintaining intact pipeline asphaltic wrap, or roof flashings which contain asbestos fibers encapsulated or coated by bituminous or resinous compounds.

The Alternative Route for Intact Material

Respirator requirements follow the class and the condition of the product. Under 29 CFR 1926.1101(h)(1), respirators are required for Class II work when material is not removed in a substantially intact state. They are also required for Class II and III work not performed using wet methods, and where no negative exposure assessment has been conducted.

An employer who complies with all provisions of that paragraph is deemed to be in compliance with the section. That is the benefit on offer, and it is conditional on every one of the requirements being met. Reading a scope against those triggers shows whether respiratory protection was priced into the job at all.

The first condition is an inspection with a finding attached. Before work begins and as needed during the job, a competent person must inspect the worksite and determine that the roofing is intact and will likely remain intact. That person must be capable of identifying asbestos hazards and selecting the appropriate control strategy, with authority to take prompt corrective measures. Training under that paragraph is specific to this kind of work rather than general awareness training.

The second is training. All employees performing work covered by (g)(11) must be trained in a program meeting the requirements of paragraph (k)(9)(viii) of the standard.

The method restrictions are what keep it whole. Under (g)(11)(iii), roofing covered by this route shall not be sanded, abraded, or ground, and manual methods which do not render the material non-intact shall be used. Manual removal is therefore the assumed approach under this route, not an option within it.

What Happens When Material Stops Being Intact

Getting product off the roof has its own rule. Under (g)(11)(iv), anything removed from a roof shall not be dropped or thrown to the ground, and unless carried or passed down by hand it must be lowered via covered, dust-tight chute, crane, or hoist.

There is also a clock on it. All such material must be removed from the roof as soon as practicable, and in any event no later than the end of the work shift. Together those provisions describe a job planned around keeping product whole from removal through disposal.

Two further provisions close the paragraph. Where roofing products labeled as containing asbestos are installed on non-residential roofs during (g)(11) operations, the employer must notify the building owner of their presence and location no later than the end of the job. Separately, all removal or disturbance of pipeline asphaltic wrap must be performed using wet methods.

NESHAP runs alongside the OSHA standard rather than inside it. Per 40 CFR 61.145(a) the requirements attach at 260 linear feet of regulated material on pipes, 160 square feet on other facility components, or 35 cubic feet where length or area could not be measured. The exception is written around roofing staying whole, which is also what the inspection is checking.

NESHAP, Notification, and the Residential Exclusion

Where they attach, the notice period is fixed. Written notice must be postmarked or delivered at least 10 working days before stripping or removal begins under 40 CFR 61.145(b), with a working day defined at 40 CFR 61.141 as Monday through Friday including holidays falling on those days. NESHAP and the OSHA standard apply independently, so satisfying one says nothing about the other.

Most houses sit outside that layer by definition. The facility definition at 40 CFR 61.141 excludes residential buildings having four or fewer dwelling units, which exempts the owner from notification and work-practice requirements.

That exclusion is frequently over-read. It confers no permission, makes no finding about safety, and displaces no state or local requirement, and EPA notes that state and local agencies may have more stringent standards than the federal government.

Exposure limits sit behind all of it. 29 CFR 1926.1101(c) bars exposing any employee to airborne asbestos above 0.1 fiber per cubic centimeter as an eight-hour time-weighted average, with an excursion limit of 1.0 fiber per cubic centimeter averaged over thirty minutes. A working day is a defined term, so the ten-day window is longer than two calendar weeks in most months.

Sampling is professional work under EPA's guidance. A trained and accredited professional should take samples, EPA says, because a professional knows what to look for and because there may be an increased health risk if fibers are released.

How the Material Is Confirmed

EPA's position on doing it yourself admits no exception. Taking samples yourself is not recommended, per EPA, and sampling done incorrectly can be more hazardous than leaving the material alone. EPA notes that state and local agencies may have more stringent standards than the federal government.

Roofing is not surfacing material, so no fixed sample count applies. Under 40 CFR 763.86(c) and (d), samples are collected in a manner sufficient to determine whether the material is asbestos-containing or not. The exemption belongs to the owner of the building rather than to any contractor working on it.

The analysis has published limits. Appendix E to subpart E of 40 CFR part 763 specifies polarized light microscopy with point counting, usable from 0 to 100 percent asbestos with a lower detection limit of less than 1 percent. Each visibly distinct roofing material is its own question for sampling purposes.

Disposal requirements apply to the waste regardless of which route the work followed. 40 CFR 61.150 requires the waste to be adequately wet, sealed in leak-tight containers while wet, labeled using the warning labels specified by OSHA at 29 CFR 1910.1001(j)(4), and deposited at a site operated in accordance with 40 CFR 61.154. Point counting is described in the appendix as a standard petrographic technique.

Adequately wet is defined so the requirement can be checked. It means sufficiently mixed or penetrated with liquid to prevent the release of particulates, per 40 CFR 61.141, and the same definition warns that the absence of visible emissions is not sufficient evidence of being adequately wet.

Disposal and Your Next Step

Ask a contractor which route the job is being run under. A scope that names either (g)(8)(ii) or (g)(11), and states how material will be lowered from the roof, is describing work that can be compared against the standard. Two checks are built into that definition, and both are observable on site.

Settle the question before any roof work begins. EPA's guidance is to have a home inspected by a trained and accredited professional when remodeling is planned, and the friable vs nonfriable asbestos guide covers the threshold that decides which requirements apply. That agency holds the current roster of accredited firms.

Keep the survey and the laboratory report with the property records. They name the material, its condition, and the result, which is what the next roofing project or sale will be planned against. The asbestos inspection cost guide covers what that survey should contain. A confirmed negative result closes the question for that material permanently.