ohioasbestosneshapnotificationdapcdemolitionrenovation

Filing an Ohio Asbestos Notification - A Practical Walkthrough

Filing an asbestos demolition or renovation notification with Ohio EPA is one of those tasks that seems straightforward until you actually do it for the first time. The form asks for specific information that requires a completed asbestos survey, and the fee structure has two separate regulatory triggers that can apply to the same project. Here is a practical walkthrough of the process.

When You Need to File

Two separate Ohio rules trigger notification requirements:

OAC 3745-20 (Ohio’s NESHAP rules):

  • All demolitions, regardless of whether ACM is present. This is the most commonly missed requirement. Even a clean survey does not eliminate the notification for demolition.
  • Renovations where the amount of regulated asbestos-containing material (RACM) exceeds 260 linear feet on pipes, 160 square feet on other components, or 35 cubic feet where length/area cannot be measured.

OAC 3745-22 (contractor licensing rules):

  • Any project where a licensed asbestos abatement contractor is performing abatement work exceeding 50 linear feet or 50 square feet of RACM.

A project can trigger notification under both rules simultaneously. Ohio uses a single combined form that covers both, but the fees are separate.

Before You Start the Form

You need these items ready before filing:

  1. Completed asbestos survey by a certified Asbestos Hazard Evaluation Specialist (AHES). The survey must identify all ACM and suspected ACM, quantify RACM in linear feet, square feet, and/or cubic feet, and classify materials as friable, Category I non-friable, or Category II non-friable.

  2. Contractor information including the Ohio EPA asbestos hazard abatement contractor license number (format: ACXXXX). If no licensed contractor is involved (e.g., demolition with no RACM), you still need the demolition contractor’s information.

  3. Disposal site - the name and location of the Ohio EPA-approved landfill where asbestos waste will be disposed.

  4. Project schedule - specific start and completion dates. Remember the 10-working-day advance notice requirement.

  5. AHES credentials - name, certification number (format: ESXXXX), and the analytical method used for the survey (typically PLM with dispersion staining, with point counting for samples under 10%).

Filing the Notification

Ohio EPA strongly encourages electronic submission through the eBusiness Center. Online submissions allow credit card or electronic check payment, and the system has built-in validation to catch common errors before submission.

  1. Log into the eBusiness Center
  2. Navigate to Air Services, then Asbestos Notifications
  3. Complete all required fields
  4. Upload the asbestos survey report
  5. Pay fees electronically
  6. Submit and save the confirmation

Paper Submission

If submitting by paper, mail the completed notification form with a check or money order (payable to “Treasurer, State of Ohio”) to:

Asbestos Program, Ohio EPA DAPC P.O. Box 1049 Columbus, OH 43216-1049

Paper notifications received without payment are considered incomplete.

Fee Structure

This is where it gets confusing because two fee schedules can apply:

ORC 3745.11(G) fees (NESHAP notification):

  • $75 base notification fee
  • Plus $3 per unit of RACM removed (1 unit = any combination of linear feet or square feet equal to 50)

OAC 3745-22-04(C) fees (contractor notification):

  • $65 per address where RACM exceeds 50 SF or 50 LF

A project with a licensed contractor removing RACM above both thresholds pays fees under both rules. The combined form handles this - just make sure you calculate both fee components.

Some local air agencies (like the Southwest Ohio Air Quality Agency covering Hamilton, Butler, Clermont, Clinton, and Warren counties) also charge regional user fees on top of the state fees.

Timing

Standard notification: At least 10 working days before the start of demolition or renovation. This is 10 working days, not calendar days.

Amended notification: If the amount of RACM, the schedule, or the removal methods change after filing, submit an amended notification within 1 working day of discovering the change. If the start date changes, the amended notification must be filed at least 10 working days before the new start date.

Emergency demolition: If a building is structurally unsound and poses an imminent danger, notify Ohio EPA as early as possible before work begins. Emergency procedures still require compliance with wetting, waste handling, and disposal requirements.

Common Mistakes

Not filing for demolitions with no ACM. All demolitions require notification. The survey came back clean - great, you still need to file.

Calendar year accumulation. Individual renovations that are each below the 260/160/35 thresholds can still trigger notification if the cumulative total across the calendar year exceeds the thresholds. Track your cumulative RACM quantities per building per year.

Wrong AHES number format. The form asks for the AHES certification number in ESXXXX format. Do not use the inspector’s social security number, training certificate number, or any other identifier.

Missing disposal site. The notification requires you to name the disposal facility. If you do not have this information at the time of filing, you cannot submit a complete notification.

Late amendments. A change in start date requires 10 working days notice from the new date. If your project gets delayed by a week, you cannot just show up on the new date - file the amendment and wait.

After Filing

Keep the notification and asbestos survey on-site during all active operations. Ohio EPA inspectors can and do conduct unannounced site visits. The notification, the survey report, and proof of worker certifications and training must be available for inspection at all times.

If the project scope changes significantly (more RACM discovered during work, additional buildings affected), file an amended notification and adjust the fees accordingly.

For the full regulatory framework, see our Ohio Asbestos Regulations Overview. For information about required certifications, see Ohio Asbestos Certification and Licensing.