Who regulates asbestos in Ohio?

Multiple agencies share jurisdiction. Ohio EPA's Division of Air Pollution Control (DAPC) administers NESHAP notification requirements, asbestos abatement and demolition regulations (OAC 3745-20), and certification/licensing for asbestos professionals (OAC 3745-22). OSHA regulates worker safety during asbestos activities under 29 CFR 1926.1101 (construction) and 29 CFR 1910.1001 (general industry). U.S. EPA administers AHERA requirements for schools under 40 CFR 763.

Do I need to notify Ohio EPA before a demolition?

Yes. All demolitions require written notification to the appropriate Ohio EPA district office at least 10 working days before work begins, regardless of whether asbestos-containing material is present. Renovations involving regulated ACM above NESHAP threshold quantities also require notification. Use the Ohio EPA notification form and submit to your district office.

What is the difference between friable and non-friable asbestos?

Friable ACM can be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACM cannot be reduced to powder by hand pressure under normal conditions. Non-friable ACM is further divided into Category I (resilient floor coverings, asphalt roofing, packings, gaskets) and Category II (everything else that is non-friable, such as cement siding, transite panels, fire doors). The distinction matters because friable ACM triggers more stringent removal and notification requirements.

Ohio Asbestos Regulations Overview

Q: When is a pre-demolition asbestos survey required?

Under OAC 3745-20 (Ohio's NESHAP rules), each owner or operator of any demolition or renovation operation must have the affected facility thoroughly inspected by a certified Asbestos Hazard Evaluation Specialist (AHES) prior to commencement of work. This applies to all demolitions and to renovations where regulated ACM may be present.

Overview

Ohio’s asbestos regulations are administered primarily by the Ohio EPA Division of Air Pollution Control (DAPC) through two chapters of the Ohio Administrative Code:

OAC 3745-20 - Asbestos emissions regulations for demolition and renovation projects. Ohio’s adoption of the federal National Emission Standards for Hazardous Air Pollutants (NESHAP) for asbestos, with some state-specific provisions.
OAC 3745-22 - Certification and licensing requirements for asbestos professionals and contractors.

Additional federal regulations that apply to asbestos work in Ohio include OSHA’s construction industry standard (29 CFR 1926.1101) for worker safety during demolition and renovation, OSHA’s general industry standard (29 CFR 1910.1001), and EPA’s AHERA regulations for schools (40 CFR 763).

Who Regulates What

Ohio EPA - Division of Air Pollution Control (DAPC)

NESHAP notification requirements for demolition and renovation
Pre-demolition/renovation asbestos survey requirements
Work practice standards for asbestos removal
Asbestos waste handling and disposal requirements
Certification of individuals (inspectors, workers, supervisors, designers, air monitors)
Licensing of asbestos abatement contractors
Contact: asbestos@epa.ohio.gov or 614.466.0061

OSHA

Worker exposure limits (PEL and excursion limit)
Exposure monitoring requirements
Respiratory protection and PPE
Medical surveillance
Training requirements for workers
Work classifications (Class I through IV)
Regulated area requirements
Recordkeeping (exposure records for 30 years, medical records for employment + 30 years)

U.S. EPA

AHERA requirements for K-12 schools (management plans, inspections, reinspections)
TSCA asbestos regulation
Federal NESHAP (delegated to Ohio EPA for implementation)

Asbestos-Containing Material (ACM) Categories

Understanding ACM categories is essential because they determine which regulatory requirements apply.

Friable ACM

Material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Examples include sprayed-on fireproofing, acoustical plaster (popcorn ceiling texture), pipe insulation, and boiler insulation. Friable ACM is subject to the most stringent requirements under both NESHAP and OSHA standards.

Category I Non-Friable ACM

Includes asbestos-containing packings, gaskets, resilient floor coverings (vinyl floor tile, sheet vinyl flooring), and asphalt roofing products. Category I non-friable ACM is not regulated under NESHAP unless it is in poor condition and friable, or it will be or has been subjected to sanding, grinding, cutting, or abrading.

Category II Non-Friable ACM

All other non-friable ACM that does not fall into Category I. Examples include cement siding, transite panels, cement pipe, fire doors, and roofing felt. Category II non-friable ACM becomes regulated when it has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material during demolition or renovation.

RACM (Regulated ACM)

Regulated asbestos-containing material includes friable ACM, Category I non-friable ACM that has become friable or will be sanded/ground/cut/abraded, and Category II non-friable ACM that has a high probability of becoming crumbled or pulverized during the work. RACM is what triggers NESHAP notification and work practice requirements.

NESHAP Notification Requirements

Demolitions

All demolitions require written notification to the appropriate Ohio EPA district office at least 10 working days before the start of demolition, regardless of whether ACM is present. This is a point that is frequently missed - even if the asbestos survey found no ACM, the demolition notification is still required.

Renovations

Renovations require notification when the amount of regulated ACM that will be removed, stripped, or disturbed exceeds NESHAP threshold quantities:

260 linear feet on pipes, or
160 square feet on other facility components, or
35 cubic feet off facility components where length or area cannot be measured

Notification Contents

The notification must include:

Owner/operator and contractor information (including Ohio contractor license number)
Facility location and description
Description and quantity of ACM to be removed
Scheduled start and end dates
Methods for ACM removal and disposal
Disposal site location
Certification that the facility has been inspected by a certified AHES

Amended Notifications

If any of the following change after notification is submitted, an amended written notification must be filed within one working day:

Amount of regulated ACM affected
Deviation in schedule
Changes in removal methods

Dual Notification and Fee Structure

Ohio’s asbestos notification covers two separate regulatory chapters. OAC 3745-20-03 requires notification for all demolitions and for renovations where RACM exceeds 260 LF / 160 SF / 35 CF. Separately, OAC 3745-22-04(C) requires notification when a licensed contractor performs abatement exceeding 50 linear feet or 50 square feet of RACM. Ohio has combined these into a single notification form, but each chapter has its own fee structure. Projects may be subject to fees under both rules.

Pre-Demolition/Renovation Asbestos Survey

Ohio’s regulations (OAC 3745-20) require that each owner or operator of a demolition or renovation operation have the affected facility or part of the facility thoroughly inspected by a certified Asbestos Hazard Evaluation Specialist (AHES) prior to commencement of work. The survey must identify the presence, location, and quantity of all ACM and suspected ACM in the areas to be affected.

For detailed information about survey sampling requirements, analytical methods, and inspection report standards, see:

AHERA Sampling and the 1% Threshold - Sampling protocols, sample quantities, and the critical difference between AHERA and OSHA definitions of ACM
Asbestos Analytical Methods - PLM, point counting, TEM, and PCM explained
Asbestos Inspection Reporting - What belongs in an asbestos inspection report

Certification and Licensing

All individuals performing asbestos-related work in Ohio must hold the appropriate Ohio EPA certification. For a detailed breakdown of each certification type, training requirements, fees, and the application process, see our Ohio Asbestos Certification and Licensing Guide.

A summary of the certification types:

Asbestos Hazard Evaluation Specialist (AHES) - Required for inspections, sampling, and air monitoring. $200/year.
Asbestos Hazard Abatement Specialist (AHAS) - Required for supervising abatement activities. $200/year.
Asbestos Hazard Abatement Worker (AHAW) - Required for non-supervisory abatement work. $50/year.
Asbestos Hazard Abatement Project Designer - Required for designing abatement projects. $200/year.
Asbestos Hazard Abatement Air Monitoring Technician - Required for air monitoring during abatement. $100/year.
Asbestos Hazard Abatement Contractor License - Required for any business performing abatement projects. $750/year.

Disposal Requirements

Asbestos-containing waste material must be:

Adequately wetted and kept wet during handling, loading, transport, and disposal
Sealed in leak-tight containers or wrapping, or transported in leak-tight vehicles that are securely covered
Labeled in accordance with OSHA and DOT requirements
Disposed of at a landfill approved by Ohio EPA for asbestos waste

Category I and Category II non-friable ACM waste that has not been crumbled, pulverized, or reduced to powder is exempt from the wetting and container requirements, but must still be disposed of properly.

For more detail on waste handling and disposal, see Asbestos Disposal Requirements - Ohio.