ASTM E2356-18

Standard Practice for Comprehensive Building Asbestos Surveys

SIGNIFICANCE AND USE
4.1 Management of asbestos-containing materials in buildings and facilities requires knowledge of the location, type, quantity, and condition of the material. The more complete and accurate the information available, the more appropriate and cost-effective are the control measures used to reduce possible exposure to airborne asbestos fibers. This is true whether the asbestos-containing materials remain undisturbed and completely intact, are selectively removed for maintenance or prior to renovation, or are removed to the greatest extent feasible before demolishing the building or facility.  
4.2 This practice describes three types of surveys that support different objectives. These are the Baseline Survey, the Project Design Survey, and the Pre-Construction Survey.  
4.2.1 The Baseline Survey is a building-wide or facility-wide inspection that provides a general sense of the overall location, type, quantity, and condition of asbestos-containing materials present. It is thorough in that most accessible functional spaces are inspected and bulk samples taken of suspect materials observed. The baseline survey provides information for long-term management of asbestos-containing materials and prioritization of response actions. The presence of asbestos in suspect materials may be assumed or presumed in some cases without bulk samples being taken or analyzed. However, the baseline survey is unobtrusive in that samples are not taken where doing so would result in objectionable damage to surfaces or where institutional barriers preclude access. In a baseline survey, destructive testing is avoided. Posting of signs and labels required for compliance with OSHA regulations would use the information generated during a Baseline Survey.
Note 1: A Baseline Survey is sometimes called an “AHERA” survey because it provides the type of information used for management of asbestos-containing materials in schools. However, the baseline survey described in this practice requires inspec...
SCOPE
1.1 This practice describes procedures for conducting comprehensive surveys of buildings and facilities for the purpose of locating, identifying, quantifying, and assessing asbestos-containing materials.  
1.2 The results of a Comprehensive Building Asbestos Survey are intended to be used for ongoing management of asbestos-containing materials, including Operations and Maintenance (O&M), removal, and other response actions. This includes response actions associated with renovations. A Comprehensive Building Asbestos Survey is also intended to provide information required for removal of asbestos-containing materials prior to demolition of a building or facility.  
1.3 This practice discusses three types of surveys: Baseline Surveys, Project Design Surveys, and Pre-Construction Surveys.  
1.4 This practice discusses the following activities for each of the above types of surveys:  
1.4.1 Planning the survey to meet defined objectives;  
1.4.2 Obtaining and reviewing information on the building or facility including previous surveys and response actions;  
1.4.3 Conducting the physical activities of inspecting the premises and collecting bulk samples of suspect materials;  
1.4.4 Analyzing the bulk samples for asbestos type and content;  
1.4.5 Assessing the Current Condition and Potential for Disturbance of asbestos-containing materials; and  
1.4.6 Preparing a report that includes a narrative discussion of the findings, tabulations of inspection, sampling and analysis results, graphical depiction of the areas inspected, and the results of the assessment.  
1.5 This practice does not include air sampling or surface (dust) sampling for purposes of evaluating a potential exposure hazard from airborne asbestos fibers. The reader may find assistance with exposure assessment determination by reviewing Practice D7886.  
1.6 Warning—Asbestos fibers are acknowledged carcinogens. Breathing asbestos fibers can result in d...

General Information

• Status: Published
• Publication Date: 30-Sep-2018
• ICS: 91.100.40 - Products in fibre-reinforced cement
• Technical Committee: D22 - Air Quality
• Drafting Committee: D22.07 - Sampling, Analysis, Management of Asbestos, and Other Microscopic Particles

Relations

• Replaces: ASTM E2356-14 - Standard Practice for Comprehensive Building Asbestos Surveys
• Effective Date: 01-Oct-2018
• Refers: ASTM E1494-18 - Standard Practice for Testing Physical Properties of Friable Surfacing Materials
• Effective Date: 01-Jul-2018
• Refers: ASTM D7712-18 - Standard Terminology for Sampling and Analysis of Asbestos
• Effective Date: 15-Apr-2018
• Refers: ASTM E631-15 - Standard Terminology of Building Constructions
• Effective Date: 01-Mar-2015
• Refers: ASTM E631-14 - Standard Terminology of Building Constructions
• Effective Date: 01-Nov-2014
• Refers: ASTM D7886-14 - Standard Practice for Asbestos Exposure Assessments for Repetitive Maintenance and Installation Tasks
• Effective Date: 15-Apr-2014
• Refers: ASTM D7521-13 - Standard Test Method for Determination of Asbestos in Soil
• Effective Date: 15-Jan-2013
• Refers: ASTM E1494-12 - Standard Practice for Encapsulation Testing of Friable Asbestos-Containing Surfacing Materials
• Effective Date: 01-Apr-2012
• Refers: ASTM E1368-11 - Standard Practice for Visual Inspection of Asbestos Abatement Projects
• Effective Date: 01-Oct-2011
• Refers: ASTM D7712-11e1 - Standard Terminology for Sampling and Analysis of Asbestos
• Effective Date: 01-Sep-2011
• Refers: ASTM D7712-11 - Standard Terminology for Sampling and Analysis of Asbestos
• Effective Date: 01-Sep-2011
• Refers: ASTM E2394-11 - Standard Practice for Maintenance, Renovation and Repair of Installed Asbestos Cement Products
• Effective Date: 01-Feb-2011
• Refers: ASTM E1494-92(2010) - Standard Practice for Encapsulants for Spray- or Trowel-Applied Friable Asbestos-Containing Building Materials
• Effective Date: 01-Oct-2010
• Refers: ASTM E631-06 - Standard Terminology of Building Constructions
• Effective Date: 01-Jun-2006
• Refers: ASTM E1368-05e1 - Standard Practice for Visual Inspection of Asbestos Abatement Projects
• Effective Date: 01-May-2005

Overview

ASTM E2356-18 is the internationally recognized standard practice for conducting comprehensive building asbestos surveys. Developed by ASTM International, this standard defines the procedures necessary to locate, identify, quantify, and assess asbestos-containing materials (ACM) in buildings and facilities. The main goal of a comprehensive asbestos survey is to ensure safe ongoing management of ACM, support maintenance and renovation projects, and meet regulatory requirements for asbestos removal prior to demolition.

Conducting a thorough asbestos survey is critical for reducing potential exposure to airborne asbestos fibers, which are hazardous to human health. The standard applies to a broad range of settings, including commercial properties, institutional buildings, and industrial facilities.

Key Topics

• Types of Surveys:
  ASTM E2356-18 describes three primary types of asbestos surveys, each designed for different project objectives:

  • Baseline Survey: A wide-ranging inspection of accessible areas to provide a full inventory of ACM across an entire building or facility. Used for long-term management and compliance.
  • Project Design Survey: Targets areas impacted by planned maintenance, renovation, or abatement projects. Often incorporates destructive testing and a detailed analysis of materials to inform project specifications.
  • Pre-Construction Survey: Conducted when planning renovation or demolition in buildings where previous survey information is lacking. May require destructive testing to identify hidden ACM.

• Survey Components and Activities:
  Key elements of a comprehensive survey under ASTM E2356-18 include:

  • Planning to define survey scope and objectives
  • Reviewing existing documentation and previous asbestos surveys
  • Systematic physical inspection of premises and bulk sampling of suspect materials
  • Laboratory analysis of samples for asbestos content and type using approved methods such as Polarized Light Microscopy (PLM)
  • Assessment of the condition and potential disturbance risk of identified ACM
  • Preparing detailed reports, including narrative findings, sample logs, laboratory data, and graphical floor plans of inspected areas

• Qualifications and Responsibilities:
  Inspectors must meet specific accreditation requirements, including certification under applicable federal and state programs. Laboratory analysis must be performed by qualified entities with recognized accreditations, such as those complying with ISO/IEC 17025.

• Safety and Compliance:
  The practice highlights the health hazards of asbestos exposure and the importance of avoiding unnecessary disturbance of materials during surveys. It also references major regulatory requirements, such as OSHA and EPA standards.

Applications

ASTM E2356-18 is an essential standard for a wide range of asbestos survey applications, including:

• Facilities Management: Provides critical information for Operations and Maintenance (O&M) programs to manage in-place ACM.
• Renovation and Demolition: Ensures compliance with regulatory requirements by identifying and quantifying asbestos materials to be removed, supporting safe project planning.
• Real Estate Transactions: Supplies necessary documentation for buyers, sellers, and lending institutions to evaluate asbestos risks in property transfers.
• Regulatory Compliance: Satisfies requirements for inspections and notifications under OSHA, EPA NESHAP, and state asbestos regulations.
• Abatement Project Design: Informs abatement plans by detailing material locations, types, quantities, and conditions.

Related Standards

A comprehensive building asbestos survey conducted under ASTM E2356-18 may reference or complement the following related standards:

• ASTM D7712: Terminology for Sampling and Analysis of Asbestos
• ASTM D7521: Test Method for Determination of Asbestos in Soil
• ASTM D7886: Practice for Asbestos Exposure Assessments for Maintenance and Installation Tasks
• ASTM E1368: Practice for Visual Inspection of Asbestos Abatement Projects
• ASTM E1494: Practice for Testing Physical Properties of Friable Surfacing Materials
• EPA NESHAP Regulations (40 CFR Part 61, Subpart M): National Emission Standards for Hazardous Air Pollutants – Asbestos
• EPA AHERA Regulations (40 CFR Part 763): Asbestos control requirements for schools
• ISO/IEC 17025: General requirements for the competence of testing and calibration laboratories

Implementing ASTM E2356-18 ensures organizations meet legal obligations, protect occupants and workers, and manage asbestos safely throughout the facility lifecycle.

Standards Content (Sample)

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E2356 − 18
Standard Practice for
Comprehensive Building Asbestos Surveys
This standard is issued under the fixed designation E2356; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision.Anumber in parentheses indicates the year of last reapproval.A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope hazard from airborne asbestos fibers. The reader may find
assistance with exposure assessment determination by review-
1.1 This practice describes procedures for conducting com-
ing Practice D7886.
prehensivesurveysofbuildingsandfacilitiesforthepurposeof
1.6 Warning—Asbestos fibers are acknowledged carcino-
locating, identifying, quantifying, and assessing asbestos-
gens. Breathing asbestos fibers can result in disease of the
containing materials.
lungs including asbestosis, lung cancer, and mesothelioma.
1.2 The results of a Comprehensive Building Asbestos
Precautions in this practice should be taken to avoid creating
Survey are intended to be used for ongoing management of
andbreathingairborneasbestosparticlesfrommaterialsknown
asbestos-containing materials, including Operations and Main-
or suspected to contain asbestos. See 2.2 for regulatory
tenance (O&M), removal, and other response actions. This
requirements addressing asbestos.
includes response actions associated with renovations.ACom-
1.7 The values stated in SI units are to be regarded as
prehensive Building Asbestos Survey is also intended to
standard. The values given in parentheses are mathematical
provide information required for removal of asbestos-
conversions to inch-pound units that are provided for informa-
containing materials prior to demolition of a building or
tion only and are not considered standard.
facility.
1.8 This standard does not purport to address all of the
1.3 This practice discusses three types of surveys: Baseline
safety concerns, if any, associated with its use. It is the
Surveys, Project Design Surveys, and Pre-Construction Sur-
responsibility of the user of this standard to establish appro-
veys.
priate safety, health, and environmental practices and deter-
1.4 This practice discusses the following activities for each
mine the applicability of regulatory limitations prior to use.
of the above types of surveys:
1.9 This international standard was developed in accor-
1.4.1 Planning the survey to meet defined objectives;
dance with internationally recognized principles on standard-
ization established in the Decision on Principles for the
1.4.2 Obtaining and reviewing information on the building
Development of International Standards, Guides and Recom-
or facility including previous surveys and response actions;
mendations issued by the World Trade Organization Technical
1.4.3 Conducting the physical activities of inspecting the
Barriers to Trade (TBT) Committee.
premises and collecting bulk samples of suspect materials;
1.4.4 Analyzing the bulk samples for asbestos type and
2. Referenced Documents
content;
2.1 ASTM Standards:
1.4.5 Assessing the Current Condition and Potential for
D7521Test Method for Determination of Asbestos in Soil
Disturbance of asbestos-containing materials; and
D7712Terminology for Sampling andAnalysis ofAsbestos
1.4.6 Preparing a report that includes a narrative discussion
D7886Practice forAsbestos ExposureAssessments for Re-
ofthefindings,tabulationsofinspection,samplingandanalysis
petitive Maintenance and Installation Tasks
results, graphical depiction of the areas inspected, and the
E631Terminology of Building Constructions
results of the assessment.
E1368Practice forVisual Inspection ofAsbestosAbatement
1.5 This practice does not include air sampling or surface
Projects
(dust)samplingforpurposesofevaluatingapotentialexposure
E1494Practice for Testing Physical Properties of Friable
Surfacing Materials
E2394Practice for Maintenance, Renovation, and Repair of
ThispracticeisunderthejurisdictionofASTMCommitteeD22onAirQuality
and is the direct responsibility of Subcommittee D22.07 on Sampling, Analysis,
Management of Asbestos, and Other Microscopic Particles. For referenced ASTM standards, visit the ASTM website, www.astm.org, or
Current edition approved Oct. 1, 2018. Published October 2018. Originally contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
approved in 2004. Last previous edition approved in 2014 as E2356–14. DOI: Standards volume information, refer to the standard’s Document Summary page on
10.1520/E2356-18. the ASTM website.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E2356 − 18
Installed Asbestos Cement Products structural and architectural surfaces. Surfacing material in-
MNL-23ManualonAsbestosControl:Surveys,Assessment, cludes acoustical plaster on ceilings, fireproofing on structural
Abatement, and Management – Third Edition, 2015 members, textured paint and exterior stucco, and other mate-
rialsappliedtosurfacesforacoustical,decorative,fireproofing,
2.2 Other Documents:
and other purposes.
29CFR1910.134Respiratory Protection Standard
29 CFR 1910.146Permit-Required Confined Spaces
3.2.1.3 thermal system insulation, n—material which is
29 CFR 1926 SubpartAAConfined Spaces in Construction
applied to interior and exterior mechanical components to
29 CFR 1926.1101 Occupational Exposure to Asbestos
reduce heat gain or loss. Thermal system insulation includes
(OSHA Construction Standard)
insulation on pipes, fittings, boilers, breeching, tanks, ducts,
40CFRPart61National Emission Standards for Hazardous
and other mechanical components.
Air Pollutants: Subpart M—Asbestos
3.2.2 crawl space, n—an accessible area that may have a
40 CFR Part 763,Appendix E to Subpart E Interim Method
dirt floor, usually with low head room.
of the Determination of Asbestos in Bulk Insulation
Samples (Section 1, Section 2 only as applicable), 1987 3.2.3 high effıciency particulate air (HEPA) filter, n—the
40CFRPart763, Subpart EAsbestos-Containing Materials
final stage filter on a negative pressure ventilation device (see
in Schools (EPAAHERA Regulations)
3.2.19 in Practice E1368)) or on a vacuum cleaner, capable of
40 CFR Part 763, Subpart E, Appendix C(EPA Model
trapping and retaining at least 99.97 percent of all mono-
Accreditation Plan)
dispersed particles of 0.3 micrometres in diameter.
EPA 560⁄5-85-030A Asbestos in Buildings: Simplified
3.2.4 dust and debris, n—visible particles, fragments, or
Sampling Scheme for Surfacing Materials (“Pink Book”),
chunks of material, large enough to have settled in the work
area by virtue of their weight, that are presumed to have
EPA 600R-04⁄004 Research Method for Sampling and
originated from the material abated by the response action, or
Analysis of Fibrous Amphibole in Vermiculite Attic
from a fiber release episode.
Insulation, January 2004
3.2.5 fiber release episode, n—uncontrolledorunintentional
EPA600⁄R-93⁄116Method for the Determination ofAsbes-
disturbance of asbestos-containing materials which results in
tos in Bulk Building Materials, June 1993
the generation of dust and debris.
Managing Asbestos in BuildingsA Guide for Owners and
Managers, March 2015
3.2.6 friable material, n—material easily crumbled or pow-
2.3 ISO Standards:
dered by moderate (hand) pressure.
ISO/IEC 17025Testing and Calibration Laboratories
3.2.7 response action, n—a method of abatement (such as
removal, encapsulation, or enclosure) or operations and main-
3. Terminology
tenance (such as repair, clean-up, or preventive measures) of
3.1 Definitions—For definitions of building terms, see Ter-
asbestos-containing material in any form, for any purpose
minology E631.
whatsoever.
3.2 Terms Defined in Practice—The user is referred to
3.2.8 visual inspection process, n—the activities before,
Practice E1368 for terms specifically related to asbestos
during, and at the conclusion of a response action that are
abatement for purposes of a Project Design Survey.
associated with detecting the presence of visible residue, dust
3.2.1 asbestos-containing materials, n—material containing
and debris, or unremoved material and verifying the absence
more than one percent asbestos.
thereof at the completion of a response action.
3.2.1.1 miscellaneous materials, n—material, other than
3.3 Definitions of Terms Specific to This Standard:
surfacing material and thermal system insulation, on interior
3.3.1 accessible location, n—a functional space or part
and exterior structural, mechanical, electrical, or architectural
thereof that can be inspected without requiring destructive
components,andsurfaces.Miscellaneousmaterialincludesbut
testingorpresentinganunacceptablehealthorsafetyrisktothe
is not limited to ceiling tiles, gaskets, floor coverings and
inspector,andwhereentryisnotprohibitedbysecurityorother
mastics, wallboard joint compound, roofing materials, and
institutional restrictions.
cementitious products.
3.3.2 building asbestos survey, n—an activity to determine
3.2.1.2 surfacing material, n—material that is sprayed,
the presence, location, condition, and quantity of asbestos-
troweled-on, or otherwise applied to interior and exterior
containingmaterialsinabuildingorfacility,orontheproperty
containing the building or facility.
Available from Occupational Safety and Health Administration (OSHA), 200
3.3.3 bulk sample, n—a sample of suspect asbestos-
Constitution Ave., NW, Washington, DC 20210, http://www.osha.gov.
AvailablefromUnitedStatesEnvironmentalProtectionAgency(EPA),William
containing material collected for identification of asbestos and
Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
determination of the percent of the components in the sample.
http://www.epa.gov.
Available from Environmental Information Association, Inc. (EIA), 6935
3.3.4 concealed space, n—a location requiring destructive
Wisconsin Avenue Suite 306 Chevy Chase, MD 20815-6112, https://eia-usa.org.
testing for penetration of a building or component surface for
Available from International Organization for Standardization (ISO), ISO
inspection and, if necessary, sampling of suspect material.
Central Secretariat, BIBC II, Chemin de Blandonnet 8, CP 401, 1214 Vernier,
Geneva, Switzerland, http://www.iso.org. Concealedspacesinclude,butarenotlimitedto,cavitiesinside
E2356 − 18
soffits, walls and chases, plenums above solid ceilings, sub- 3.3.15 suspect material, n—material that is sampled or is
floor ducts and cable runs, and the interior of HVAC equip- presumed to contain asbestos on the basis of its location,
purpose, appearance, and other factors considered by the
ment.
inspector.
3.3.5 destructive testing, n—inspection procedures that nec-
3.4 Terms Defined in Practice D7521:
essarilyinvolveobjectionableornoticeabledamagetobuilding
3.4.1 asbestos, n—a collective term that describes a group
surfaces, or require penetration of a surface such as a wall,
of naturally occurring, inorganic, highly-fibrous, silicate min-
ceiling, chase, or shaft to gain access to a concealed space.
erals that are easily separated into long, thin, flexible, strong
Lifting a ceiling tile or opening a hatch is not destructive
fibers when crushed or processed.
testing.
3.4.1.1 Discussion—Included in the definition are the as-
3.3.6 excluded area, n—a functional space or part thereof
bestiform varieties of serpentine (chrysotile); riebeckite (cro-
where entry is prohibited by security or other institutional
cidolite); grunerite (grunerite asbestos [Amosite]); anthophyl-
restrictions.
lite(anthophylliteasbestos);tremolite(tremoliteasbestos);and
actinolite (actinolite asbestos).The amphibole mineral compo-
3.3.7 functional space, n—an area within a building or
sitions are defined according to the nomenclature of the
facility that is used for a specific purpose. Examples include a
International Mineralogical Association.
warehouse in a manufacturing plant and a conference room in
3.4.1.2 Discussion—The mineral fibers described in this
an office building.Afunctional space can be vertical in extent,
definition are listed below. This method is also applicable to
such as a pipe chase, and span several floors.
other mineral fibers of interest not listed in Table 1.
3.3.8 homogeneous area, n—surfacing material, thermal
3.5 Acronyms:
system insulation material, or miscellaneous material that is
3.5.1 ACM—Asbestos-containing material(s)
uniform in color and texture and apparent or known date of
3.5.2 AHERA—Asbestos Hazard Emergency Response Act
installation.
3.5.3 EPA—U.S. Environmental Protection Agency
3.3.9 laboratory, n—an entity that is equipped and qualified
3.5.4 HEPA—High Efficiency Particulate Air
to perform one or more of the following analyses, using
3.5.5 NAD—No Asbestos Detected
approved methods: (1) identify and quantify asbestos in bulk
samples by Polarized Light Microscopy, (2) identify and 3.5.6 NESHAP—National Emission Standards for Hazard-
quantify asbestos in bulk samples by Transmission Electron
ousAirPollutants;specifically,theNationalEmissionStandard
Microscopy,and (3)performcountingproceduresandquantify for Asbestos (40CFRPart61, Subpart M)
airborne fibers with Phase Contrast Microscopy.
3.5.7 NOB—Non-friable organically-bound
3.3.10 limits of abatement, n—an area where asbestos- 3.5.8 OSHA—U.S. Department of Labor, Occupational
related activities will be conducted before, during and at the
Safety and Health Administration
conclusion of the project, that is contiguous with and includes
3.5.9 PPE—Personal Protective Equipment
the limits of construction for an associated renovation or
3.5.10 PLM—Polarized Light Microscopy
demolition project.
3.5.11 TEM—Transmission Electron Microscopy
3.3.11 non-friable organically bound (NOB) materials,
3.5.12 VAI—Vermiculite Attic Insulation
n—materials that are not friable and that consist of fibers and
other particulate matter embedded in a solid matrix of
4. Significance and Use
asphaltic, vinyl or other organic substances.
4.1 Management of asbestos-containing materials in build-
3.3.12 operations and maintenance (O&M) program, n—a ings and facilities requires knowledge of the location, type,
proactive management program to provide periodic surveil- quantity,andconditionofthematerial.Themorecompleteand
lance of asbestos-containing materials, maintain them in good accurate the information available, the more appropriate and
cost-effective are the control measures used to reduce possible
condition, mitigate fiber release from existing asbestos-
exposure to airborne asbestos fibers. This is true whether the
containing materials, and clean up asbestos-containing dust
asbestos-containing materials remain undisturbed and com-
and debris that has been released, in order to minimize worker
pletelyintact,areselectivelyremovedformaintenanceorprior
or occupant exposure to asbestos fibers.
3.3.13 polarized light microscopy (PLM), n—a method of
TABLE 1 Asbestos
analytical mineralogy that uses an optical microscope to
Chemical Abstract
determine the optical properties of sample constituents and, in Asbestos
Service No.
the case of bulk sample analysis for asbestos, to provide
Chrysotile 12001-29-5
positive identification of suspect fibers as asbestos and to
Crocidolite 12001-28-4
Amosite 12172-73-5
quantify the percent of asbestos in the sample.
Anthophyllite asbestos 77536-67-5
Tremolite asbestos 77536-68-6
3.3.14 skim coat, n—athinfinishcoatappliedtoanexisting
Actinolite asbestos 77536-66-4
plaster surface or other substrate to improve appearance or
Asbestos 1332-21-4
other reasons.
E2356 − 18
NOTE 3—On August 7, 2015, the EPA published a clarification letter
to renovation, or are removed to the greatest extent feasible
allowingfortheuseofthePre-ConstructionSurveyforcomplianceforthe
before demolishing the building or facility.
asbestos NESHAP requirements to “…thoroughly inspect the affected
4.2 This practice describes three types of surveys that
facility…”[40CFRPart61.145(a)].Thisclarificationlettercanbefound
on the EPA’s Applicability Determination Index (ADI) as item number
supportdifferentobjectives.ThesearetheBaselineSurvey,the
A150001. The clarification letter explains what sections of this practice
Project Design Survey, and the Pre-Construction Survey.
must be used for compliance.
4.2.1 The Baseline Survey is a building-wide or facility-
wide inspection that provides a general sense of the overall 4.3 Theinter-relationshipsamongthethreetypesofsurveys
and with other ASTM asbestos control standards is shown in
location, type, quantity, and condition of asbestos-containing
materials present. It is thorough in that most accessible Fig. 1.
functional spaces are inspected and bulk samples taken of
4.4 ThispracticeemphasizestheconceptthataComprehen-
suspect materials observed. The baseline survey provides
sive Building Asbestos Survey consists of more than the
information for long-term management of asbestos-containing
collection and analysis of samples, and the report is more than
materials and prioritization of response actions. The presence
acompilationoflaboratoryresults.Itisimportanttoinspectas
of asbestos in suspect materials may be assumed or presumed
many functional spaces as possible and to document the
in some cases without bulk samples being taken or analyzed.
reasons why certain functional spaces were not inspected and
However,thebaselinesurveyisunobtrusiveinthatsamplesare
locations where no suspect materials were observed and,
nottakenwheredoingsowouldresultinobjectionabledamage
consequently, no samples were taken. Reasons might include
to surfaces or where institutional barriers preclude access. In a
access limitations, the absence of materials to sample, the
baselinesurvey,destructivetestingisavoided.Postingofsigns
existence of information from previous surveys, or the avail-
and labels required for compliance with OSHA regulations
ability of reliable documentation such product data sheets or
wouldusetheinformationgeneratedduringaBaselineSurvey.
Safety Data Sheets (previously known as Material Safety Data
NOTE 1—ABaseline Survey is sometimes called an “AHERA” survey Sheets,MSDS)wherethecontentofthatdocumentspecifically
because it provides the type of information used for management of
details the absence of added asbestos. It is worthy to note that
asbestos-containing materials in schools. However, the baseline survey
it can be difficult to find MSDS or product data sheets for
described in this practice requires inspection, bulk sampling,
installed materials or in older buildings or structures. It is also
quantification, and assessment of suspect materials that are excluded by
known that asbestos content was not always disclosed in these
virtue of their type and location from theAHERAregulations for schools.
NOTE 2—Suspect material subject to disturbance by planned or emer- documents. In other cases there may be a material descriptions
gency maintenance may not always be identified as to asbestos content in
(as with asphaltic roofing products) where the term “encapsu-
a Baseline Survey. Collecting a single bulk sample, or a small number of
lated asbestos” is used. Terms of this nature do not do not
samples, to determine if the material contains asbestos does not constitute
constitute the absence of asbestos. If the absence of asbestos is
a survey within the meaning of this practice. Nonetheless, the sample(s)
not clearly noted on these documents they should not be used
shouldbecollectedinaccordancewiththemethodsdescribedinAppendix
X1(thismustbedonebyaproperly-credentialedindividual)andanalyzed
to eliminate an installed material from a survey.
as set forth in 6.5.
4.5 A Comprehensive Building Asbestos Survey is not
4.2.2 The Project Design Survey is more focused than a
limited to the class of materials commonly referred to as
Baseline Survey and is used to provide information to the
asbestos-containingbuildingmaterials(ACBM),definedinthe
Project Designer for preparing abatement plans and specifica-
AHERA regulations as “. found in or on interior structural
tions. The locations inspected are limited to the areas that will
membersorotherpartsofabuilding.”Itemsthataredifficultto
be affected by the abatement project. If the project is being
distinguish as such may include cooling towers, laboratory
done prior to renovation or demolition, the construction plans
hoods, gaskets, chalkboards, and other articles. These may be
or at least a clear statement of the scope of the renovation or
installed in, attached to, or adjacent to the building or facility
demolition work are required for a proper Project Design
but are not as clearly a part of the building or facility as
Survey. Destructive testing is often required for a Project
fireproofing or floor tile. Nonetheless, such items still fall
DesignSurvey.Thepresenceofasbestosinsuspectmaterialsis
within the scope of an asbestos management program and
always confirmed in a Project Design Survey rather than being
therefore are addressed in this practice. Locations outside the
assumed or presumed. Other information required for the
building, in particular equipment in industrial facilities and
Project Design is collected during the survey.
power plants, and crawl spaces underneath the building are
4.2.3 The Pre-Construction Survey is performed in antici-
within the scope of a Comprehensive Building Asbestos
pation of renovation or demolition where a Baseline Survey
Survey.
has not been conducted and there is no information, or
insufficient information, as to the existence of asbestos- 4.6 This practice is intended to be used by individuals who
containing materials within the planned limits of construction. areconductingaComprehensiveBuildingAsbestosSurveyfor
The Pre-Construction Survey requires destructive testing if the owner or manager of a building or facility under a
concealed spaces are to be breached during construction. If contractual arrangement for services as well as by employees
asbestos-containing materials are found, a Project Design of the owner or manager. If the individual is conducting the
Survey is conducted to provide information for preparing the survey under a contractual arrangement (which may be with
plans and specifications.The Pre-Construction Survey satisfies the firm employing the individual), the owner or manager of
theEPANESHAPrequirementsforrenovationordemolitionto the building is still responsible for certain activities as de-
“thoroughly inspect the affected facility.” scribed in this practice.
E2356 − 18
FIG. 1 Relationship Between E2356 Surveys and Other Standards
5. Qualifications and Responsibilities 5.3.3 Project Designer—For a project design survey, ac-
creditation as a project designer is desirable because this
5.1 This section describes the qualifications and responsi-
surveywillprovideinformationfortheplansandspecifications
bilitiesoftheindividualswhoparticipateintheComprehensive
to be used on an abatement project.
BuildingAsbestosSurvey.Therequirementforaccreditationas
an Inspector in accordance with the ModelAccreditation Plan
5.3.4 Contractor/Supervisor—For a project design survey,
applies to the activities covered by this practice. Additional
accreditation as a contractor/supervisor would be helpful
accreditations may be required, and qualifications may be
because of the knowledge of abatement processes such an
imposed by state licensing (certification) requirements or the
individual possesses.
policiesoftheownerormanagerofthebuildingorfacilitythat
5.4 In addition to the above accreditations, the following
are beyond the scope of this practice. Field experience in
credentials are evidence of the ability to perform one or more
performing asbestos building surveys as described in this
of the aspects of a Comprehensive Building Asbestos Survey.
practice is of paramount importance.
5.4.1 Credentialsthatindicateknowledgeofbuildingdesign
5.2 Not all of the qualifications discussed herein will be
include experience in building design, construction, or opera-
required for every Comprehensive Building Asbestos Survey
tions and academic degree(s), licensure, or registration as an
conducted, and in many cases one individual (usually the
architect or engineer.
accreditedinspector)willhavemorethanone,andpossiblyall,
of the required credentials.
5.4.2 Credentialssuchasacademicdegree(s)orcertification
in industrial hygiene, occupational safety, or a related field
5.3 Qualifications and responsibilities of individuals con-
indicates knowledge of the hazardous properties of asbestos
ducting the survey:
and other substances as well as the means of controlling the
5.3.1 Accredited Inspector—For both types of surveys, ac-
hazards.
creditation as an Inspector is required for the individual who
takes the bulk samples and otherwise performs the physical
5.4.3 Credentials that indicate knowledge of building con-
activities comprising the survey. This includes review of
struction and operations include field experience in building
relevant building documentation and preparation of the survey
construction, renovation, demolition, or maintenance, or a
report.
combination thereof; or formal or on-the-job training in con-
5.3.2 Management Planner—Forabaselinesurvey,accredi-
struction technology or management.
tation as a management planner is only required for hazard
5.5 Qualifications and Responsibilities of Owner or Man-
assessmentanddeterminationofresponseactionsifthesurvey
ager of Building or Facility—To be able to provide the
is performed in a school, but is a desirable credential for all
buildings and facilities. necessary information, access, and other support to the
E2356 − 18
inspector(s), the staff of the building or facility owner or liability.Inmostcases,conflictofinterestissueswouldbebest
manager should have taken at least a two-hour Asbestos avoided by using an outside consultant. Typically, outside
Awareness course. consultantscancompleteasurveyinamoretimelyfashionand
provide a more thorough and unbiased report than in-house
5.6 Laboratories analyzing the samples shall possess one or
personnel. Additionally, building owners and managers can
moreofthefollowingqualificationsinadditionto,oraspartof,
benefit from the consultant’s experience gained while inspect-
any applicable state licensing requirements.
ing other facilities.
5.6.1 For bulk sample analysis using Polarized Light Mi-
6.1.3 Establishing the Scope of the Survey—It is essential
croscopy:
thattheinspectorhavedocumented,inwriting,theexactscope
5.6.1.1 Accreditation by the National Voluntary Laboratory
of work for which he is responsible.ABaseline Survey would
Accreditation Program (NVLAP) of the National Institute of
normally be comprehensive in nature. However, if the inspec-
Standards and Technology (NIST), or that offered by the other
tion is to be limited to certain buildings, or portions of
accrediting organizations that assures that participant labora-
buildings, the specific areas to be inspected must be docu-
tories are in compliance with the international laboratory
mented in order for the inspector to achieve substantial
standard through ISO/IEC 17025;
completion of the contract, and not be held responsible for
5.6.1.2 Participation in the BulkAsbestos ProficiencyAna-
further work. One of the most important functions in-house
lytical Testing Program (BAPAT) provided by the American
personnel can provide is to participate in determining the
Industrial HygieneAssociation (AIHA) ProficiencyAnalytical
purpose of the survey, planning the survey and reviewing the
Testing Programs, LLC; and
results of the inspection done by the outside consultant.
5.6.1.3 Certification under the requirements found in state
In-house personnel should also play a role with providing
or local asbestos regulations where this issue is addressed.
access to all areas of the building/facility to the survey team(s)
5.6.2 Air samples are not collected or analyzed from the
and be available to answer questions posed by the survey team
areas where bulk samples are obtained as part of a Compre-
and the building occupants.
hensive Survey.
6.1.3.1 Identify buildings, or portions of buildings, to be
inspected. Each individual building shall be inspected sepa-
6. Baseline Surveys
rately and all functional spaces inspected, whether or not bulk
6.1 Planning the Survey—It is essential that the planning
samplesaretakentherein.Aseparatesetofhomogeneousareas
stage of an asbestos survey be complete in addressing the
ofsuspectmaterialshallbeidentified,sampledorassumed,and
following issues and be defensible.Awell-planned survey will
determined to beACM or non-ACM per building.Ahomoge-
consult other appropriate professionals, trades, or knowledge-
neous area may not be extended to include more than one
ableindividualswhomayprovidevaluableinformationregard-
building, but may include components exterior to a building
ing systems included in the survey.
such as cooling towers, vessels, and piping. Data forms,
6.1.1 Establishing the Purpose of the Survey—The purpose
supplies, and equipment must be sufficient to address multiple
of the Baseline Survey is to identify suspect asbestos-
buildings if necessary.
containing materials as defined in the scope of the survey.
6.1.3.2 ACM should be identified in the Baseline Survey
Management of theACM will include normal O&M activities
regardless of whether it is used as a construction material or
over a long term and will include prioritizing asbestos hazards
not, and whether located inside, outside or underneath the
for the purpose of planning future abatement activities. If the
building, as long as the area inspected is within the scope of
inspection is for pending demolition or renovation activities,
survey. This should specifically include stored materials such
see Section 7 on Project Design Surveys.
as gaskets, packing, or insulation not yet installed in or on the
6.1.2 Deciding Who Conducts the Survey—Whether the
facility.
inspection is conducted by an outside consultant or in-house
6.1.3.3 In some industrial facilities, there may be gaskets,
staff,theinspectorshallbeproperly-credentialedasanasbestos
packing, and other ACM installed in equipment (such as
building inspector by either federal EPA or an EPA approved
furnaces) that are not part of the building systems (such as
stateprogramundertheModelAccreditationPlan.Theinspec-
HVAC). The equipment may be in operation at the time of the
tor may also be required to be licensed by the state, city, or
survey, or the suspected ACM may be inaccessible for other
local jurisdiction of the inspection, or combination thereof.
reasons. For example, the inspector may lack the tools and
6.1.2.1 In-house staff should have a more intimate knowl-
skills to properly disassemble the equipment for access to the
edge of the locations of suspect materials and the use and
suspected ACM. The scope of work for the survey should be
occupancyoftheareascontainingthosematerials.Bulksample
clearastowhetherthisequipmentistobeinspectedandunder
collection by in-house inspectors may be useful when dealing
whatcircumstances.Themostconvenient,andoftenthesafest,
with emergency repairs or planning operations and mainte-
time to inspect such equipment is when it is out of service for
nance activities when only a few bulk samples are required.
maintenance or while production is interrupted. The plant
However, in-house staff usually has other responsibilities that
manager should make a list of equipment with suspect ACM
may preclude the timely completion of a baseline survey, and
and the plant’s O&M plan should specify if and when gaskets,
they may not have the experience necessary to perform a
packing, etc., are to be sampled.
thorough survey.
6.1.2.2 The outside consultant should have insurance cov- 6.1.4 Inspection Requirements—Atypicalscopeofworkfor
ering asbestos operations to insulate the owner from potential an asbestos survey will address the following topics: survey
E2356 − 18
protocol, what materials will be sampled, what materials will building function. The survey report will include a complete
be presumed/assumed (floor tiles, floor tile mastic, roofing laboratory report detailing the analysis of each bulk sample
materials, gaskets, and packings), what materials will not be analyzed. Applicable sections of this practice, including
included in the survey, quantification of materials, areas of the appendices, should be referenced in the report (see 6.7).
building/facility to be surveyed, access to specific areas of the Preparation of the survey report will be facilitated if the forms
building/facility (high ceilings, vaults, computer rooms, roofs, used for data collection in the field are designed so they are
etc.), areas of the building/facility not to be surveyed (pipe consistent in format with corresponding tables in the report. If
chases, wall cavities, roofs), numbers of samples, quality information is recorded electronically in the field it may be
control, follow-up analyses (point-counting, TEM), time possible to import the files directly into the survey report.
schedules, and deliverables (reporting, reporting format, floor
6.1.7 Schedule—A schedule must be coordinated with the
plansordrawing,andsoforth).Bulksamplingshallbedoneto
building owner that will provide access as necessary for a
prove that the material in question is notACM. Otherwise the preliminary site visit, as well as the performance of the
suspectmaterialshallbeassumedtobeACM,anddocumented
comprehensive survey. Contractual issues on completion of
and managed accordingly (see Appendix X1, Sampling Tech- work and submission of report must also be addressed as
niques and Equipment).
planning issues.
6.1.4.1 Under this practice, a minimum of three bulk 6.1.7.1 Preliminary site visits may be scheduled at any time
samples representative of each different homogeneous area of and should give the inspector an indication of the type and
suspect material to be sampled shall be collected and analyzed variety of suspect materials present, the scope or extent of the
to prove that the material sampled is notACM. See 6.4.6.1 for work, and normal use and occupancy of various areas of the
specific minimum numbers of samples by type of suspect facility.Typicallythepreliminarysitevisitprovidestheinspec-
material. Situations that call for more than the accepted tor(s) the opportunity to become familiar with a building/
minimum should be called to the attention of the building facility and provides an opportunity to ask questions affecting
owner. the performance of the survey to develop a cost proposal for
the completion of the survey.
6.1.4.2 Fieldnotebooksshouldincludeformsforthecollec-
6.1.7.2 Bulk sampling activities should be scheduled when
tion of information as follows: a complete list and location of
thefunctionalspacestobeinspectedareunoccupied.Thismay
functional spaces to be inspected (see 6.4.2); bulk sample logs
meannightorweekendwork,asthecasemaybe.Aninspector
(see 6.4.3); a complete list and location of suspect materials
shallnotdisturbsuspectmaterialintheunprotectedpresenceof
and homogeneous areas (see 6.4.5); chain of custody (see
building occupants. Facilities that operate on a 24-h basis may
6.4.9.1); assessment information (see 6.6). Samples of forms
havetoisolateordemarcateareasforsamplingormayassume
are provided in Appendix X3, Field Data Collection Forms.
allidentifiedsuspectmaterialsinareasthatmaynotbeisolated
6.1.4.3 Destructive testing is not performed on a Baseline
tobeACM.BecauseOSHAregulationsrequiresrespiratorand
Survey and therefore suspect materials in concealed spaces are
protective clothing use in the absence of a negative exposure
not directly sampled, assessed or quantified. However, the
assessment, sampling in unoccupied areas is least troublesome
inspector may, if specifically requested by the building owner,
to both the building owner as well as the inspector. Security
indirectly infer the location, quantity and condition of con-
systems or escort, or both, may also have to be coordinated
cealed suspect materials on the basis of information from
with the owner.
accessible confirmedACM that appears to be part of the same
homogeneous area. In this case the concealed material will be
6.2 Estimating the Cost of the Survey—Estimated Cost of
treated as ACM. The assumptions on which such extrapola-
Survey—Many factors affect the cost of performing a compre-
tions are based should be clearly spelled out in the survey
hensive asbestos survey. Some of these factors may vary over
report.
time and may be dependent upon regional, state, or other
economic factors such as salaries, benefits, cost of living, and
6.1.5 Analytical Requirements—At a minimum, Polarized
Light Microscopy (PLM) shall be used to analyze bulk the economic condition of the companies, or individuals
samples, as described in 6.5.1.1. A laboratory qualified in performing the survey or laboratory analyses. This practice
accordancewith5.6.1shallbeused.Ifconfirmationofnegative does not attempt to identify or address those issues. This
PLM results by gravimetric analysis and quantitative Trans- practice attempts to identify, but not quantify, the most com-
mission Electron Microscopy (TEM) may be required, a mon components that affect the cost of performing a compre-
laboratory with those capabilities must be selected.Adetermi- hensive asbestos survey. Companies or individuals purchasing
nation shall be made initially that all samples required to be asbestos survey services should clearly define the scope of
collected will be analyzed unless the “positive stop” approach services to obtain the most accurate and comprehensive price.
described in 6.5.5 is used.
6.2.1 The preliminary site visit may or may not affect the
price of the survey. Depending upon the contractual arrange-
6.1.6 Survey Report—Asurveyreportwillbegeneratedthat
ment and the company providing the proposal, the time and
should include; at a minimum; the date of the inspection and
expense of the preliminary site visit may be absorbed into the
report; the accreditation number and dates of accreditation for
cost of doing the survey or provided without charge.
the inspector(s) conducting the survey; identification,
quantification, and location of all suspect material; an indica- 6.2.2 Document Review—The review of construction docu-
tion of whether the material isACM or non-ACM; assessment mentsincludingspecifications,blueprintsandpossiblyproduct
informationonconditionofACM;andhowtheACMrelatesto receipts provide information regarding asbestos-containing
E2356 − 18
products, locations, and quantities. This review is typically that all samples are accounted for and proper chain-of-custody
performed after the survey contract is awarded; however, a ismaintained.Shippingtothelaboratorywillbedeterminedby
preliminary review of these documents may be helpful in the time schedule of the survey or by the need to identify
determining the number of samples necessary. The extent and specific asbestos, or non-asbestos-containing material (see
ultimatecostofthereviewwillbedependentuponthescopeof 6.4.9).
the survey, the size of the facility being inspected,
6.2.7 Quantifying Asbestos-containing Materials—
organization/accessibility of the documents, and the amount of
Asbestos-containing materials (assumed and confirmed)
documents to be reviewed.
should be quantified as part of the comprehensive asbestos
6.2.3 Survey Preparation and Mobilization—Prior to begin- survey.Itmaybepossibletoreducethebudgetofthesurveyby
ning the survey a number of technical and logistical tasks are postponing the quantification process until the laboratory
required to prepare for the survey. Time is required to gather
reports are received allowing for the quantification of only the
field supplies and coordinate travel. When surveys require air confirmedACMs rather than all suspect materials. However, it
travel, it may be most cost-effective to ship supplies and
may be most cost effective to develop quantities of limited
materials to the survey site in advance. In this case, shipping homogeneousareasorwhenlimitednumbersofsuspectACMs
fees would apply. If materials are not shipped, additional
are sampled, rather than returning to the survey site a second
baggage fees may apply when baggage limits are exceeded, time. The Project Manager should determine the most cost-
and extra time may be needed to clear airport security.
effective method of quantification of ACMs based on the
specifics of the survey.
6.2.4 Travel—Travel time is a factor in developing the cost
ofthesurvey.Thecostmaybeincludedinthebillingrateofthe
6.2.8 Assessing Asbestos-Containing Materials—Physical
consultants performing the survey or may be billed at a full
and hazard assessments should be performed for asbestos-
rate, or reduced hourly/daily rate.
containing materials (presumed and confirmed) as part of the
6.2.5 Survey Personnel—Surveys should preferably be per- comprehensive asbestos survey. It may be possible to reduce
formedinteamsoftwoormoreindividualsinordertoprovide thebudgetofthesurveybyperformingtheseassessmentsafter
a more thorough inspection and to provide an added safety for the laboratory reports are received so that only the confirmed
theteammembers.Personsinvolvedinthesurveymayinclude ACMs are assessed rather than all suspect materials. However,
aPrincipalorTechnicalDirector,ProjectManager,andSurvey it may be more cost effective to perform these assessments at
the time of the survey when limited functional spaces, homo-
Team Members, or individuals with equivalent titles.
geneous areas or numbers of suspectACMs are identified.The
6.2.5.1 The Principal/Technical Director has the overall
Project Manager should determine the most cost-effective
authority and responsibility for the successful completion of
method of assessment of ACMs based on the specifics of the
the survey.The Principal/Technical Director should insure that
survey.
the scope and technical aspects of the survey conform to
regulatory and professional standards. The Principal/Technical 6.2.9 Data Review and Interpretation—It is important to
Director is also responsible for the fiscal aspects of the survey providesufficienttimetoreviewthesurveylaboratorydataand
and should insure that the budget for the survey is appropriate. interprettheresults.Timeisneededtodetermineifappropriate
The Principal/Technical Director typically has the highest homogenousareashavebeenidentifiedandtoidentifytheneed
billing rate of the personnel on the survey. His involvement is for follow up analyses such as PLM point count or confirma-
necessaryatthebeginningofthesurveytoreviewtheproposed tory TEM.
scope of work and budget, during the survey to review
6.2.10 Report preparation is performed by the Project Man-
technical and budgetary progress, and at the completion of the
ager and the Survey Team members. Other individuals that
survey to review the final work product to insure it is
may be utilized during report preparation include a draftsman/
technically sound. On large surveys, the Principal/Technical
computer aided drafting designer and clerical staff. Completed
Director may want to attend the Preliminary Site Visit (see
reports should always be reviewed by a Principal/Technical
6.1.7.1).
Director or the Project Manager to insure compliance with the
6.2.5.2 The Project Manager has the responsibility for the scope of work, standards of the industry, and technical com-
survey team and the performance of the scope of work. The
petence.
ProjectManagershouldpossesstheexperienceandknowledge
6.2.11 Laboratory Fees—Completebudgetsforcomprehen-
to complete the survey in the given survey environment.
sive surveys should include all analyses required for the
Accordingly, the Project Manager will have the highest billing
completion of the survey. Laboratory fees will vary depending
rate for those in the field performing the work. The Project
upon the location of the laboratory, the workload of the
Manager is utilized in all phases of the survey.
laboratory, the number of samples being submitted, the type of
6.2.5.3 Survey Team Members work with the Project Man-
analyses requested, and the turn-around time for the results.
ager on-site to complete the scope of the survey. Team
Somelaboratoriescha
...

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: E2356 − 14 E2356 − 18
Standard Practice for
Comprehensive Building Asbestos Surveys
This standard is issued under the fixed designation E2356; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope
1.1 This practice describes procedures for conducting comprehensive surveys of buildings and facilities for the purpose of
locating, identifying, quantifying, and assessing asbestos-containing materials.
1.2 The results of a Comprehensive Building Asbestos Survey are intended to be used for ongoing management of
asbestos-containing materials, including Operations and Maintenance (O&M), removal, and other response actions. This includes
response actions associated with renovations. A Comprehensive Building Asbestos Survey is also intended to provide information
required for removal of asbestos-containing materials prior to demolition of a building or facility.
1.3 This practice discusses three types of surveys: Baseline Surveys, Project Design Surveys, and Pre-Construction Surveys.
1.4 This practice discusses the following activities for each of the above types of surveys:
1.4.1 Planning the survey to meet defined objectives;
1.4.2 Obtaining and reviewing information on the building or facility including previous surveys and response actions;
1.4.3 Conducting the physical activities of inspecting the premises and collecting bulk samples of suspect materials;
1.4.4 Analyzing the bulk samples for asbestos type and content;
1.4.5 Assessing the Current Condition and Potential for Disturbance of asbestos-containing materials; and
1.4.6 Preparing a report that includes a narrative discussion of the findings, tabulations of inspection, sampling and analysis
results, graphical depiction of the areas inspected, and the results of the assessment.
1.5 A Comprehensive Building Asbestos Survey provides sufficient information about the asbestos-containing materials in a
building or facility for purposes of a real property transaction. In situations where the amount of information required by a party
to the transaction is minimal, a Limited Asbestos Screen (see Practice E2308) may suffice in place of the Comprehensive Building
Asbestos Survey.
1.5 This practice does not include air sampling or surface (dust) sampling for purposes of evaluating a potential exposure hazard
from airborne asbestos fibers. The reader may find assistance with exposure assessment determination by reviewing Practice
D7886.
1.6 Warning—Asbestos fibers are acknowledged carcinogens. Breathing asbestos fibers can result in disease of the lungs
including asbestosis, lung cancer, and mesothelioma. Precautions in this practice should be taken to avoid creating and breathing
airborne asbestos particles from materials known or suspected to contain asbestos. See 2.2 for regulatory requirements addressing
asbestos.
1.7 The values stated in SI units are to be regarded as standard. The values given in parentheses are mathematical conversions
to inch-pound units that are provided for information only and are not considered standard.
1.8 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility
of the user of this standard to establish appropriate safety safety, health, and healthenvironmental practices and determine the
applicability of regulatory limitations prior to use.
1.9 This international standard was developed in accordance with internationally recognized principles on standardization
established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued
by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
This practice is under the jurisdiction of ASTM Committee D22 on Air Quality and is the direct responsibility of Subcommittee D22.07 on Sampling and Analysis of
AsbestosSampling, Analysis, Management of Asbestos, and Other Microscopic Particles.
Current edition approved Jan. 15, 2014Oct. 1, 2018. Published January 2014October 2018. Originally approved in 2004. Last previous edition approved in 20102014 as
E2356 – 10.E2356 – 14. DOI: 10.1520/E2356-14.10.1520/E2356-18.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E2356 − 18
2. Referenced Documents
2.1 ASTM Standards:
D7521 Test Method for Determination of Asbestos in Soil
D7712 Terminology for Sampling and Analysis of Asbestos
D7886 Practice for Asbestos Exposure Assessments for Repetitive Maintenance and Installation Tasks
E631 Terminology of Building Constructions
E1368 Practice for Visual Inspection of Asbestos Abatement Projects
E1494 Practice for Testing Physical Properties of Friable Surfacing Materials
E2308 Guide for Limited Asbestos Screens of Buildings (Withdrawn 2014)
E2394 Practice for Maintenance, Renovation, and Repair of Installed Asbestos Cement Products
MNL-23 Manual on Asbestos Control: Surveys, Removal, Assessment, Abatement, and Management – SecondThird Edition,
2.2 Other Documents:
29 CFR 1910.134 Respiratory Protection Standard
29 CFR 1910.146 Permit-requiredPermit-Required Confined Spaces
29 CFR 1926 Subpart AA Confined Spaces in Construction
29 CFR 1926.1101 Occupational Exposure to Asbestos (OSHA Construction Standard)
40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants: Subpart M—Asbestos
40 CFR Part 763, Appendix E to Subpart E Interim Method of the Determination of Asbestos in Bulk Insulation Samples
(Section 1, Section 2 only as applicable), 1987
40 CFR Part 763 40 CFR Part 763, Subpart E Subpart E—Asbestos-Containing Asbestos-Containing Materials in Schools (EPA
AHERA Regulations)
40 CFR Part 763763, Subpart E, Appendix C Subpart E, Appendix C (EPA Model Accreditation Plan)
EPA 560/5-85-024 Guidance for Controlling Asbestos-Containing Materials in Buildings (“Purple Book”), 1985
EPA 560 ⁄5-85-030A Asbestos in Buildings: Simplified Sampling Scheme for Surfacing Materials (“Pink Book”), 1985
EPA 600R-04 ⁄004 Research Method for Sampling and Analysis of Fibrous Amphibole in Vermiculite Attic Insulation, January
EPA 600 ⁄R-93 ⁄116 Method for the Determination of Asbestos in Bulk Building Materials, June 1993
State of New York Environmental Laboratory Approval Program (ELAP) Certification Manual, Item No. 198.1 Polarized Light
Microscopy Method for identifying and Quantifying Asbestos in Non-Friable Organically Bound Bulk Samples, May 15,
State of New York Environmental Laboratory Approval Program (ELAP) Certification Manual, Item No. 198.4Managing
Asbestos in Buildings Transmission Electron Microscopy Method for identifying and Quantifying Asbestos in Non-Friable
Organically Bound Bulk Samples, March 1, 1997A Guide for Owners and Managers, March 2015
2.3 ISO Standards:
ISO/IEC 17025 Testing and Calibration Laboratories
3. Terminology
3.1 Definitions—For definitions of building terms, see Terminology E631.
3.2 Terms Defined in PracticeE1368—The user is referred to Practice E1368 for terms specifically related to asbestos abatement
for purposes of a Project Design Survey.
3.2.1 asbestos-containing materials, n—material containing more than one percent asbestos.
3.2.1.1 miscellaneous materials, n—material, other than surfacing material and thermal system insulation, on interior and
exterior structural, mechanical, electrical, or architectural components, and surfaces. Miscellaneous material includes but is not
limited to ceiling tiles, gaskets, floor coverings and mastics, wallboard joint compound, roofing materials, and cementitious
products.
3.2.1.2 surfacing material, n—material that is sprayed, troweled-on, or otherwise applied to interior and exterior structural and
architectural surfaces. Surfacing material includes acoustical plaster on ceilings, fireproofing on structural members, textured paint
and exterior stucco, and other materials applied to surfaces for acoustical, decorative, fireproofing, and other purposes.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM Standards
volume information, refer to the standard’sstandard’s Document Summary page on the ASTM website.
Available from Occupational Safety and Health Administration (OSHA), 200 Constitution Ave., NW, Washington, DC 20210, http://www.osha.gov.
Available from United States Environmental Protection Agency (EPA), Ariel Rios William Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
http://www.epa.gov.
Available from the Environmental Laboratory Approval Program (ELAP), Wadsworth Center, P.O. Box 509, Albany, NY 12201, http://www.wadsworth.org/labcert/
elap/elap.htm. Environmental Information Association, Inc. (EIA), 6935 Wisconsin Avenue Suite 306 Chevy Chase, MD 20815-6112, https://eia-usa.org.
Available from International Organization for Standardization (ISO), ISO Central Secretariat, BIBC II, Chemin de Blandonnet 8, CP 401, 1214 Vernier, Geneva,
Switzerland, http://www.iso.org.
E2356 − 18
3.2.1.3 thermal system insulation, n—material which is applied to interior and exterior mechanical components to reduce heat
gain or loss. Thermal system insulation includes insulation on pipes, fittings, boilers, breeching, tanks, ducts, and other mechanical
components.
3.2.2 crawl space, n—an accessible area that may have a dirt floor, usually with low head room.
3.2.3 high effıciency particulate air (HEPA) filter, n—the final stage filter on a negative pressure ventilation device (see 3.2.19
in Practice E1368)) or on a vacuum cleaner, capable of trapping and retaining at least 99.97 percent of all mono-dispersed particles
of 0.3 micrometres in diameter.
3.2.4 dust and debris, n—visible particles, fragments, or chunks of material, large enough to have settled in the work area by
virtue of their weight, that are presumed to have originated from the material abated by the response action, or from a fiber release
episode.
3.2.5 fiber release episode, n—uncontrolled or unintentional disturbance of asbestos-containing materials which results in the
generation of dust and debris.
3.2.6 friable material, n—material easily crumbled or powdered by moderate (hand) pressure.
3.2.7 response action, n—a method of abatement (such as removal, encapsulation, or enclosure) or operations and maintenance
(such as repair, clean-up, or preventive measures) of asbestos-containing material in any form, for any purpose whatsoever.
3.2.8 visual inspection process, n—the activities before, during, and at the conclusion of a response action that are associated
with detecting the presence of visible residue, dust and debris, or unremoved material and verifying the absence thereof at the
completion of a response action.
3.3 Definitions of Terms Specific to This Standard:
3.3.1 asbestos, n—the asbestiform varieties of: chrysotile (serpentinite); crocidolite (riebeckite); amosite (cummingtonite-
grunerite); anthophyllite; tremolite; and actinolite.
3.3.1 accessible location, n—a functional space or part thereof that can be inspected without requiring destructive testing or
presenting an unacceptable health or safety risk to the inspector, and where entry is not prohibited by security or other institutional
restrictions.
3.3.2 building asbestos survey, n—an activity to determine the presence, location, condition, and quantity of asbestos-containing
materials in a building or facility, or on the property containing the building or facility.
3.3.3 bulk sample, n—a sample of suspect asbestos-containing material collected for identification of asbestos and determination
of the percent of the components in the sample.
3.3.4 concealed space, n—a location requiring destructive testing for penetration of a building or component surface for
inspection and, if necessary, sampling of suspect material. Concealed spaces include, but are not limited to, cavities inside soffits,
walls and chases, plenums above solid ceilings, sub-floor ducts and cable runs, and the interior of HVAC equipment.
3.3.5 destructive testing, n—inspection procedures that necessarily involve objectionable or noticeable damage to building
surfaces, or require penetration of a surface such as a wall, ceiling, chase, or shaft to gain access to a concealed space. Lifting a
ceiling tile or opening a hatch is not destructive testing.
3.3.6 excluded area, n—a functional space or part thereof where entry is prohibited by security or other institutional restrictions.
3.3.7 functional space, n—an area within a building or facility that is used for a specific purpose. Examples include a warehouse
in a manufacturing plant and a conference room in an office building. A functional space can be vertical in extent, such as a pipe
chase, and span several floors.
3.3.8 homogeneous area, n—surfacing material, thermal system insulation material, or miscellaneous material that is uniform
in color and texture and apparent or known date of installation.
3.3.9 laboratory, n—an entity that is equipped and qualified to perform one or more of the following analyses, using approved
methods: (1) identify and quantify asbestos in bulk samples by Polarized Light Microscopy, (2) identify and quantify asbestos in
bulk samples by Transmission Electron Microscopy, and (3) identify perform counting procedures and quantify airborne fibers with
Phase Contrast Microscopy.
3.3.10 limits of abatement, n—an area where asbestos-related activities will be conducted before, during and at the conclusion
of the project, that is contiguous with and includes the limits of construction for an associated renovation or demolition project.
3.3.11 non-friable organically bound (NOB) materials, n—materials that are not friable and that consist of fibers and other
particulate matter embedded in a solid matrix of asphaltic, vinyl or other organic substances.
3.3.12 operations and maintenance (O&M) program, n—a proactive management program to provide periodic surveillance of
asbestos-containing materials, maintain them in good condition, mitigate fiber release from existing asbestos-containing materials,
and clean up asbestos-containing dust and debris that has been released, in order to minimize worker or occupant exposure to
asbestos fibers.
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3.3.13 polarized light microscopy (PLM), n—a method of analytical mineralogy that uses an optical microscope to determine
the optical properties of sample constituents and, in the case of bulk sample analysis for asbestos, to provide positive identification
of suspect fibers as asbestos and to quantify the percent of asbestos in the sample.
3.3.14 skim coat, n—a thin finish coat applied to an existing plaster surface or other substrate to improve appearance or other
reasons.
3.3.15 suspect material, n—material that is sampled or is presumed to contain asbestos on the basis of its location, purpose,
appearance, and other factors considered by the inspector.
3.4 Terms Defined in Practice D7521: D7712:
3.4.1 asbestos, n—a collective term that describes a group of naturally occurring, inorganic, highly fibrous, silicate dominated
minerals, which highly-fibrous, silicate minerals that are easily separated into long, thin, flexible flexible, strong fibers when
crushed or processed.
3.4.1.1 Discussion—
Included in the definition are the asbestiform varieties of serpentine (chrysotile); riebeckite (crocidolite); grunerite (grunerite
asbestos [Amosite]); anthophyllite (anthophyllite asbestos); tremolite (tremolite asbestos); and actinolite (actinolite asbestos). The
amphibole mineral compositions are defined according to the nomenclature of the International Mineralogical Association.
3.4.1.2 Discussion—
The mineral fibers described in this definition are listed below. This method is also applicable to other mineral fibers of interest
not listed in Table 1.
3.5 Acronyms:
3.5.1 ACM—Asbestos-containing material(s)
3.5.2 AHERA—Asbestos Hazard Emergency Response Act
3.5.3 EPA—U.S. Environmental Protection Agency
3.5.4 HEPA—High Efficiency Particulate Air
3.5.5 NAD—No Asbestos Detected
3.5.6 NESHAP—National Emission Standards for Hazardous Air Pollutants; specifically, the National Emission Standard for
Asbestos (40 CFR Part 61, Subpart M)
3.5.7 NOB—Non-friable organically-bound
3.5.8 OSHA—U.S. Department of Labor, Occupational Safety and Health Administration
3.5.9 PPE—Personal Protective Equipment
3.5.10 PLM—Polarized Light Microscopy
3.5.11 TEM—Transmission Electron Microscopy
3.5.12 VAI—Vermiculite Attic Insulation
4. Significance and Use
4.1 Management of asbestos-containing materials in buildings and facilities requires knowledge of the location, type, quantity,
and condition of the material. The more complete and accurate the information available, the more appropriate and cost-effective
are the control measures used to reduce possible exposure to airborne asbestos fibers. This is true whether the asbestos-containing
materials remain undisturbed and completely intact, are selectively removed for maintenance or prior to renovation, or are removed
to the greatest extent feasible before demolishing the building or facility.
TABLE 1 Asbestos
Chemical Abstract
Asbestos
Service No.
Chrysotile 12001-29-5
Crocidolite 12001-28-4
Amosite 12172-73-5
Anthophyllite asbestos 77536-67-5
Tremolite asbestos 77536-68-6
Actinolite asbestos 77536-66-4
Asbestos 1332-21-4
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4.2 This practice describes three types of surveys that support different objectives. These are the Baseline Survey, the Project
Design Survey, and the Pre-Construction Survey.
4.2.1 The Baseline Survey is a building-wide or facility-wide inspection that provides a general sense of the overall location,
type, quantity, and condition of asbestos-containing materials present. It is thorough in that most accessible functional spaces are
inspected and bulk samples taken of suspect materials observed. The baseline survey provides information for long-term
management of asbestos-containing materials and prioritization of response actions. The presence of asbestos in suspect materials
may be assumed or presumed in some cases without bulk samples being taken or analyzed. However, the baseline survey is
unobtrusive in that samples are not taken where doing so would result in objectionable damage to surfaces or where institutional
barriers preclude access. In a baseline survey, destructive testing is avoided. Posting of signs and labels required for compliance
with OSHA regulations would use the information generated during a Baseline Survey.
NOTE 1—A Baseline Survey is sometimes called an “AHERA” survey because it provides the type of information used for management of
asbestos-containing materials in schools. However, the baseline survey described in this practice requires inspection, bulk sampling, quantification, and
assessment of suspect materials that are excluded by virtue of their type and location from the AHERA regulations for schools.
NOTE 2—Suspect material subject to disturbance by planned or emergency maintenance may not always be identified as to asbestos content in a
Baseline Survey. Collecting a single bulk sample, or a small number of samples, to determine if the material contains asbestos does not constitute a survey
within the meaning of this practice. Nonetheless, the sample(s) should be collected in accordance with the methods described in Appendix X1 (this must
be done by a properly-credentialed individual) and analyzed as set forth in 6.5.
4.2.2 The Project Design Survey is more focused than a Baseline Survey and is used to provide information to the Project
Designer for preparing abatement plans and specifications. The locations inspected are limited to the areas that will be affected by
the abatement project. If the project is being done prior to renovation or demolition, the construction plans or at least a clear
statement of the scope of the renovation or demolition work are required for a proper Project Design Survey. Destructive testing
is often required for a Project Design Survey. The presence of asbestos in suspect materials is always confirmed in a Project Design
Survey rather than being assumed or presumed. Other information required for the Project Design is collected during the survey.
4.2.3 The Pre-Construction Survey is performed in anticipation of renovation or demolition where a Baseline Survey has not
been conducted and there is no information, or insufficient information, as to the existence of asbestos-containing materials within
the planned limits of construction. The Pre-Construction Survey requires destructive testing if concealed spaces are to be breached
during construction. If asbestos-containing materials are found, a Project Design Survey is conducted to provide information for
preparing the plans and specifications. The Pre-Construction Survey satisfies the EPA NESHAP requirements for renovation or
demolition to “thoroughly inspect the affected facility” or the requirements of governmental agencies for issuance of a building
permit.facility.”
NOTE 3—On August 7, 2015, the EPA published a clarification letter allowing for the use of the Pre-Construction Survey for compliance for the asbestos
NESHAP requirements to “…thoroughly inspect the affected facility…” [40 CFR Part 61.145(a)] . This clarification letter can be found on the EPA’s
Applicability Determination Index (ADI) as item number A150001. The clarification letter explains what sections of this practice must be used for
compliance.
4.3 The inter-relationships among the three types of surveys and with other ASTM asbestos control standards is shown in Fig.
1.
4.4 This practice emphasizes the concept that a Comprehensive Building Asbestos Survey consists of more than the collection
and analysis of samples, and the report is more than a compilation of laboratory results. It is important to inspect as many
functional spaces as possible and to document the reasons why certain functional spaces were not inspected and locations where
no suspect materials were observed and, consequently, no samples were taken. Reasons might include access limitations, the
absence of materials to sample, the existence of information from previous surveys, or the availability of reliable documentation
such product data sheets or Safety Data Sheets (previously known as Material Safety Data Sheets.Sheets, MSDS) where the content
of that document specifically details the absence of added asbestos. It is worthy to note that it can be difficult to find MSDS or
product data sheets for installed materials or in older buildings or structures. It is also known that asbestos content was not always
disclosed in these documents. In other cases there may be a material descriptions (as with asphaltic roofing products) where the
term “encapsulated asbestos” is used. Terms of this nature do not do not constitute the absence of asbestos. If the absence of
asbestos is not clearly noted on these documents they should not be used to eliminate an installed material from a survey.
4.5 A Comprehensive Building Asbestos Survey is not limited to the class of materials commonly referred to as
asbestos-containing building materials (ACBM), defined in the AHERA regulations as “. found in or on interior structural
members or other parts of a building.” Items that are difficult to distinguish as such may include cooling towers, laboratory hoods,
gaskets, chalkboards, and other articles. These may be installed in, attached to, or adjacent to the building or facility but are not
as clearly a part of the building or facility as fireproofing or floor tile. Nonetheless, such items still fall within the scope of an
asbestos management program and therefore are addressed in this practice. Locations outside the building, in particular equipment
in industrial facilities and power plants, and crawl spaces underneath the building are within the scope of a Comprehensive
Building Asbestos Survey.
4.6 This practice is intended to be used by individuals who are conducting a Comprehensive Building Asbestos Survey for the
owner or manager of a building or facility under a contractual arrangement for services as well as by employees of the owner or
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FIG. 1 Relationship Between E2356 Surveys and Other Standards
manager. If the individual is conducting the survey under a contractual arrangement (which may be with the firm employing the
individual), the owner or manager of the building is still responsible for certain activities as described in this practice.
5. Qualifications and Responsibilities
5.1 This section describes the qualifications and responsibilities of the individuals who participate in the Comprehensive
Building Asbestos Survey. The requirement for accreditation as an Inspector in accordance with the Model Accreditation Plan
applies to the activities covered by this practice. Additional accreditations may be required, and qualifications may be imposed by
state licensing (certification) requirements or the policies of the owner or manager of the building or facility that are beyond the
scope of this practice. Field experience in performing asbestos building surveys as described in this practice is of paramount
importance.
5.2 Not all of the qualifications discussed herein will be required for every Comprehensive Building Asbestos Survey
conducted, and in many cases one individual (usually the accredited inspector) will have more than one, and possibly all, of the
required credentials.
5.3 Qualifications and responsibilities of individuals conducting the survey:
5.3.1 Accredited Inspector—For both types of surveys, accreditation as an Inspector is required for the individual who takes the
bulk samples and otherwise performs the physical activities comprising the survey. This includes review of relevant building
documentation and preparation of the survey report.
5.3.2 Management Planner—For a baseline survey, accreditation as a management planner is only required for hazard
assessment and determination of response actions if the survey is performed in a school, but is a desirable credential for all
buildings and facilities.
5.3.3 Project Designer—For a project design survey, accreditation as a project designer is desirable because this survey will
provide information for the plans and specifications to be used on an abatement project.
5.3.4 Contractor/Supervisor—For a project design survey, accreditation as a contractor/supervisor would be helpful because of
the knowledge of abatement processes such an individual possesses.
5.4 In addition to the above accreditations, the following credentials are evidence of the ability to perform one or more of the
aspects of a Comprehensive Building Asbestos Survey.
5.4.1 Credentials that indicate knowledge of building design include experience in building design, construction, or operations
and academic degree(s), licensure, or registration as an architect or engineer.
5.4.2 Credentials that indicate knowledge of building design include experience in building design, construction, or operations
and academic degree(s), licensure, or registration as an architect or engineer. Academic such as academic degree(s) or certification
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in industrial hygiene, occupational safety, or a related field indicates knowledge of the hazardous properties of asbestos and other
substances as well as the means of controlling the hazards.
5.4.3 Credentials that indicate knowledge of building construction and operations include field experience in building
construction, renovation, demolition, or maintenance, or a combination thereof; or formal or on-the-job training in construction
technology or management.
5.5 Qualifications and Responsibilities of Owner or Manager of Building or Facility—To be able to provide the necessary
information, access, and other support to the inspector(s), the staff of the building or facility owner or manager should have taken
at least a two-hour Asbestos Awareness course.
5.6 Laboratories analyzing the samples shall possess one or more of the following qualifications in addition to, or as part of,
any applicable state licensing requirements.
5.6.1 For bulk sample analysis using Polarized Light Microscopy:
5.6.1.1 Accreditation by the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Institute of
Standards and Technology (NIST), or that offered by the other accrediting organizations that assures that participant laboratories
are in compliance with the international laboratory standard through ISO/IEC 17025;
5.6.1.2 Participation in the Bulk Asbestos Proficiency Analytical Testing Program (BAPAT) provided by the American Industrial
Hygiene Association (AIHA) Bulk Asbestos Proficiency Analytical Testing Program, Programs, LLC; and
5.6.1.3 Certification under the State of New York Environmental Laboratory Approval Program (ELAP),requirements found in
state or local asbestos regulations where this and issue is addressed.
5.6.1.4 Participation in a proficiency testing and certification program similar to 5.6.1.1 – 5.6.1.3.
5.6.2 For bulk sample analysis of NOBs using Transmission Electron Microscopy, the laboratory shall be certified under the
State of New York Environmental Laboratory Approval Program (ELAP) or provide other evidence of capability and experience
with the ELAP method or its equivalent acceptable to the consultant.
5.6.2 Air samples are not collected or analyzed from the areas where bulk samples are obtained as part of a Comprehensive
Survey.
6. Baseline Surveys
6.1 Planning the Survey—It is essential that the planning stage of an asbestos survey be complete in addressing the following
issues and be defensible. A well-planned survey will consult other appropriate professionals, trades, or knowledgeable individuals
who may provide valuable information regarding systems included in the survey.
6.1.1 Establishing the Purpose of the Survey—The purpose of the Baseline Survey is to identify suspect asbestos-containing
materials as defined in the scope of the survey. Management of the ACM will include normal O&M activities over a long term
and will include prioritizing asbestos hazards for the purpose of planning future abatement activities. If the inspection is for
pending demolition or renovation activities, see Section 7 on Project Design Surveys.
6.1.2 Deciding Who Conducts the Survey—Whether the inspection is conducted by an outside consultant or in-house staff, the
inspector shall be properly-credentialed as an asbestos building inspector by either federal EPA or an EPA approved state program
under the Model Accreditation Plan. The inspector may also be required to be licensed by the state, city, or local jurisdiction of
the inspection, or combination thereof.
6.1.2.1 In-house staff should have a more intimate knowledge of the locations of suspect materials and the use and occupancy
of the areas containing those materials. Bulk sample collection by in-house inspectors may be useful when dealing with emergency
repairs or planning operations and maintenance activities when only a few bulk samples are required. However, in-house staff
usually has other responsibilities that may preclude the timely completion of a baseline survey, and they may not have the
experience necessary to perform a thorough survey.
6.1.2.2 The outside consultant should have insurance covering asbestos operations to insulate the owner from potential liability.
In most cases, conflict of interest issues would be best avoided by using an outside consultant. Typically, outside consultants can
complete a survey in a more timely fashion and provide a more thorough and unbiased report than in-house personnel.
Additionally, building owners and managers can benefit from the consultant’sconsultant’s experience gained while inspecting other
facilities.
6.1.3 Establishing the Scope of the Survey—It is essential that the inspector have documented, in writing, the exact scope of
work for which he is responsible. A Baseline Survey would normally be comprehensive in nature. However, if the inspection is
to be limited to certain buildings, or portions of buildings, the specific areas to be inspected must be documented in order for the
inspector to achieve substantial completion of the contract, and not be held responsible for further work. One of the most important
functions in-house personnel can provide is to participate in determining the purpose of the survey, planning the survey and
reviewing the results of the inspection done by the outside consultant. In-house personnel should also play a role with providing
access to all areas of the building/facility to the survey team(s) and be available to answer questions posed by the survey team and
the building occupants.
6.1.3.1 Identify buildings, or portions of buildings, to be inspected. Each individual building shall be inspected separately and
all functional spaces inspected, whether or not bulk samples are taken therein. A separate set of homogeneous areas of suspect
material shall be identified, sampled or assumed, and determined to be ACM or non-ACM per building. A homogeneous area may
E2356 − 18
not be extended to include more than one building, but may include components exterior to a building such as cooling towers,
vessels, and piping. Data forms, supplies, and equipment must be sufficient to address multiple buildings if necessary.
6.1.3.2 ACM should be identified in the Baseline Survey regardless of whether it is used as a construction material or not, and
whether located inside, outside or underneath the building, as long as the area inspected is within the scope of survey. This should
specifically include stored materials such as gaskets, packing, or insulation not yet installed in or on the facility.
6.1.3.3 In some industrial facilities, there may be gaskets, packing, and other ACM installed in equipment (such as furnaces)
that are not part of the building systems (such as HVAC). The equipment may be in operation at the time of the survey, or the
suspected ACM may be inaccessible for other reasons. For example, the inspector may lack the tools and skills to properly
disassemble the equipment for access to the suspected ACM. The scope of work for the survey should be clear as to whether this
equipment is to be inspected and under what circumstances. The most convenient, and often the safest, time to inspect such
equipment is when it is out of service for maintenance or while production is interrupted. The plant manager should make a list
of equipment with suspect ACM and the plant’s O&M plan should specify if and when gaskets, packing, etc., are to be sampled.
NOTE 3—Gaskets are usually installed in bolted flange fittings. If only one or two fittings are being worked with, the gaskets can be presumed to be
asbestos-containing material (PACM) and the employee instructed to follow appropriate procedures. For such small-scale work, it may be faster and
cheaper to follow these procedures rather than to sample and analyze the gaskets. If an inspector were to sample for demolition purposes, the same
restrictions would apply. In a demolition situation, it makes more sense to cut the pipe, leave the fittings intact, and dispose of them.
6.1.4 Inspection Requirements—A typical scope of work for an asbestos survey will address the following topics: survey
protocol, what materials will be sampled, what materials will be presumed/assumed (floor tiles, floor tile mastic, roofing materials,
gaskets, and packings), what materials will not be included in the survey, quantification of materials, areas of the building/facility
to be surveyed, access to specific areas of the building/facility (high ceilings, vaults, computer rooms, roofs, etc.), areas of the
building/facility not to be surveyed (pipe chases, wall cavities, roofs), numbers of samples, quality control, follow-up analyses
(point-counting, TEM), time schedules, and deliverables (reporting, reporting format, floor plans or drawing, and so forth). Bulk
sampling shall be done to prove that the material in question is not ACM. Otherwise the suspect material shall be presumedassumed
to be ACM, and documented and managed accordingly. (Seeaccordingly (see Appendix X1, Sampling Techniques and
Equipment)Equipment).
6.1.4.1 Under this practice, a minimum of three bulk samples representative of each different homogeneous area of suspect
material to be sampled shall be collected and analyzed to prove that the material sampled is not ACM. See 6.4.6.1 for specific
minimum numbers of samples by type of suspect material. Situations that call for more than the accepted minimum should be
called to the attention of the building owner.
6.1.4.2 Field notebooks should include forms for the collection of information as follows: a complete list and location of
functional spaces to be inspected (see 6.4.2); bulk sample logs (see 6.4.3); a complete list and location of suspect materials and
homogeneous areas (see 6.4.5); chain of custody (see 6.4.9.1); assessment information (see 6.6). Samples of forms are provided
in Appendix X3, Field Data Collection Forms.
6.1.4.3 Destructive testing is not performed on a Baseline Survey and therefore suspect materials in concealed spaces are not
directly sampled, assessed or quantified. However, the inspector may, if specifically requested by the building owner, indirectly
infer the location, quantity and condition of concealed suspect materials on the basis of information from accessible confirmed
ACM that appears to be part of the same homogeneous area. In this case the concealed material will be treated as ACM. The
assumptions on which such extrapolations are based should be clearly spelled out in the survey report.
6.1.5 Analytical Requirements—At a minimum, Polarized Light Microscopy (PLM) shall be used to analyze bulk samples, as
described in 6.5.1.1. A laboratory qualified in accordance with 5.6.1 shall be used. If confirmation of negative PLM results by
gravimetric analysis and quantitative Transmission Electron Microscopy (TEM) may be required, a laboratory with those
capabilities must be selected. A determination shall be made initially that all samples required to be collected will be analyzed
unless the “positive stop” approach described in 6.5.5 is used.
6.1.6 Survey Report—A survey report will be generated that should include; at a minimum; the date of the inspection and report;
the accreditation number and dates of accreditation for the inspector(s) conducting the survey; identification, quantification, and
location of all suspect material; an indication of whether the material is ACM or non-ACM; assessment information on condition
of ACM; and how the ACM relates to building function. The survey report will include a complete laboratory report detailing the
analysis of each bulk sample analyzed. Applicable sections of this practice, including appendices, should be referenced in the report
(see 6.7). Preparation of the survey report will be facilitated if the forms used for data collection in the field are designed so they
are consistent in format with corresponding tables in the report. If information is recorded electronically in the field it may be
possible to import the files directly into the survey report.
6.1.7 Schedule—A schedule must be coordinated with the building owner that will provide access as necessary for a preliminary
site visit, as well as the performance of the comprehensive survey. Contractual issues on completion of work and submission of
report must also be addressed as planning issues.
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6.1.7.1 Preliminary site visits may be scheduled at any time and should give the inspector an indication of the type and variety
of suspect materials present, the scope or extent of the work, and normal use and occupancy of various areas of the facility.
Typically the preliminary site visit provides the inspector(s) the opportunity to become familiar with a building/facility and
provides an opportunity to ask questions affecting the performance of the survey to develop a cost proposal for the completion of
the survey.
6.1.7.2 Bulk sampling activities should be scheduled when the functional spaces to be inspected are unoccupied. This may mean
night or weekend work, as the case may be. An inspector shall not disturb suspect material in the unprotected presence of building
occupants. Facilities that operate on a 24-h basis may have to isolate or demarcate areas for sampling or may assume all identified
suspect materials in areas that may not be isolated to be ACM. Because OSHA regulations requires respirator and protective
clothing use in the absence of a negative exposure assessment, sampling in unoccupied areas is least troublesome to both the
building owner as well as the inspector. Security systems or escort, or both, may also have to be coordinated with the owner.
6.2 Estimating the Cost of the Survey—Estimated Cost of Survey—Many factors affect the cost of performing a comprehensive
asbestos survey. Some of these factors may vary over time and may be dependent upon regional, state, or other economic factors
such as salaries, benefits, cost of living, and the economic condition of the companies, or individuals performing the survey or
laboratory analyses. This practice does not attempt to identify or address those issues. This practice attempts to identify, but not
quantify, the most common components that affect the cost of performing a comprehensive asbestos survey. Companies or
individuals purchasing asbestos survey services should clearly define the scope of services to obtain the most accurate and
comprehensive price.
6.2.1 The preliminary site visit may or may not affect the price of the survey. Depending upon the contractual arrangement and
the company providing the proposal, the time and expense of the preliminary site visit may be absorbed into the cost of doing the
survey or provided without charge.
6.2.2 Document Review—The review of construction documents including specifications, blueprints and possibly product
receipts provide information regarding asbestos-containing products, locations, and quantities. This review is typically performed
after the survey contract is awarded; however, a preliminary review of these documents may be helpful in determining the number
of samples necessary. The extent and ultimate cost of the review will be dependent upon the scope of the survey, the size of the
facility being inspected, organization/accessibility of the documents, and the amount of documents to be reviewed.
6.2.3 Survey Preparation and Mobilization—Prior to beginning the survey a number of technical and logistical tasks are
required to prepare for the survey. Time is required to gather field supplies and coordinate travel. When surveys require air travel,
it may be most cost-effective to ship supplies and materials to the survey site in advance. In this case, shipping fees would apply.
If materials are not shipped, additional baggage fees may apply when baggage limits are exceeded, and extra time may be needed
to clear airport security.
6.2.4 Travel—Travel time is a factor in developing the cost of the survey. The cost may be included in the billing rate of the
consultants performing the survey or may be billed at a full rate, or reduced hourly/daily rate.
6.2.5 Survey Personnel—Surveys should preferably be performed in teams of two or more individuals in order to provide a more
thorough inspection and to provide an added safety for the team members. Persons involved in the survey may include a Principal
or Technical Director, Project Manager, and Survey Team Members, or individuals with equivalent titles.
6.2.5.1 The Principal/Technical Director has the overall authority and responsibility for the successful completion of the survey.
The Principal/Technical Director should insure that the scope and technical aspects of the survey conform to regulatory and
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