- supplying personal protective equipment (PPE),
- providing quantitative respirator fit testing,
- providing respirator medical evaluations,
- our monthly Safety Suzy newsletter with content on asbestos, mold, indoor air quality, and occupational safety and health information,
- our blog where we post items of interest and discussion,
- our negative air app,
- our air sampling charts,
- our training library,
- our partnership with SiteDocs,
- and all of it found on FEDTC's website.
Future Environment Designs Training Center specializes in asbestos, indoor air quality, industrial hygiene, and occupational safety training programs. We offer New York State asbestos and mold certification courses. We design, develop, and maintain the various indoor air quality, asbestos, and safety programs that are Keeping Your Employees Safe.
Search This Blog
Friday, October 10, 2025
Future Environment Designs, Inc. Celebrates 37 Years in Business With a New Program Called "After The Refresher"
Tuesday, February 18, 2025
The Role of Asbestos Inspections in Construction Safety: Don't Miss the Asbestos Inspection Panel at PACNY's Environmental Conference!
In the construction world, one of the most pressing concerns for worker safety is the potential asbestos exposure. This hazardous material, once commonly used in various building materials for its fire-resistant and other properties, has been linked to serious health risks, including lung cancer, asbestosis, and mesothelioma. Asbestos exposure remains a significant threat, especially in older buildings undergoing renovation or demolition. The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) have set strict guidelines to minimize this danger, but compliance hinges on one key factor: thorough and accurate asbestos inspections.
To explore the intricacies of asbestos inspections, Angelo Garcia, III of Future Environment Designs, Inc., will be moderating a distinguished panel at PACNY's 2025 Environmental Conference on Thursday, February 27, 2025. The panel will dive deep into the importance and differences in asbestos inspections from various perspectives. This includes Tom Laubenthal of TGL Consulting and ASTM E2356 Chairman, who will discuss the ASTM asbestos inspection standard, Chris Alonge now with Dormitory Authority of the State of New York (DASNY) who will provide insights from an owner's perspective, Marc Rutstein from Environmental Consulting & Management Services, who will offer a consultant's viewpoint and highlight the differences between NYCDEP and NYSDOL inspections, and Matt Brooks from International Asbestos Removal (IAR), who will speak on the contractor’s perspective.
![]() |
Asbestos pipe insulation with fitting insulation |
Asbestos inspections play a vital role in identifying materials that may contain asbestos before they are disturbed. This proactive approach not only prevents worker exposure but also ensures that proper abatement procedures are followed. A well-executed asbestos inspection is the first line of defense against the release of airborne asbestos fibers, which can be deadly when inhaled.
Understanding the Importance of Homogeneous Areas
At the heart of every asbestos inspection is the process of determining whether a material is classified as a surfacing material, thermal system insulation, or miscellaneous material. Once the material type is identified, the inspector must establish whether the materials are homogeneous. According to the EPA’s Asbestos Hazard Emergency Response Act (AHERA), a homogeneous area is defined as one where the material is uniform in color and texture.
Floor tiles and numerous homogeneous areas |
However, that is not the only definition of homogeneous area/material. For example, the American Society for Testing and Materials (ASTM) has established a Standard Practice for Comprehensive Asbestos Surveys (ASTM E2356-18) in this standard the definition of homogeneous area is surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture and apparent or known date of installation. The other definitions that are used by inspectors also include some reference to installation or formulation in addition to color and texture. This classification is crucial because it informs the number of samples that must be taken to accurately assess the presence of asbestos.
Sampling Procedures: The Foundation of a Successful Inspection
For surfacing materials, the size of the homogeneous area directly influences the number of samples needed. Under the EPA’s guidelines, inspectors follow the “3-5-7 rule.” This means that three samples are required for areas smaller than 1,000 square feet, five samples for areas between 1,000 and 5,000 square feet, and seven samples for areas larger than 5,000 square feet. Additionally, the EPA’s “Pink Book,” formally known as Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials, recommends taking nine samples per homogeneous area, regardless of the square footage, for increased accuracy.
Asbestos Fireproofing |
For thermal system insulation, the process differs slightly. Inspectors must determine if the material is homogeneous, patch material, or material used on fittings like elbows and valves. Homogeneous areas of thermal system insulation require three samples, while patch materials smaller than six linear or square feet only need one sample (the only time one sample is allowed). Cement or plaster used on fittings must be sampled based on the specific mechanical system in question, and a minimum of two samples is required for each system. However, the EPA in A Guide to Performing Reinspections Under AHERA strongly advises taking at least three samples in larger homogeneous areas, even if regulations don't mandate it.
For materials such as joint compound and add-on materials, however, the EPA’s “Asbestos Sampling Bulletin dated September 30, 1994” specifies that three samples are required for each material. These distinctions are critical for asbestos inspectors to ensure compliance and accuracy in their assessments (see our original blog post on asbestos surveys).
In May 2007, the EPA provided important clarification on sampling requirements. Mr. Chris Alonge, at the time, was working for New York State Department of Labor (NYSDOL) and he requested clarification regarding the number of samples that should be taken for each suspect asbestos-containing homogeneous miscellaneous material. The clarification was distributed by the Professional Abatement Contractors of New York (PACNY) in November 2007. According to this clarification, the minimum number of samples that should be taken of miscellaneous materials (i.e., floor tiles, roofing, caulk, ceiling tiles) is two (see our original blog post on this issue).
Respirator and protective clothing should be worn by the inspector during sampling |
Following proper sampling protocols is crucial because asbestos is considered present if any one of the samples from a homogeneous area contains more than 1% asbestos. Conversely, if all samples return asbestos concentrations at or below 1%, the area is deemed asbestos-free—though it’s important to remember that materials containing 1% or less of asbestos are still regulated under OSHA’s asbestos standard (see the Varga letter).
The Legal and Health Implications of Incomplete Inspections
Inadequate or incorrect asbestos inspections can have severe consequences. From a legal standpoint, failing to adhere to EPA and OSHA regulations can result in hefty fines and penalties. Remember neither regulation has a specific end date for buildings not containing asbestos (see our post Is There an Appropriate End Date for Asbestos Use?). More importantly, from a health perspective, improperly identifying or failing to identify asbestos-containing materials (ACMs) can expose construction workers to dangerous fibers, leading to long-term health problems. Given that asbestos-related diseases may take decades to develop, the human cost of negligent inspections can be devastating.
![]() |
The closet door with asbestos core was cut without any precautions costing over $30,000 to clean up the contamination. |
Mr. Tom Laubenthal wrote EPA in November 2014 regarding The Standard Practice for Comprehensive Asbestos Surveys (ASTM E2356-18) Pre-Construction Survey (section 8 of the standard) meeting the requirement under National Emissions Standards of Hazardous Air Pollutants (NESHAPS) of a thorough inspection. EPA responded that they would expect an owner/operator to follow the steps in Sections 1 through 5 and Section 8 to comply with the NESHAPS regulation. This standard provides a framework for conducting thorough asbestos inspections, particularly in pre-construction scenarios, ensuring that no asbestos-containing material goes unnoticed.
Conclusion: The Essential Role of Inspections
Asbestos inspections are the cornerstone of any effort to protect workers from exposure to this hazardous material. By adhering to the EPA’s and OSHA’s strict sampling and inspection guidelines, inspectors can identify asbestos-containing materials before they are disturbed, reducing the risk of airborne fibers and subsequent health issues. Given the serious implications of asbestos exposure, thorough inspections are not just a regulatory requirement—they are a moral imperative in safeguarding the health and well-being of workers.
![]() |
Asbestos Floor Tiles disturbed before identification led to a clean-up costing over $250,000 |
In the end, the responsibility lies with all stakeholders—building owners, contractors, and asbestos inspectors alike—to ensure that every construction or renovation project is free from asbestos hazards. As inspectors, staying current on regulations, maintaining rigorous sampling standards, and educating clients on the risks and regulations associated with asbestos are critical components in this ongoing battle against a deadly substance.
The asbestos inspection panel promises to be an invaluable session for professionals across the construction, consulting, and regulatory industries. With these diverse viewpoints, we aim to shed light on the critical role inspections play in protecting workers and ensuring compliance with ever-evolving asbestos regulations. Asbestos inspections are not just about checking boxes—they are about saving lives.
Saturday, July 09, 2022
AHERA Bulk Sampling Rules and Other Requirements that Apply to Asbestos Surveys.
Saturday, June 05, 2021
Is There an Appropriate End Date for Asbestos Use?
When we first became an asbestos consultant over 39 years ago, we remember people telling us that buildings will remove all their
asbestos materials in 5 years, 10 years, or 15 years depending on who we talked to. Well, asbestos is still in
buildings and this article is about why there are many years still left in this industry. In the construction industry, there are some who think that a certain
year was the end of asbestos use in building materials. Over the years we have reviewed many asbestos
inspection reports or property transfer reports (phase I environmental audits)
reporting that since a building or a part of a building was built after 1980
there are no asbestos-containing materials.
The companies making this statement assume that the federal government
banned all asbestos-containing materials in 1980. In
Terrazo? |
The federal agency with
the responsibility for banning asbestos is the EPA. This agency, under the National
Emissions Standards for Hazardous Air Pollutants (NESHAPS), banned the use of
asbestos for sprayed-on application of fireproofing and insulating in 1973 and
for decorating purposes in 1978. In 1975 EPA’s NESHAPS regulation
also banned the installation of pre-formed (molded) asbestos block insulation
on boilers and hot water tanks and the wet-applied and pre-formed (molded)
asbestos pipe insulation. Since two of
these bans did not go into effect until after 1974, the
Electrical wire insulation |
Is there an appropriate
end date for asbestos use in buildings? Some headlines indicate the answer to this question is no. These headlines indicate that some current building
materials are contaminated with asbestos or still contain asbestos sufficiently
enough for the materials to be considered asbestos-containing materials. For example, the Asbestos Disease Awareness
Organization (ADAO) reported in November 2007 that they sampled a number of current
building materials and determined that DAP’s “33” window glazing and “crack
shot” spackling paste and Gardner’s leak stopper roof patch all contained
asbestos. DAP’s “33” window glazing was
purchased at Home Depot and Lowes for the purpose of the study and contained 2.6%
tremolite, and 0.13% chrysotile asbestos (2.73% total asbestos). DAP’s “crack shot” spackling paste was also purchased
at Home Depot and Lowes and contained 0.98% tremolite, and 0.066% chrysotile
asbestos (1.05% total asbestos).
asbestos woven products |
The Liability of Ignorance
Since there is no total ban on the use of asbestos
in building materials, it means that 1974 or 1980 are not appropriate cut off
dates on the use of asbestos in building materials. This means all buildings or facilities no matter when they were constructed should be inspected for asbestos-containing materials. EPA's NESHAP regulation 40 CFR 61.145 Standard for demolition and renovation requires buildings/facilities to be thoroughly inspected before the renovation or demolition, no matter what date the building was built. It also means that the construction industry
should be very careful when working on buildings after these dates because it
is possible that if an asbestos inspection or survey was done it may have not been done properly. From our experience, we've seen inspectors not sample roofing materials, joint compound, sheetrock, textured paint, siding shingles, and window caulking just to name a few building materials that should be sampled. Building owners,
banks, facility managers, architects, engineers, general contractors, and
subcontractors should not think that because the EPA regulation requires an inspection, and if the inspection is not done correctly that there is no chance for a violation or liability. OSHA requires that employers inform their
workers of all the potential hazards at a project (job) site. Should materials that were not inspected turn
out to be asbestos-containing or even if the sample result is 1% or trace asbestos and the exposure exceeds the permissible exposure
limit (0.1 fibers per cubic centimeter based on an eight hour time-weighted
average) or the excursion limit (1.0 fibers per cubic centimeter over thirty
minutes) the employer would be in violation of the OSHA asbestos
regulation. No matter the construction
date of the building. The building owner
could then face third-party litigation from the workers if they develop a
disease (mesothelioma being the most significant because of its direct tie to
asbestos exposure) from such an exposure. In addition, the AHERA regulation which
applies to public and private schools (kindergarten to 12th grade) requires that architects that design new
schools or renovations of existing schools certify that the building materials
used do not contain asbestos. Utilizing safety data sheets (SDS), which are required for most building
products, to certify the products would not be sufficient considering that
DAP’s SDS (discussed above) did not mention the asbestos contamination in the product and the NESHAPS regulation requires building materials to be sampled for the content of asbestos. Meaning the only way to certify the products
to limit liability would be to have suspected materials sampled and analyzed
for asbestos. It is very important for
building owners, banks, facility managers, architects, engineers, general
contractors, sub-contractors, asbestos inspectors, and phase I environmental
auditors to realize that although the asbestos regulations refer to dates before 1980, inspections are advisable and required under the EPA's NESHAPS & OSHA's asbestos regulations since the
installation of asbestos-containing materials into buildings can continue to this
day.
![]() |
Fire Door |
Tuesday, March 31, 2020
Proficiency Day - Day One of PACNY's 24th Annual Environmental Conference!
![]() |
Poll Everywhere Result |
![]() |
Mr. James Meacham, P.E. discussing Contamination Assessments |
![]() |
Bart Gallagher discussing the Case Study |
![]() |
"Remember I'm not in the book" |
Thursday, March 28, 2019
Proficiency Day Awards Architects & Engineers 3 Professional Development Hours - PACNY's 23rd Annual Environmental Conference - Day One
![]() |
Karen Cummings, MPH presenting on the Asbestos Safety Training Program |
![]() |
Angelo Garcia, III, CIEC, CEOP, presenting on Asbestos Inspections & NYCDEP Changes |
The final presentation was "New York City Title 15 Amendments" also presented by Mr. Angelo Garcia, III, CIEC, CEOP, and again this presentation can be found in the Dropbox folder. This presentation was on the recent changes to the New York City Department of Environmental Protection's (NYC DEP's) Title 15 Asbestos Regulation (formerly known as Local Law 76). These changes were made because of the arrest of 17 NYC asbestos investigators (see the above video on the press conference on the arrests) and the recommendations of the New York City Department of Investigations (NYC DOI). These changes included additional requirements for NYC Asbestos Investigators and some changes to other parts of the asbestos regulations. See our previous blog post on these new requirements.
![]() |
TS Steakhouse Waitress making the "Gotham" |
Related Articles:
- NYCDEP Asbestos Rule Amendment Goes Into Effect January 6, 2019
- Countdown to PACNY's 23rd Annual Environmental Conference Begins!
Thursday, February 07, 2019
Countdown to PACNY's 23rd Annual Environmental Conference Begins!
It all begins on Wednesday, February 27, 2019, at 12:30 PM with a presentation from Ms. Karen Cummings, M.P.H., New York State Department of Health's (NYSDOH's) Director of the Asbestos Safety Training Program. Her presentation will update us on the status of asbestos training in NYS. Along with some failings of training providers. It will continue with presentations from Pete Delucia & Gregg Mance, both of AAC Contracting and myself, Angelo Garcia, III, of Future Environment Designs (#FEDTC), discussing asbestos inspection requirements, and polling of the audience to make this presentation interactive. Finishing the session will be a presentation of the amendments to the New York City Department of Environmental Protection (NYDEP's) Title 15 Asbestos Regulations (NYCDEP has been invited to present by teleconference). We have also submitted the information regarding this day of the conference to the Practicing Institute of Engineering (PIE) for the purpose of being able to award three (3) Professional Development Hours (PDH) to the attendees. The President's Reception is later that evening.
The second day will include presentations by Ms. Sue Rossi, of Waste Management, discussing "Waste Management NY Landfills with acceptance of waste streams"; Adam Schrader of Ecospect with George Schanbach, of NYS AARST, discussing Radon and DOH Regulations Update"; Brian Sampson, of Unshackle Upstate, discussing Albany 2019 What You Need to Know and How it Will Impact Your Business"; Mike Rubin Esq., Partner at Goldberg Segalla, discussing "Best Practices for Abatement Contractors"; Mike Waller, of Rochester Regional Health, discussing "Sustainability?solutions and How to Balance"; and a representative of EIA discussing the "TSCA Update". The vendor reception/networking will follow the presentations on Thursday.
![]() |
NYSDOL Panel 2018 |
![]() |
Sheryl Esposito Will Be Back at the FEDTC booth this year! |
Related Articles:
- Winter Storm Impacts PACNY Conference, Part One.
- PACNY's Second Day, Part Two - A Storm is Coming!
- PACNY's Environmental Conference, Part Three-Bomb Cyclone Hits
Tuesday, July 05, 2016
Asbestos Dust Sampling in New York State
![]() |
Asbestos Inspector Initial Course |
![]() |
SKC Catalog Photo |
- This test method does not describe procedures or techniques required for the evaluation of the safety or habitability of buildings with asbestos-containing materials, or compliance with federal, state, or local regulations or statutes.....
- At present, a single direct relationship between asbestos sampled from a surface and potential human exposure does not exist.....
Friday, July 25, 2014
NYSDOH Announces The Imminent Availability of Vermiculite Analysis
Vermiculite-containing Sprayed-on Fireproofing is the focus of the communication |
日本語: バーミキュライト (Photo credit: Wikipedia) |
Future Environment Designs, Inc. Celebrates 37 Years in Business With a New Program Called "After The Refresher"
On October 5, 1988, Angelo Garcia, III, founded Future Environment Designs, Inc. (FEDTC) as an indoor air quality consulting and training s...

-
The New York City Department of Environmental Protection (NYC DEP) has introduced proposed amendments to Chapter 1 of Title 15 of the Rules...
-
… … … This debate regarding asbestos floor tiles started at the Professional Abatement Contractors of New York's ...
-
Image via Wikipedia The National Institute for Occupational Safety and Health (NIOSH) today invited public comment on a draft document titl...