Background on AQMD Engagement Regarding Asbestos Abatement<\/p>\n
The City of Laguna Woods, in collaboration with the Village’s Manor Alterations Division,<\/p>\n
initially submitted an Air Quality Management District (AQMD) speaker request form to<\/p>\n
facilitate a town hall on February 22, 2024. The event aimed to address asbestos abatement<\/p>\n
concerns raised by Village residents.<\/p>\n
However, AQMD informed organizers that due to staffing and workload constraints, they were<\/p>\n
unable to provide a speaker for the scheduled event but committed to responding to submitted<\/p>\n
questions. Despite efforts by Manor Alterations and the City of Laguna Woods to reschedule<\/p>\n
the town hall for a later date, these attempts were unsuccessful.<\/p>\n
In response, Manor Alterations and the city actively sought community input to gather asbestos<\/p>\n
abatement-related questions. These questions were submitted to AQMD, which provided<\/p>\n
detailed responses. To ensure transparency and community awareness, Manor Alterations<\/p>\n
sought and obtained approval from Third\u2019s and United\u2019s Architectural Control and Standards<\/p>\n
Committees to publish AQMD\u2019s questions and answers for public access.<\/p>\n
This initiative underscores the Village’s commitment to addressing resident concerns and<\/p>\n
facilitating clear communication regarding asbestos abatement processes.
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Rule 1403 – Asbestos Emissions from Demolition\/Renovation Activities<\/p>\n
South Coast Air Quality Management District Overview<\/p>\n
This Q&A document aims to provide clear and concise information about asbestos demolition and<\/p>\n
removal requirements from South Coast Air Quality Management District (SCAQMD) in the event<\/p>\n
members of the Laguna Woods Village community apply for a permit with the City of Laguna<\/p>\n
Woods.<\/p>\n
1. Does SCAQMD recommend proactively abating undamaged \u201cpopcorn\u201d ceilings\/other<\/p>\n
undamaged asbestos-containing materials in dwelling units, or is abatement in conjunction with<\/p>\n
other renovation\/demolition work sufficient?<\/p>\n
SCAQMD does not make recommendations regarding abatement of undamaged asbestos-<\/p>\n
containing materials (ACM), such as intact \u201cpopcorn\u201d ceilings. Abatement is required when<\/p>\n
renovations or demolitions are planned because those activities could disturb ACM and release<\/p>\n
asbestos fibers into the air.<\/p>\n
2. Does SCAQMD offer guidance or suggestions for selecting a well-qualified certified asbestos<\/p>\n
consultant or certified asbestos contractor?<\/p>\n
SCAQMD does not make recommendations regarding hiring certified asbestos consultants or<\/p>\n
contractors. Key steps in choosing consultants or contractors include checking for state<\/p>\n
certifications, insurance, references and compliance with local regulations. The California<\/p>\n
Department of Industrial Relations provides the following:<\/p>\n
LJ<\/p>\n
Asbestos Consultants and Site Surveillance Technicians<\/p>\n
https:\/\/www.dir.ca.gov\/databases\/doshcaccsst\/caccsst_query_1.html<\/p>\n
LJ<\/p>\n
Contractors\/ Cal\/OSHA – Asbestos Registrants\u2019 Database<\/p>\n
https:\/\/www.dir.ca.gov\/Databases\/doshacru\/acrulist.asp<\/p>\n
3. What is the basis for Rule 1403 applying more involved standards to multi-unit dwellings?<\/p>\n
In detached single-unit dwellings, only the occupants are potentially exposed to hazardous<\/p>\n
emissions. In multi-unit structures, however, the actions of the occupants of one unit can affect the<\/p>\n
occupants of all the other attached units.
\n4. Is there a process whereby SCAQMD could be requested to consider modifying asbestos survey<\/p>\n
requirements for multi-unit dwellings (e.g., extending the same waivers that apply to single-unit<\/p>\n
dwellings to multi-unit dwellings when renovation activities are undertaken with the knowledge<\/p>\n
and consent of the owner of the multi-unit building)?<\/p>\n
Asbestos survey requirements under Rule 1403 cannot be modified. Any variances from Rule 1403<\/p>\n
requirements must be sought through the SCAQMD hearing board and would apply only to<\/p>\n
residential structures of four units or fewer. Multi-unit residential structures with greater than four<\/p>\n
units are also subject to the federal National Emissions Standards for Hazardous Air Pollutants<\/p>\n
(NESHAP).<\/p>\n
5. Are multiple detached single-unit dwellings on the same lot (e.g., detached condominium<\/p>\n
units) considered single-unit or multi-unit dwellings?<\/p>\n
The definition of a residential single unit dwelling per Rule 1403 explicitly states that townhouses<\/p>\n
and condominiums are not residential single-unit dwellings.<\/p>\n
6. If an asbestos survey was completed for renovation\/demolition work previously performed in<\/p>\n
the same dwelling unit in which future work is to be conducted, can that same asbestos survey<\/p>\n
be used in place of a new asbestos survey for the future work?<\/p>\n
In some cases, previous asbestos surveys can be used if the condition of the building materials have<\/p>\n
not changed from when the previous survey was conducted. However, specific circumstances of<\/p>\n
the situation and should be verified with SCAQMD to ensure Rule 1403 compliance.<\/p>\n
7. Can completing an asbestos survey for renovation and demolition work in a dwelling unit be<\/p>\n
skipped if all work is conducted as if asbestos were present (i.e., can renovation\/demolition work<\/p>\n
occur with the assumption asbestos is present)?<\/p>\n
It is not permissible to skip an asbestos survey by simply assuming the presence of asbestos. Rule<\/p>\n
1403 requires that all renovations and demolitions be preceded by an asbestos survey. Assuming a<\/p>\n
material contains greater than 1% asbestos only relieves the requirement for sample collection and<\/p>\n
analysis. Surveys also document the conditions and quantities of ACM, and proper documentation<\/p>\n
is required for regulatory compliance.<\/p>\n
8. Can completing an asbestos survey be skipped if the dwelling unit in which renovation\/or<\/p>\n
demolition work is to be conducted has been recently renovated?<\/p>\n
Even if a dwelling has been recently renovated, an asbestos survey is still required before new<\/p>\n
renovation or demolition work can begin.<\/p>\n
9. Is completing an asbestos survey required for a city to issue an \u201cafter-the-fact\u201d building permit<\/p>\n
for renovation\/demolition work in a dwelling unit when such work was conducted without first<\/p>\n
obtaining a city building permit? In other words, must a current occupant who is seeking to<\/p>\n
obtain a city building permit to legalize renovation\/demolition work conducted in years past by a<\/p>\n
previous occupant complete an asbestos survey?<\/p>\n
To comply with Rule 1403, an asbestos survey is required to be conducted prior to the renovation<\/p>\n
or demolition activity. SCAQMD cannot comment on what a city may require to issue a building<\/p>\n
permit.
\n10. Are there any circumstances in which asbestos surveys can be conducted by persons other<\/p>\n
than a certified asbestos consultant? Can asbestos surveys ever be conducted by owner-builders<\/p>\n
or contractors who are not certified asbestos consultants using National Voluntary Laboratory<\/p>\n
Accreditation Program laboratories?<\/p>\n
Under Rule 1403, asbestos surveys must be conducted by certified asbestos consultants.<\/p>\n
11. Are cities required to enforce SCAQMD Rule 1403?<\/p>\n
As part of their broader responsibility to protect public health and safety, cities should take steps to<\/p>\n
protect their citizens from exposure to asbestos. In our jurisdiction (which includes Orange County),<\/p>\n
however, SCAQMD is the designated agency responsible for enforcing asbestos laws, including both<\/p>\n
Rule 1403 and the corresponding federal asbestos regulations.<\/p>\n
12. Do cities have the ability to waive or modify provisions of SCAQMD Rule 1403?<\/p>\n
No.
\n13. Is an asbestos survey\/submission of a Rule 1403 notification form required for any of the<\/p>\n
following types of work in single-unit or multi-unit dwellings?<\/p>\n
Asbestos Survey by a Certified | Rule 1403 Notification<\/p>\n
Asbestos Consultant<\/p>\n
Form to SCAQMD<\/p>\n
(Yes or No)<\/p>\n
(Yes or No)<\/p>\n
Type of Work<\/p>\n
(Conducted as standalone work and<\/p>\n
Single Unit<\/p>\n
not a part of a larger project)<\/p>\n
(Personally<\/p>\n
conducted by<\/p>\n
Multi-Unit | Single-Unit | Multi-Unit<\/p>\n
Owner-Occupant<\/p>\n
ONLY)<\/p>\n
Installation of a natural light duct (e.g.,<\/p>\n
\u4e0d<\/p>\n
\u662f\u7684<\/p>\n
No*<\/p>\n
No*<\/p>\n
Solatube) that only requires opening a<\/p>\n
10-inch-diameter hole in a ceiling<\/p>\n
Installation of a bathroom fan that only<\/p>\n
requires opening a 9.5″ x 9.5″ opening<\/p>\n
\u4e0d<\/p>\n
\u662f\u7684<\/p>\n
No*<\/p>\n
No*<\/p>\n
in a ceiling<\/p>\n
Installation of a ductless mini split heat<\/p>\n
pump that only requires opening one<\/p>\n
\u4e0d<\/p>\n
\u662f\u7684<\/p>\n
No*<\/p>\n
No*<\/p>\n
3-inch diameter hole in a wall<\/p>\n
Installation of a new electric receptacle<\/p>\n
and new conduit to conceal wiring for<\/p>\n
\u4e0d<\/p>\n
\u662f\u7684<\/p>\n
No*<\/p>\n
No*<\/p>\n
a wall-mounted television that only<\/p>\n
requires opening two 4%” x 2%” holes<\/p>\n
in a wall<\/p>\n
Installation of drywall over an existing<\/p>\n
asbestos-containing \u201cpopcorn\u201d ceiling<\/p>\n
This activity is not allowed under Rule 1403(d)(1)(C)(ii)(1)<\/p>\n
(\u201cpopcorn\u201d ceiling is not scraped)<\/p>\n
Removing and replacing 1″ x 40″<\/p>\n
\u4e0d<\/p>\n
\u662f\u7684<\/p>\n
No*<\/p>\n
No*<\/p>\n
of drywall<\/p>\n
*A Rule 1403 notification is not required for abatement of less than 100 square feet of intact<\/p>\n
asbestos-containing materials (ACM). There is no exemption for damaged ACM.
\n14. Does SCAQMD offer, or is SCAQMD aware of, any financial assistance opportunities related to<\/p>\n
the abatement of asbestos in dwelling units?<\/p>\n
SCAQMD does not offer financial assistance, but state or federal programs may be available. Local<\/p>\n
agencies, nonprofit organizations or state health departments may have more information on<\/p>\n
assistance for asbestos abatement projects.<\/p>\n
For specific guidance or clarification regarding the requirements of Rule 1403, members of the<\/p>\n
public can contact SCAQMD directly by emailing Rule1403Notifications@agmd.gov, calling 909-<\/p>\n
396-2336 or consulting with a certified asbestos consultant.<\/p>\n
In addition, SCAQMD holds compliance assistance classes on Rule 1403 – Asbestos Emissions from<\/p>\n
Demolition\/Renovation Activities. Find registration information at<\/p>\n
https:\/\/www.agmd.gov\/home\/programs\/business\/training-1403-asbestos-demolition.<\/p>","protected":false},"author":28,"featured_media":0,"template":"","document_category":[1127],"document_type":[53],"class_list":["post-63093","document","type-document","status-publish","hentry","document_category-manor-alterations","document_type-other"],"acf":{"document":67920,"resolutions":null,"legacy_id":"","pdf_extracted_text":""},"yoast_head":"\n