Commercial Floor Tile Removal
Does flooring contain asbestos?
Flooring, including sheet vinyl, floor tiles and any associated paper-like backing, adhesive or glue, can contain asbestos. Asbestos was added during the production of flooring to strengthen the flooring and to increase its durability.
When is flooring hazardous?
Flooring that contains asbestos, when intact and in good condition, is not considered hazardous.
However, heat, water, or aging can damage flooring to the point where it is friable. Friable means the flooring can be crumbled with hand pressure. Flooring can also be made friable during removal. Friable flooring can release asbestos into the air. Once in the air, asbestos is a health hazard when people breathe it.
When is flooring removal regulated?
MDH does not regulate non-friable materials. These are materials that cannot be crumbled, pulverized, or reduced to powder by hand pressure. However, if you are removing greater than 160 square feet of non-friable flooring material and the removal method you are using causes any portion to become friable, then removal must be performed according to all MDH regulations.
Removal methods that make non-friable flooring friable
Any removal method can make a non-friable flooring material friable. The following removal methods will make non-friable flooring material friable:
- shot blasting
- mechanical means (chipping, grinding, sanding, sawing, etc.)
The following removal methods have a lower chance of making non-friable flooring friable. But that doesn’t mean if they are used the floor tile is automatically considered non-friable:
- hand tools (ice chippers, spud bars, hammer and putty knife, etc.)
- dry ice
- heat or infrared
MDH and MPCA floor tile guidance
MDH, in conjunction with the Minnesota Pollution Control Agency (MPCA) has developed the following guidance as to when MDH and MPCA consider floor tile removal as regulated.
Removal of floor tile in commercial settings offers a unique challenge to licensed asbestos contractors. In its undisturbed state, floor tile may be classified as a nonfriable material and therefore non-regulated. However, floor tile may be damaged during a removal project to the extent that it would be considered a regulated friable material.
Building owners and contractors, both licensed and unlicensed, believe that using spud bars, ice chippers, etc., is always a non-regulated removal method because hand tools are being used. Using hand tools to remove floor tile does not mean the floor tile will remain nonfriable.
MDH and MPCA consider the damage done to the floor tile, even if hand tools are used for the removal. Damage directly relates to the friability of a material.
There is nothing in MDH’s or MPCA’s rules that states using hand tools is a non-regulated removal method. Hand tools may be used to remove floor tile, but if the floor tile becomes damaged or will become damaged, then the asbestos-containing floor tile will be regulated by MDH and MPCA.
The MDH had issued an administrative penalty order (APO) to a licensed asbestos contractor for failing to notify MDH and follow proper work procedures during a floor tile removal project. The asbestos contractor contested the APO and a hearing was held in front of an administrative law judge. The administrative law judge concluded that MDH had correctly determined that the floor tile had been rendered friable as defined by the Minnesota Rules and therefore the project was regulated by the MDH. Read the administrative law judge's recommendations in report number OAH No. 3-0900-15066-2 Findings of Fact, Conclusions, and Recommendations (PDF).
When non-friable flooring material becomes friable
Flooring material should remain intact during the removal process. If the flooring material being removed begins to break, the non-friable flooring material is now friable and regulated by MDH. See the guidance photographs or contact the Asbestos Program at MDH through the internet or by telephone at (651) 201-4620.
If more than 160 square feet of non-friable floor tile is being removed, and it might become friable, take the following steps:
- Submit a courtesy notification to the MPCA ten (10) working days in advance of the start date of the project. Do not submit courtesy notifications to MDH.
- When the floor tile becomes friable, stop work. The project is now regulated by MDH and MPCA.
- Inform MDH that an emergency notification is being submitted for the floor tile removal project.
- Amend the courtesy notice that was submitted to MPCA (see Step 1).
- After the emergency notice has been submitted, proceed to complete the work as a regulated asbestos project following all required work practices.
NOTE: The emergency notification and permit are issued only for the material that is part of the emergency situation! The permit and notification cannot be extended to any additional material.
For more information about asbestos, contact the Asbestos Program at MDH through the internet or by telephone at (651) 201-4620.
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