January 5, 2022



Commercial, industrial, and multi-family buildings about to undergo major renovations commonly contain hazardous materials, whether asbestos, lead, mercury-containing devices, Freon, PCBs, or others. They’re present in various building materials, painted surface coatings, mechanical equipment, or other items utilized for property operation.

Examples include, but are not limited to, old dial thermostats, fireproofing, floor coverings, adhesives, paints/varnishes, smoke detectors, and fluorescent lights. If left intact during renovations, they can create inhalation, ingestion, and dermal hazards that pose a significant risk to human health and the environment. These materials must be identified and managed properly to mitigate accidental human exposure and environmental risk; stay in good graces with regulators, and prevent project delays.

The safest and most effective approach is designing and executing a good abatement plan where highly skilled, licensed workers come in and properly remove potential offenders before the renovation begins.

Abatement is an involved process commanding adherence to tightly regulated protocol around securing materials, ensuring contaminants do not become airborne, properly containerizing and disposing of them in landfills permitted to accept these regulated wastes. It takes orchestration, with multiple trade contractors working in tandem, and ideally a third-party professional to oversee and streamline the entire process.


Full abatement is practical.

Mike Dustman, an SCS Engineers senior project manager who oversees environmental remediation jobs, recommends that property owners survey their buildings for the presence of hazardous materials before renovation begins and remove them, rather than remove some materials and entomb others—particularly for major overhauls.

“While a full, thorough abatement costs more upfront, it saves over the project span in both money and headaches. You will pay more to monitor and provide upkeep if you leave live building systems like plumbing and electricity entombed with asbestos or other hazardous materials. Leaving them in place can delay or complicate the renovation, or even impede ordinarily quick maintenance projects in the future,” Dustman says.

He illustrates using a scenario where asbestos-containing fireproofing left in exterior soffits holding the building’s roof drains caused expensive repairs later. A full asbestos containment must be set up when the drains leak to make a relatively simple plumbing repair. “To avoid situations like this, property owners should plan and budget to abate and remove all hazardous materials from their buildings fully,” Dustman says.

Suppose you have limited cleanup dollars, your resources for renovation shrink when involving abatement. Property owners without the upfront capital might limit the scope of their renovation at first. An initial survey helps determine where conducting abatement projects is necessary and where it is practical to leave materials in place while raising money to plan for a full abatement later.

Assessment and cleanup grant dollars may be available through U.S. Environmental Protection Agency (EPA) grants issued to local municipalities through Brownfield programs.


Planning for the future is key.

Prepare abatement design with thought to existing structural, mechanical, electrical, and plumbing designs that will either be retrofitted or use new building systems.

The design considers where those new systems will run, removing hazardous materials before installing new systems, preventing potential worker exposure and project delays. Contractors can safely and quickly access structural members, run new plumbing lines, or update interior finishes.

It’s on the property owner to identify potential hazardous building materials and equipment and inform renovation contractors of the presence and location of these materials preceding a renovation.

“The way we ensure and prove proper identification is by collecting bulk samples of suspect building materials and submitting them for lab analysis as part of the pre-renovation survey. The survey typically includes sampling building materials for asbestos, testing surface coatings for lead, and inventorying universal/hazardous waste items.

If the analysis does not detect the presence of harmful contaminants, you can safely proceed with your renovation project. However, if the survey identifies such contaminants, an abatement plan is necessary,” Dustman says.


A coordinated effort.

The first step is figuring out the abatement goal and the general contractor’s plans. And you must ask, what is the redesign of the building, its purpose, and the underlying material hazards?

Understanding the goals, what hazardous materials exist, and which materials will be impacted by a renovation allows for better awareness by all parties. It lowers the risk of accidental disturbance before and during removal, and it helps workers avoid disturbing hazardous materials until properly remediated.

The consultant that prepares the abatement design, the architect, engineers, and every party involved in the remodeling or renovation must be on the same page around such details as the scope of work, budget, and schedule. Transparency gives the abatement contractor and design consultant an understanding of what to clean before other trade contractors begin their work.


Preventing accidental exposure while work is in progress and upon project completion.

Worker safety is a common thread from start to finish. SCS performs daily air sampling throughout the removal process as third-party consultants to ensure the engineering controls are functioning as designed.

Enclosures are monitored during the renovation to confirm and document that no exposure is occurring outside of regulated work areas.

Once completing an area, Dustman’s team goes back in and visually inspects the work area, searching for remaining dust or debris. If the work area passes the visual inspection, they perform more air sampling to ensure safe reoccupation without respiratory protection.

In the case of a lead abatement project, the team conducts both air sampling and dust wipe clearance sampling. Dust wipe sampling is necessary since lead is a heavy elemental metal and quickly settles out of the ambient air and onto horizontal surfaces.

Once completing abatement, a close-out report confirms hazardous waste disposal to the appropriate regulatory enforcement agency. The report contains all air sampling and clearance data, with findings and conclusions supporting the data. “This report shows that you have executed and completed an effective abatement plan in compliance with federal, state, and local requirements,” Dustman says.


What if the building wasn’t, or couldn’t be, fully abated?

If hazardous materials remain, develop an operation and maintenance plan. It entails monitoring for future deterioration and meticulous recordkeeping documenting details such as type, location, and condition of remaining materials and removing or adding any materials. It’s a living document that is continually updated to determine when abatement is necessary and ensure that all details are readily available to move forward promptly.

“Identifying, removing, and properly disposing of hazardous materials found in your buildings before the renovation is an involved process with many steps. But every step counts to avoid occupant and worker exposures, accidental material disturbances, and to help complete your project on time,” Dustman says.


Michael Dustman’s experience is in environmental project management, remedial design activities, building inspection, site assessments, and field training. He possesses an in-depth knowledge of relevant and applicable Federal, State, and local environmental laws and protocols. Mike has served as project manager for numerous local agencies and private clients, including the U.S. Environmental Protection Agency (EPA) Region 4 Superfund Technical Assessment and Response Team (START), City of Kansas City, Missouri Brownfields Office, and Commerce Tower Redevelopment Team. Mike’s expertise includes natural disaster emergency responses to major floods, hurricanes, and tornadoes. He is a certified asbestos project designer, management planner, building inspector, certified air sampling professional, and certified lead-based paint risk assessor.


Additional Resources

Brownfields and Voluntary Remediation

Environmental Due Diligence

Health and Safety









Posted by Diane Samuels at 8:46 am