Simply stated: YES, unless you want to treat all the materials in your existing buildings as if they contain asbestos.

The Environmental Protection Agency's Asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP) Common Questions explains requirements in understandable language. Basically, the asbestos NESHAP requires a thorough inspection of both the inside and outside of a building before renovation or demolition. The asbestos NESHAP protects the general public from airborne contaminants that are hazardous to human health.

Two Occupational Safety and Health Administration (OSHA) standards affect our employees and contractors who work at our facilities. The General Industry Standard (29 CFR 1910.1001) covers custodial work and the Construction Standard (29 CFR 1926.1101) covers construction work including repair, renovation, telecommunications, and demolition. The OSHA Asbestos Fact Sheet summarizes OSHA asbestos regulations. OSHA requires that building owners communicate asbestos hazards to those who may be exposed to asbestos. To do so, the owner must know whether asbestos-containing materials (ACM) are present and if so, their location and quantity. Unless testing has been conducted that proves otherwise, OSHA regulations require building owners to presume that the following building materials contain asbestos if they were installed before 1981:

• Thermal systems insulation—includes furnace ductwork and water pipe insulation.
  
• Sprayed, troweled and other surfacing materials—includes popcorn and other texture on ceilings and walls.
  
• Resilient flooring—includes linoleum and vinyl tile and sheet flooring.

Guilty until proven innocent!

The NESHAP and OSHA regulations don't cover exactly the same set of circumstances. For instance, NESHAP asbestos regulations exempt residential buildings with four or fewer units, but OSHA covers employees working with ACM in residences. Building managers can be assured of compliance with all regulations if they have all buildings inspected both inside and outside.

Let’s not forget our own Forest Service directives:

• The Forest Service Manual 2167.13 says we must identify and effectively manage all asbestos-containing materials used in Forest Service-occupied buildings and activities.
  
  
• The Health and Safety Code Handbook 6709.11,60 calls for inspections before remodeling.
  
  
• The Buildings and Related Facilities Handbook 7309.11,40 calls for using accredited asbestos workers, establishing management plans, labeling asbestos, and transferring asbestos records with building ownership.