Renovation & Demolition:
Environmental, Health & Safety Requirements You Should Know About
Do you do renovation or demolition work, or hire or oversee those who do?
If so, there are a number of environmental, health, and safety requirements that may apply to you.
Some of the more common and important of these requirements are listed below. Please note that not every possible requirement is listed, and that this information is only intended as a helpful summary.
If you would like more information about the requirements that apply to renovation and demolition, please contact the agencies listed in Table 1 at the bottom of this page.
| Asbestos |
Asbestos may be present in materials such as thermal systems insulation, flooring, plaster, wallboard, siding, roofing, and other materials. Residential structures with 5 or more units, and commercial, industrial, institutional, and public structures must be inspected by an asbestos consultant before renovation or demolition is started, to determine if asbestos is present. If a facility is structurally sound, all asbestos-containing material must be abated prior to demolition. Asbestos abatement involving more than 3 linear feet or more than 3 square feet must be performed by a licensed asbestos contractor. A notification must be submitted to DPH whenever more than 10 linear or 25 square feet of asbestos will be disturbed. A demolition notification be submitted to DPH for any structure that is demolished. Consultants and contractors are licensed by DPH. Asbestos is regulated as a "special waste," and cannot be disposed of with regular trash. Asbestos work must be done in accordance with worker protection requirements. Table 1, Key A1, B1, B8, C2, C3, D, & E.
| Lead-Based Paint |
The EPA Renovation, Repair, and Painting (RRP) Rule: Contractors performing renovation work that disturbs more than 6 square feet of interior painted surface per room or more than 20 square feet of exterior painted surface in a pre-1978 house must distribute the EPA “Renovate Right” brochure to the owner and occupants and get written confirmation that the owner and occupants have received it. The contractor must be an EPA RRP certified firm (application completed on EPA’s website). Renovation work must comply with all lead safe work practices. Employees performing renovation work must be EPA RRP certified renovators (to obtain this an employee must take a 1-day EPA-approved training course).
Lead abatement activities in dwellings with children under age six are subject to CT’s Lead Poisoning Prevention & Control Regulations. Only DPH licensed lead consultants, employing DPH certified lead inspectors, lead inspector risk assessors and/or lead planner project designers, may perform activities such lead inspections, lead risk assessments and lead abatement/management plan development. Only DPH licensed lead abatement contractors, employing DPH certified lead supervisors and/or lead abatement workers, may perform lead abatement work.
The HUD Lead Safe Housing Rule applies to HUD-funded rehabs of pre-1978 housing, and to required maintenance of pre-1978 HUD-assisted (e.g., Section 8) housing. Only DPH licensed lead consultants, employing DPH certified lead inspectors and/or lead inspector risk assessors, may perform lead inspections, risk assessments, hazard screens, and clearance examinations.
Lead-based paint wastes must be properly characterized to determine whether or not they are hazardous wastes. Persons engaged in "lead detection work" as defined in RCSA Section 20-478-1 must be licensed by DPH with respect to lead sampling and analysis. The removal of any lead paint must be done so as not to violate air or water pollution control requirements.
Worker safety requirements often apply to lead removal work (see separate section below).
Table 1, Key A2, B1, D, & E.
| Fugitive Dust and Air Emissions |
Dust emissions must be controlled (e.g., with water misting) to ensure that they do not cross any property line. Also, if crushing or other processing equipment is going to be used on-site, it may trigger certain air permitting requirements. On-site emissions of silica, nuisance dust or other particulates may pose a safety hazard, and may be subject to certain worker protection requirements. Table 1, Key B8, C2, D, & E.
| Wastewaters |
Activities like power-washing may generate wastewaters that must be collected and properly disposed. Such wastewaters must either be hauled off-site by a licensed hauler, or treated and discharged to the sanitary sewer (discharge to septic is not allowed). For a sanitary sewage discharge, permission must be obtained from the municipal sewer authority as well as from DEEP under its "Miscellaneous General Permit." In addition, sites with one or more acres of disturbed land are subject to the DEEP’s General Permit for the Discharge of Stormwater and Dewatering Wastewaters Associated with Construction Activities. Table 1, Key B1 & B7.
| Sandblasting and Power-Washing |
Sandblasting creates large amounts of dust that may present a safety hazard both to the workers performing the sandblasting, and to any occupants of the structure and neighboring properties. This is particularly a concern if lead-based paint or asbestos is present. Sandblasting activities must be properly contained to prevent fugitive dust emissions. Spent sandblasting grit must be properly disposed of and may be a hazardous waste if lead-based paint is present. Power-washing creates a wastewater that must be collected and properly disposed. Table 1, Key A1, A2, B1, B7, B8, D, & E.
| Worker Safety Requirements |
The federal Occupational Safety and Health Administration (OSHA) has numerous worker safety requirements that would apply to most companies involved in renovation or demolition. In particular, OSHA requirements address issues such as physical hazards (e.g., fall protection, confined spaces, trenching, use of tools), and chemical exposure hazards (e.g., asbestos, lead-based paint, solvents). Public-sector agencies (e.g., state and local governments) are subject to the similar requirements of CONN-OSHA, a Division of the Connecticut Department of Labor. Table 1, Key D, E.
| Construction and Demolition Waste |
Construction and demolition waste (or "C&D waste") may include anything from individual architectural components (i.e., doors, windows, siding, etc.) to whole-building demolition debris. C&D waste may be contaminated with asbestos, lead-based paint, or chemical residues and require special disposal (see separate sections on these topics for more information). Uncontaminated C&D waste that is disposed of must be sent to a landfill or volume reduction facility (VRF) that is permitted to take C&D waste. Uncontaminated C&D waste may also be recycled or reused. Many C&D components may be sent to permitted recycling facilities to be made into new products. Clean rock, brick, ceramic, and concrete may be utilized on-site as fill material. However, see the section on fugitive dust and air emissions for requirements that may apply if crushing is required in order to use these materials as fill. Table 1, Key B1 & B5.
| Treated Wood |
There are a number of types of treated wood, including pressure-treated wood, and wood that has been treated with pentachlorophenol ("penta") or creosote. Pressure-treated wood may contain the toxic metals chromium or arsenic. Penta and creosote are both pesticides whose use has been restricted since 1986. Treated wood may not be buried or burned on-site or processed into mulch, but must instead be sent to a permitted facility for disposal. Wood that has been treated with penta may be classified as a hazardous waste if the concentrations of penta are high enough. Table 1, Key B1 & B5.
| Land-Clearing Debris |
Land-clearing debris includes items such as trees, stumps, and brush that must be removed as part of site preparation work. Land-clearing debris may not be buried on-site, but must be sent to a recycling or disposal facility that is permitted to take such items. If there is a need for mulch or wood chips at the work site, equipment may be brought in to process the land-clearing debris into the desired form (however, see section on fugitive dust and air emissions for requirements that may apply to such processing). Processing of materials from off-site cannot be conducted without a solid waste permit. Table 1, Key B1 & B5.
| Chemical Products |
Commercial and industrial sites may have process chemicals, oils, cleaning products, or other chemical products stored inside them. Many of these products may be classified as hazardous waste when disposed, and most others may not be disposed of with regular trash. These materials must be shipped to a permitted disposal facility by a licensed transporter. Residential sites may also contain chemical products (paints, solvents, pesticides, cleaners, etc.). Although household wastes are not subject to hazardous waste requirements, most of these products may not be disposed of with regular trash. However, in many cases, these materials may be disposed of at a local household hazardous waste collection center or one-day collection event (check with your local recycling coordinator for more information on the services available in your area). Table 1, Key B1.
| Mercury |
Fluorescent lamps, thermostats, mercury switches, manometers, natural gas meters, and other items may contain enough mercury to be classified as a hazardous waste, and may therefore not be disposed of as regular trash. However, fluorescent lamps, thermostats, and other mercury-containing equipment are eligible for management under a special set of hazardous waste requirements known as the Universal Waste Rule. Also, you can go to www.thermostat-recycle.org to find out how to properly dispose of thermostats for free. Table 1, Key B1, B5.
| Polychlorinated Biphenyls (PCBs) |
PCBs may be found in a number of items, including transformers, capacitors, fluorescent light ballast and other oil-containing equipment, and in certain building materials (i.e., caulking, paint, roofing, flooring, insulation, etc.). PCB-containing items such as these must be managed and disposed of in accordance with special PCB requirements. DEEP has developed a guidance table in conjunction with EPA Region 1 that compares remediation and disposal options for caulking material contaminated with PCBs and associated substrates. Although specific to caulk, the table may generally be applied to other building materials that contain PCBs. In many cases, state and federally-regulated PCB contaminated building materials are found in conjunction with one another. Therefore, characterization of building materials should be consistent with the requirements of 40 CFR 761 and EPA guidance. Table 1, Key B1, B2, and C4.
| Used Electronics and Batteries |
Used electronics and batteries may contain enough lead, mercury, cadmium, or corrosive electrolytes to be classified as hazardous waste. In such cases, they may not be disposed of as regular trash. However, like mercury thermostats, these items are eligible for management under a special set of hazardous waste requirements known as the Universal Waste Rule. Table 1, Key B1, B5.
| Contaminated Equipment/Structures/Soil |
Commercial and industrial facilities may contain contaminated equipment or structures (e.g. tanks, ductwork, piping, process equipment, wood flooring, etc.). Contaminated soil may also be present, either under the building footprint, or outside it. In some cases, these materials may be classified as hazardous waste when disposed. In other cases, they may not be hazardous waste, but may still be restricted from reuse or disposal at a solid waste landfill without authorization from DEEP. Table 1, Key B1, B4.
| Air Conditioning and Refrigeration Equipment |
Such equipment must be removed and disposed of in a way that will prevent the venting of CFCs (e.g., Freon) to the atmosphere. Table 1, Key B1, C1.
| Underground Storage Tanks (USTs) |
Commercial and industrial sites often have petroleum USTs that may be subject to certain procedures for registration, removal and abandonment. In cases where such tanks have leaked, the affected area must be cleaned up to specified remediation standards, as determined through confirmation sampling. Residential USTs are not subject to the same rules as commercial and industrial USTs, but should still be properly removed or abandoned, and underlying soils tested to determine if there have been any releases to the environment. Wastes generated from the removal and cleanup of all USTs must be properly tested and disposed of in accordance with solid and/or hazardous waste requirements. Table 1, Key B1, B3.
| Site Cleanup Issues |
There are a number of soil and groundwater cleanup requirements that may apply. Some industrial and commercial sites are required to be cleaned up under DEEP’s Property Transfer Program. Others may be under cleanup orders from DEEP. Table 1, Key B4.
| Spills |
Any spill of oil or petroleum, chemical liquids or solids, or hazardous waste must be reported immediately by calling the DEEP’s 24-hour spill reporting number: (860) 424-3338, or toll-free at 1-866-DEP-SPIL. Table 1, Key B6.
| Drinking Water Supplies |
There are certain public health requirements relating to:
-
the potable water source at the site (well or public water system),
-
plumbing materials used in renovations (must be free of lead solder),
-
the potential for any cross connections that may contaminate the potable water supply; and,
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the electrical wiring/components of the water supply system (must meet applicable CT Building Code requirements). Table 1, Key A3.
| Other Issues |
RADON is a naturally-occurring radioactive gas that is emitted from the bedrock in many parts of Connecticut. Testing should be performed both before and after renovation activities to ensure that indoor air is safe. Table 1, Key A1.
MOLD may be produced when building materials are exposed to moisture. The mold spores that are subsequently released may cause irritation and allergic reactions in workers and building occupants. For more info, see the DPH Indoor Environmental Quality website.
CALL BEFORE YOU DIG is a free service you should use prior to excavation to check for underground utilities. Check out their web site at www.cbyd.com, or call toll free at 1-800-922-4455.
THE DEPARTMENT OF CONSTRUCTION SERVICES has certain rules that apply to renovation and demolition projects and the contractors that perform them. For more information, go to the Department of Administrative Services website and search under the keyword "demolition."
TABLE 1: List of Contacts for Additional Information
|
Agency |
Key |
Division / Program |
Telephone Number / Web Site |
|---|---|---|---|
|
CT Dept. of Public Health |
A1 |
Environmental Health Section (asbestos and radon) |
DPH Asbestos Program: (860) 509-7367 |
|
A2 |
Environmental Lead Unit |
(860) 509-7299 |
|
|
A3 |
Drinking Water Section |
(860) 509-7333 |
|
|
CT Dept. of Energy and Environmental Protection |
B1 |
Waste Engineering & Enforcement Division |
(860) 424-3023 or Toll Free at (888) 424-4193 EPA "In Focus" Guidance for Construction, Demolition, and |
|
B2 |
PCB Program |
(860) 424-3368 |
|
|
B3 |
Underground Storage Tank Program |
(860) 424-3374 |
|
|
B4 |
Remediation Division |
(860) 424-3705 |
|
|
B5 |
Recycling Program |
(860) 424-3366 |
|
|
B6 |
Emergency Response and Spill Prevention Division |
(860) 424-3338 or 1-866-DEP-SPIL (emergency) (860) 424-3024 (non-emergency) |
|
|
B7 |
Water Permitting & Enforcement Division |
(860) 424-3018
|
|
|
B8 |
Air Engineering and Enforcement Division |
(860) 424-4152 |
|
|
U.S. Environmental Protection Agency |
C1 |
Stratospheric Protection Division |
(202) 343-9729 or (617) 918-1858 |
|
C2 |
Asbestos NESHAPs Program |
(617) 918-1739
|
|
|
C3 |
Asbestos Hazard Emergency Response Act (AHERA) Schools Program |
General Info and Compliance: (617) 918-1739 |
|
|
C4 |
PCB Program |
General Questions: (617) 918-1527 |
|
|
U.S. Dept. of Labor |
D |
Occupational Safety & Health Administration (OSHA) |
Hartford: (860) 240-3152 |
|
CT Dept. of Labor |
E |
Division of Occupational Safety and Health (CONN-OSHA) |
(860) 263-6900 |
Content last updated on February 5, 2020