Understanding “Asbestos Procedure 5”

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A Guide for HOA Managers, Board Members & Property Owners

When asbestos is discovered during a restoration or construction project, things can quickly feel overwhelming. Terms like “Procedure 5” get used, and suddenly your project involves testing, containment, air monitoring, and government notifications.

This article breaks down exactly what Asbestos Procedure 5 is, when it’s required, and what you should expect from each party involved.

What Is “Asbestos Procedure 5”?

In California (under South Coast AQMD Rule 1403 and Cal/OSHA regulations), Procedure 5 is required when asbestos-containing material (ACM) is disturbed in a way that is not minor or incidental.

It typically applies when:

  • Asbestos-containing drywall, flooring, or other materials are damaged

  • Water damage requires demolition of asbestos-containing building materials

  • A significant amount of regulated asbestos-containing material (RACM) must be removed

  • The material is friable (crumbly) or may become airborne during removal

Procedure 5 is essentially a full regulatory asbestos abatement process, not a small-scale removal.

This means:

  • Government notification is required

  • A licensed asbestos abatement contractor must perform the work

  • Strict containment and air monitoring protocols must be followed

Why It Matters to HOA’s and Property Owners

Asbestos is not just a construction issue — it is a liability issue.

If handled improperly, it can:

  • Expose residents and workers to health risks

  • Trigger regulatory fines

  • Create major legal exposure for boards and property managers

  • Delay projects significantly

Procedure 5 exists to ensure:

  • Safety

  • Compliance

  • Documentation

  • Proper clearance before rebuilding begins

When done correctly, it protects everyone involved.

What the Process Looks Like (Step-by-Step)

1. Initial Testing & Assessment

Before demolition, materials are tested by a certified asbestos consultant or industrial hygienist.

If asbestos is present and the scope meets regulatory thresholds, Procedure 5 is triggered.

You should expect:

  • A written asbestos report

  • Clear identification of affected materials

  • A defined scope of abatement

2. Regulatory Notification

Under Procedure 5, the appropriate air quality management district must be notified (typically 10 days prior to work unless emergency conditions apply).

This is not optional.

You should expect:

  • Formal notification filing

  • Documentation of approval

  • Scheduled start date

3. Work Area Containment

The abatement contractor builds a full containment system, which typically includes:

  • Critical barriers (plastic sheeting sealing all openings)

  • Negative air machines with HEPA filtration

  • Decontamination chambers

  • Warning signage

This prevents asbestos fibers from migrating to other units or common areas.

For HOA communities, this step is especially critical in multi-unit buildings.

4. Licensed Asbestos Removal

Only a properly licensed asbestos abatement contractor may perform the removal.

Workers must:

  • Wear full protective equipment

  • Follow wet removal methods

  • Double-bag and label asbestos waste

  • Transport waste to approved disposal facilities

You should expect:

  • Daily oversight by a supervisor

  • Strict jobsite controls

  • No cross-contamination into occupied areas

5. Third-Party Air Monitoring

An independent industrial hygienist or environmental consultant performs:

  • Visual inspection

  • Aggressive air clearance testing

  • Final clearance documentation

Reconstruction cannot begin until clearance levels pass.

This protects:

  • Residents

  • HOA boards

  • Property managers

  • Insurance carriers

6. Final Clearance & Documentation

Once clearance is achieved, you should receive:

  • Air clearance report

  • Waste manifests

  • Regulatory documentation

  • Abatement completion paperwork

Keep this documentation permanently. It protects the association in the future.

Who Does What? (Roles Explained Clearly)

HOA Board

Your responsibility:

  • Ensure proper vendors are hired

  • Protect the association from liability

  • Confirm documentation is retained

You are not managing the technical process — you are overseeing compliance and protection of the community.

Property Manager

Your responsibility:

  • Coordinate communication

  • Ensure proper vendor licensing

  • Verify documentation is received

  • Manage resident notifications if required

Strong communication during Procedure 5 is critical. Delays and confusion typically happen when roles are unclear.

Industrial Hygienist / Environmental Consultant

Their role:

  • Perform testing

  • Write the abatement protocol

  • Conduct air monitoring

  • Provide clearance certification

They are the independent third party protecting everyone from improper handling.

Licensed Asbestos Abatement Contractor

Their role:

  • Build containment

  • Remove asbestos per the written protocol

  • Maintain regulatory compliance

  • Coordinate disposal

They do not write the testing protocol — they execute it.

Restoration / Reconstruction Contractor

Their role:

  • Coordinate with abatement

  • Begin reconstruction only after clearance

  • Ensure no demolition happens outside the approved scope

A good contractor manages this sequencing tightly to avoid delays.

What to Expect in Terms of Timeline

Procedure 5 adds time. That’s unavoidable.

Typical sequence:

  • 2–5 days for testing and reporting

  • 10-day notification period (unless emergency)

  • 2–7 days for abatement (depending on scope)

  • 1–2 days for clearance testing

Trying to shortcut this process creates risk — and that risk falls on the property owner and HOA.

Common Misunderstandings

“It’s just a little drywall.”

If it contains asbestos and exceeds regulatory thresholds, it’s not “little.” It’s regulated.

“Can’t we just have our contractor remove it?”

Not legally, and not safely.

“This is overkill.”

It may feel that way, but these regulations exist because improper handling has caused serious health consequences.

The Big Picture

Procedure 5 is not about bureaucracy.

It’s about:

  • Protecting residents

  • Protecting workers

  • Protecting board members

  • Protecting property managers

  • Protecting property values

  • Protecting against lawsuits

Handled correctly, it becomes a controlled, documented, and professionally managed process.

Handled incorrectly, it becomes a liability event.

Final Thoughts for HOA Leaders

When asbestos is involved:

  • Slow down.

  • Get proper testing.

  • Follow the protocol.

  • Demand documentation.

  • Work with experienced, licensed professionals.

Your job as a board member or property manager isn’t to be an asbestos expert.

Your job is to ensure the right experts are involved — and that the process is done right.

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