AQ 36: Non-Traditional Asbestos Abatement Work Practice Approval

Next steps   for AQ 36: Non-Traditional Asbestos Abatement Work Practice Approval

1. What to Know

   Non-Traditional Asbestos Abatement Work Practices are practices that differ from those required by 310 CMR 7.15 (the MassDEP Asbestos Regulation) and are needed to address specific situations in which the prescribed practices cannot be implemented safely (e.g., before demolition of a fire-damaged building; or in areas near high-voltage electrical equipment and other situations where wetting would be dangerous).

   Before proceeding with Non-Traditional Asbestos Abatement Work Practices, you must persuade MassDEP that they will:

   • Not discharge visible emissions of asbestos to the outside air,
   • Keep asbestos containing materials and wastes adequately wet (where appropriate) until they are placed and sealed into containers for transport to a disposal facility, 
   • Comply with all other applicable requirements of 310 CMR 7.15, and
   • Be consistent all other applicable federal, state, and local requirements.

2. Review the Instructions

   Guidance on how to prepare and submit your application.

   Open PDF file, 252.84 KB,  Instructions: AQ 36 (English, PDF 252.84 KB)

3. Complete Your Application

   You may fill out and save the Microsoft Word form on your computer. The PDF version has to be printed out and completed by hand.

   Open DOCX file, 56.03 KB,  Form: AQ 36 (English, DOCX 56.03 KB)

   Open PDF file, 127.13 KB,  Form: AQ 36 (English, PDF 127.13 KB)

4. Submit Your Application & Payment to MassDEP

   Since MassDEP staff often work remotely under a hybrid work environment, it is important to complete all three steps below.

   Step a. Send your original application form to the appropriate MassDEP Regional Office, Attn: Asbestos Program. Follow the link below for a listing of regional offices by community.

   Step b. Send a copy of your application form and payment ($600 check payable to the Commonwealth of Massachusetts) to:

   MassDEP
   P.O. Box 4062
   Boston, MA 02211

   Note: MassDEP will return your submittal it if it is found to be incomplete.

   Step c. Email scanned copies of your (1) original completed and signed application form, (2) proposed site-specific work plan (including all relevant attachments and demonstrations) signed by the Asbestos Project Designer who prepared it, and (3) check for fee payment to the appropriate regional asbestos contact.

   • Central Region: christa.cronk@mass.gov
   • Northeast Region: grady.dante@mass.gov
   • Southeast Region: colleen.ferguson@mass.gov
   • Western Region: john.moriarty@mass.gov

   MassDEP Regional Offices by Community 

5. Wait for MassDEP Approval

   MassDEP will issue an approval or denial within ten (10) working days of receiving your application and finding it administratively and technically complete. In the case of an emergency situation, the agency will strive to issue an approval or denial within two (2) business days of receiving an application.

   If MassDEP finds your application incomplete, the agency will request additional information and give you 30 calendar days to respond.

   After you submit the requested information, MassDEP will have ten (10) working days to issue an approval or denial. 

6. Submit an Asbestos Removal Notification

   Once you have obtained a Non-Traditional Asbestos Abatement Work Practice Approval from MassDEP, you will need to file an AQ 04 (ANF-001): Asbestos Removal Notification that references your Non-Traditional Work Practice Approval and wait ten (10) working days before you can begin work.

   AQ 04 (ANF-001): Asbestos Removal Notification 

7. Start Your Project

   You may begin asbestos removal work only after the waiting period of ten (10) working days specified by the MassDEP asbestos regulation (310 CMR 7.15) has elapsed. Starting early is a violation and may result in enforcement action, including financial penalties.

   If you are unable to wait ten (10) working days before starting work, you must obtain an emergency waiver of the notification wait period. Please click here to refer to the Emergency Waiver Request Procedures: Asbestos Abatement and Demolition Projects.

   You must begin work on and complete work by the “start” and "end" dates indicated in your notification. If you plan to change either or both of these dates, you MUST file a notification revision.

   AQ 04 (ANF-001): Asbestos Notification Revision