Under Washington's asbestos rules for construction, four groups are presumed asbestos-containing in buildings or floors from 1980 or earlier, without waiting for a lab result. Estimators who count and price demolition or remodel work in older buildings run into the same problem on almost every job: the material that matters often cannot be tested before the bid goes out. The rule handles that gap with presumptions. For certain materials in a building or on a floor that is old enough, the rule says the material must be identified as asbestos-containing, or treated as presumed asbestos-containing.
This post goes through the four presumed material groups in that rule in the order you would reach them on a job. For each one it covers what to check, what to count, and how the presumption changes the price. The rule is Washington's, and the rules where you work may differ, so check the text that applies to your project. Every date, requirement and dollar amount below comes from the Washington sections linked where they appear. This post is a guide to that text, not a replacement for reading it.
Key takeaways
- Sort each finding by its trigger date: construction date for thermal system insulation and surfacing, installation date for flooring and decking.
- Count thermal system insulation as presumed material from the start, not as ordinary insulation that might turn out to be clean.
- Check each floor layer against both flooring rows, since an employer or owner determination can remove the presumption for asphalt or vinyl flooring.
- Do not assume a determination exists unless it is in the project file.
- Pick the owner's handling route before you price, and carry the presumed work as its own scope.
1. Confirm the construction and installation dates
Start with two dates, because the rule uses two different triggers. For thermal system insulation and for sprayed-on or troweled-on surfacing, the trigger is when the building or substrate was constructed. The rule covers those materials in buildings or substrates "constructed no later than 1980" ( WAC 296-62-07721). For flooring and decking, the trigger is when the material was installed. The rule covers asphalt or vinyl flooring and decking "installed in buildings or vessels no later than 1980," and it covers resilient flooring and decking "installed no later than 1980" ( WAC 296-62-07721).
Do not assume the floor matches the building. A building's construction date does not settle the flooring question, because a floor has its own install date. A floor can be laid during a remodel long after the building went up. When you see a building, ask separately when each floor layer was installed.
Useful sources for these dates include original drawings, building permits for past remodels, tenant improvement records, the owner's maintenance files, and the memory of long-serving facilities staff. Where two sources disagree, write down both dates instead of choosing the one that makes the job simpler.
Record the source beside each date in your takeoff. If a date is unknown, do not pick a convenient one. Flag it, and carry the unknown forward into the handling decision in step 6, because an unknown date can change which presumption applies to a material.
2. Survey mechanical spaces for thermal system insulation
Thermal system insulation is the first presumed group, and it usually sits where the building's mechanical systems do. The rule says all thermal system insulation in buildings or substrates constructed no later than 1980 "must be identified as PACM" ( WAC 296-62-07721). In practice, the insulation goes into your estimate as presumed material from the start, not as ordinary insulation that might turn out to be clean.
Walk the boiler room, the mechanical penthouse, pipe chases, crawlspaces, utility tunnels, and the spaces above drop ceilings where pipes and ducts run. The forms you will see most often are pipe wrap, fitting insulation, boiler jackets, tank insulation, and duct wrap. Count each run by length and by diameter, and note the access route for each one. Pipe that is high on a wall, insulated fittings at valves, and runs that pass through a fixed ceiling each change the labor, even when the length on paper looks the same as an open run in a clear room.
Access is where the estimate tends to move. A straight run in an open room and a run behind a fixed ceiling in a tight chase may measure the same, but they are not the same job. Price them as separate lines. Where a run goes into an area the bid will not open, say so in the scope, and state what the owner must open or clear before the work starts. A hidden run that is left out quietly becomes an argument later.
Illustrative example: one mechanical room
Suppose a mechanical room holds 6 pipe runs and 2 boiler jackets, and 2 of the runs pass behind a fixed ceiling. Price those 2 hidden runs as their own line, because access changes the labor. If the owner has not yet chosen a handling route, name the lines that depend on that choice in the bid. This example is illustrative only and describes no real project.
Keep the mechanical count on its own sheet. These totals will feed the handling line you build in step 7. A sheet that mixes them with general demolition quantities makes it hard for the owner to see which work is presumed and which is not. For more on pre-bid checks in demolition, see asbestos and ladder checks for demolition bids.
3. Sort each finding into one of four presumed groups
Once you have found a material, place it in the group the rule gives it. The table sets out the four groups this post covers. The first two come from the same rule sentence about buildings and substrates constructed no later than 1980. The last two are the flooring rules. Every date and requirement in the table comes from WAC 296-62-07721.
Two points about the flooring rows deserve attention. First, the asphalt-or-vinyl row carries an exception. The material counts as asbestos-containing unless the employer or owner determines it is not, under WAC 296-62-07712 (10)(a)(ix). The determination route runs through that section, so read it before you rely on it. Second, the resilient row carries no such determination route. A vinyl floor can fit both descriptions, so check each floor against both rows, and do not assume that one row replaces the other.
4. Walk ceilings, walls and structure for sprayed-on and troweled-on surfacing
The second group is surfacing material applied wet, either by spray or by trowel. Sprayed-on or troweled-on surfacing materials in buildings or substrates constructed no later than 1980 "must be identified as PACM" ( WAC 296-62-07721). The sentence covers both application methods, so the presumption is the same whichever method was used. The survey still needs to record where the material is, because the handling plan depends on location.
Look at ceiling surfaces, the undersides of floor and roof decks, structural steel and columns, the tops of walls, and the spaces above suspended ceilings. Ask whether a surface has been painted, covered, or patched over. Record any coating you see. The bid should describe what is on the surface now, not what the surface looked like when it was first finished.
Pricing surfacing work depends more on the work area than on the count of surfaces. Estimate the isolation of the area, the protection of the rest of the building and its occupants, the waste handling, and the time it takes to keep the area controlled while work goes on. Each of these should be its own line. A single line labeled general demolition hides the presumed-material work, and then the owner cannot compare your bid against others on equal terms.
Measure the surfacing by area and by location type. A ceiling over an open floor, a column in a corridor, and a deck underside above a finished space each need a different plan, even when the square footage is the same. Note the height and the access equipment you expect to need, and carry those notes into the price rather than leaving them for a change order.
5. Check every floor and deck against both flooring rules
Flooring has the most layers to miss. A floor can carry a finish, an underlayment, an adhesive, and an older floor beneath a newer one. The rule ties presumption to the installation date, so each layer raises its own question. Record each layer you can see, its material, and its install date if you can find it. A floor that looks new on top can have an older layer underneath, and the older layer may be the one the date rule reaches.
For asphalt or vinyl flooring and decking installed no later than 1980, the rule says the material "must also be considered as asbestos containing unless the employer/owner, according to WAC 296-62-07712 (10)(a)(ix) determines it is not asbestos containing" ( WAC 296-62-07721). Under that wording the presumption applies by default. A determination can change the treatment, and the employer or owner makes it. If it is not there, the floor stays on your presumed list.
For resilient flooring and decking installed no later than 1980, the rule says the material "must also be identified as asbestos containing" ( WAC 296-62-07721). Price it as presumed.
Photograph each floor layer and each deck surface you open, and mark the location on the plan. The photographs help the owner follow your count, and they help you compare the bid with what the crew finds once the work starts.
Decks get the same attention as floors. The rule names flooring and decking together in both sentences, so count decks along with floors and note whether each is interior or exterior. Exterior decks and rooftop surfaces often need a different protection and waste plan than an interior floor, and that difference belongs in the line item rather than in a general note.
6. Decide how the presumption will be handled before you price
Before you settle the number, find out what the owner has chosen. The rule gives two routes that remove the need for a good-faith inspection. In the first, the building or facility owner or the owner's agent assumes the suspect material contains asbestos and handles it in accordance with WAC 296-62-07701 through 296-62-07753. In the second, the owner or the owner's agent is reasonably certain that asbestos will not be disturbed by the project. A good-faith inspection is not required in either case ( WAC 296-62-07721).
These two routes produce very different bids. The first produces a priced handling scope for every presumed group you counted. The second depends on the owner's judgment that the project will not disturb the material. Read the proposed scope against the drawings before you accept that the work will avoid the material. A demolition line that cuts through a presumed run or surface is not avoided just because the scope says it is.
Do not assume the owner's choice falls in your favor. The rule also sets a penalty for the owner. A building or facility owner or owner's agent who fails to comply with WAC 296-62-07721 (2)(b)(ii) and (iii) "must be subject to a mandatory fine of not less than two hundred fifty dollars for each violation" ( WAC 296-62-07721). That penalty falls on the owner or the owner's agent, not on the estimator. It still matters to you, because an owner who faces it will want a bid that keeps the work inside the rule, and a bid that leaves a presumed group out of scope may need correcting before the work can start.
Read subsections (2)(b)(ii) and (iii) before you finish the scope, and do not price around them from memory.
7. Price the handling and keep the record
Carry the presumed work as its own priced scope, separate from general demolition. Use one line for each presumed group, and bring in the quantities from steps 2 through 5. Add lines for the handling route the owner chose in step 6, for protection of the rest of the building, for waste, and for any paperwork that route requires. Do not spread these costs into general labor, because an owner comparing bids cannot see what each one includes if the presumed work is hidden in a general number.
Show the presumed scope as a separate section with its own subtotal. If the owner has not yet chosen a route under step 6, say so on the bid, and name the lines that depend on that choice. If the owner later changes the route, the lines you already priced show exactly what the change adds or removes, and nobody has to rebuild the estimate from the top.
Keep a decision record with the bid. For each presumed group, note the date source from step 1, the quantity, the location, the handling route the owner selected, and who made that selection and when. The record shows what was known and what was assumed at the time the bid was prepared. It also helps the owner compare the scope with the drawings after the bid is accepted.
The record is also your check on the rest of the estimate. A floor you could not reach, a run you could not open, a surface you could not see behind a finish, or a date you could not confirm should appear in the record as an open item. State each one plainly, with either a price for the uncertainty or an exclusion that names exactly what is left out. An open item that is written down can be resolved. An open item that is never written down tends to surface during the work, when it is most expensive. For a wider review before the bid goes out, see construction estimate audit.
Presumed materials turn a question about age into a question about cost. Estimators who sort by date first, count by group, and price the handling as its own scope can give the owner a bid that shows exactly what the presumption adds. A bid built this way gives the owner something concrete to check against the drawings, and it makes the rule's requirements part of the job rather than a surprise on the first day of demolition.
Your next step
Today, open the project file and write the construction or installation date beside each floor layer, each mechanical run and each surfacing area you have found, using the sources in step 1. Mark any date you cannot confirm as an open item.
Frequently asked questions
Which date triggers the presumption?
Thermal system insulation and sprayed-on or troweled-on surfacing key to when the building or substrate was constructed. Flooring and decking key to when the material was installed.
Can a determination remove the flooring presumption?
Yes, but only for asphalt or vinyl flooring: the rule treats it as asbestos-containing unless the employer or owner determines it is not, under WAC 296-62-07712 (10)(a)(ix). Do not assume that determination exists unless it is in the project file.
Who faces the fine for noncompliance?
The building or facility owner or the owner's agent faces it, not the estimator. The rule sets a mandatory fine of not less than two hundred fifty dollars for each violation of WAC 296-62-07721 (2)(b)(ii) and (iii).