Swimming Pools and Asbestos

Asbestos found in materials used in the construction of swimming pools

Not all products containing asbestos are banned. Asbestos is currently used in more than 3,000 building materials and may still be used in pool construction. The most common pool construction materials that may contain asbestos are cementitious materials (e.g. gunite, shotcrete) and plaster.

How to know if a pool is subject to asbestos regulations

Pools are regulated at the following facilities under the Asbestos NESHAP: 
  • Two or more contiguous single family homes
  • Homes that are part of a larger demolition project (e.g. two or more houses being demolished for a new freeway)
  • Multi-family housing with five or more units (i.e. apartment, town home, condominium) 
  • Commercial buildings including public/private schools, and churches
  • Any structure being prepped for a fire training exercise

Pool inspection requirements

An inspection for the presence of asbestos must be conducted by a current Asbestos Hazard Emergency Response Act (AHERA) certified Building Inspector within 12 months prior to commencement of renovation or demolition activities of a regulated (Asbestos NESHAP) pool.

What to do after receiving the AHERA inspection results

The pool is regulated if the following two criteria are met:
  • Over one percent Asbestos Containing Material (ACM) 
  • Regulated Asbestos Containing Material (RACM) identified to be generated at threshold amounts of 160 square feet or greater
Projects that meet these criteria are required to submit a Renovation or Demolition Notification to the Maricopa County Air Quality Department. There is a 10 day waiting period prior to commencement on any work on the pool. The asbestos must properly be abated by an asbestos abatement contractor by wetting, bagging, labeling, and disposing of the RACM at an asbestos receiving landfill. Please note that there are different types of ACM with pool plaster typically being considered Category II material, which is non-friable by definition. Removal of plaster by either mechanical or hand methods render the material RACM.

Is the removal of a swimming pool considered demolition?

A residential swimming pool (single family home) is exempt from Asbestos NESHAP regulation and therefore is not regulated as demolition. If more than one living structure (i.e. guest house) is located on the property the swimming pool would be subject to the Asbestos NESHAP regulation.

Removal of a commercial pool where the entire pool is being excavated out of the ground and the sidewalls are being collapsed is considered demolition. This is because the sidewalls are considered to be load bearing (supporting the load horizontally) and is therefore subject to the Asbestos NESHAP regulation and notification requirements. 
As an alternative, pools may simply be decommissioned by cutting several two foot by two foot holes in the bottom of the pool for drainage of rainwater, then the decking of the pool dumped into the pool (note that an AHERA survey is still required) then the remainder of the pool is filled with dirt and the pool graded over. In this case as long as the AHERA survey has been completed there would be no requirement for any demolition notification submittal. Please maintain a copy of the survey onsite for survey verification.

Other pool remodeling activities regulated by the Air Quality Department

The EPA has banned all spray-on applications of materials containing more than one percent asbestos by weight.

Page reviewed 31 May 2019