Removal & Abatement
The role with the highest conflict potential in asbestos projects. Incompatibilities, regulations, fraud cases, and how to protect yourself.
What a Removal Company Does
An asbestos removal (abatement) company physically removes asbestos-containing materials from buildings. This involves establishing containment zones with polyethylene sheeting, creating negative air pressure using HEPA-filtered units, wetting materials to suppress fibre release, carefully removing and double-bagging asbestos waste, decontaminating the work area, and coordinating final clearance air testing. Removal is the most physically intensive and highest-risk phase of any asbestos project.
The Main Conflict of Interest
Removal is the role with the highest conflict potential in the entire asbestos management chain. The removal company has a financial interest in every other phase of the project, creating multiple vectors for abuse.
- Performing the initial survey: incentive to find more asbestos than exists, recommend removal over management-in-place, and inflate the scope of work
- Conducting air monitoring during its own works: incentive to produce favourable results that allow work to continue without costly shutdowns or rework
- Performing the final clearance test: acting as both judge and party, certifying its own work as safe
- Selecting the laboratory: steering analysis to a compliant lab that will deliver passing results
- Managing the project: supervising itself eliminates independent oversight
- Cutting corners on containment, decontamination, or worker protection when no independent monitor is present
The Rule
The removal company executes the physical intervention. Diagnosis, supervision, air monitoring, and final clearance certification must all come from independent third parties with no financial connection to the removal contractor. This is the most strictly regulated separation in the industry.
Incompatibilities with Other Roles
Removal is incompatible with more roles than any other function. The following table shows the full picture.
| Role | Compatibility |
|---|---|
| Survey | Incompatible |
| Laboratory | Incompatible |
| Air Monitoring | Incompatible |
| Consulting | Incompatible |
| Project Mgmt | Incompatible |
| Waste Mgmt | Conditional |
| Training | Incompatible |
Regulation by Country
How different jurisdictions regulate removal company independence.
| Country | Regulation | Requirement for this role |
|---|---|---|
| France | Code du Travail SS3/SS4, NFX 46-020 | Removal companies must be certified. The surveyor must be independent. Final air clearance must be performed by a COFRAC-accredited body with no link to the removal company. |
| United Kingdom | Control of Asbestos Regulations 2012, HSG247 | Licensed removal contractors cannot perform their own clearance inspections. An independent analyst must certify that the site is safe for reoccupation. |
| Spain | RD 396/2006, RERA registration | Removal companies must be registered in RERA. Environmental monitoring must be conducted by an independent ENAC-accredited entity. |
| United States | EPA NESHAP, OSHA 1926.1101 | Most states prohibit the same firm from performing inspection and abatement. Independent air monitoring is required by many state regulations. |
| Australia | WHS Regulations, Code of Practice for Removal | Class A or B licensed removalists. Independent licensed assessor required for clearance. |
Documented Cases of Fraud
Real cases where removal companies operated without independent oversight, with severe consequences.
Alexander Salvagno / AAR Environmental
New York, United States · 2002–2006
Salvagno's removal company AAR secretly owned the laboratory (ALA) that was supposed to independently verify its work. AAR performed 1,555 illegal "rip and run" removals -- tearing out asbestos without proper containment, negative pressure, or worker protection. Schools, churches, hospitals, and the New York Legislative Office Building were all affected. Up to 75,000 lab samples were falsified.
25-year federal prison sentence. $2M forfeiture, $23M restitution order. The longest environmental crime sentence in U.S. history.
PreZero / CESPA Conten
Bilbao, Spain · 2020s
The removal company failed to perform required personal exposure measurements. Monitoring sensors were repositioned during active work to avoid recording accurate fibre concentrations inside the containment zone. Results were manipulated to appear compliant when exposure limits had actually been exceeded.
Investigated by OSALAN. Workers were exposed to asbestos fibre concentrations above legal limits without proper documentation or protection.
Peter Horrey / Absolute Asbestos Ltd
Camden, United Kingdom · 2010s
Horrey, the company director, removed asbestos without a license and then falsified the air clearance report. An independent analyst had issued a FAIL certificate, but Horrey provided residents with an altered version showing a PASS. The independent analyst discovered the forgery and alerted the Health and Safety Executive (HSE). This case illustrates how an independent analyst functions as a safeguard.
Suspended prison sentence. Prosecution by the HSE for unlicensed removal and document falsification.
Red Flags for Building Owners
- The removal company offers a "complete package" including survey, removal, air monitoring, and final certification all from the same entity
- The company performing the removal selects and pays the air monitoring firm directly
- The removal contractor discourages you from hiring an independent project monitor
- The price quote is significantly lower than competitors -- this may indicate corners will be cut on containment and decontamination
- The contractor cannot provide a current license or RERA/HSE/state registration number
- Work begins before a proper survey and removal plan have been documented and submitted to the relevant authority
- The contractor proposes to start and finish over a weekend or holiday to avoid regulatory oversight
How to Protect Yourself
- Never let the removal company control the selection of the surveyor, laboratory, or air monitoring firm. Each must be independently contracted by the building owner or an independent project manager.
- Verify the removal company's license directly with the regulatory authority (HSE in the UK, RERA in Spain, prefectural notification in France).
- Hire an independent project monitor who reports directly to you, not to the removal contractor.
- Insist on an independent analyst for the final clearance inspection. If the removal company offers to "handle" clearance, decline.
- Request and verify all waste disposal certificates. Every bag of asbestos waste must be traceable to an authorized landfill.
- Visit the site during works (in safe areas outside the containment) to verify that containment, signage, and decontamination units are in place.