Asbestos in Old Roofs: Testing Before a Tear-Off
Yes, in most of the Los Angeles area, and not only on old roofs. South Coast AQMD's Rule 1403 applies to residential buildings and requires an asbestos survey by a Cal/OSHA-certified inspector before any demolition or renovation, and a re-roof, which removes part of the building, is a renovation. For a single-family house, the rule's exceptions are a renovation that removes less than 100 square feet and work the owner-occupant does personally. The rule has no exception by building age. If the survey finds asbestos in the roofing, more than 100 square feet of it is removed by a contractor registered with Cal/OSHA for asbestos work, with notice to the air district 10 working days before; if it doesn't, the re-roof goes ahead as planned. This page covers the rules for a house, not medical or legal advice.
Where asbestos can be in a roof
Asbestos was used in roofing as well as other building products. The EPA lists roofing and siding shingles among the places it can be found in a home, and California's contractors board notes that some roofing shingles were made with asbestos and Portland cement. Rule 1403's definition of asbestos material that can be broken or crumbled in demolition or renovation names roofing felts, roofing tiles, asbestos cement and transite products and mastic.
On a roof, that points to:
- Asbestos-cement shingles and tiles, sometimes sold as transite. California's residential code doesn't allow a new roof over asbestos-cement tile (CRC R908.4), so they come off on any re-roof.
- Roofing felts, under shingles and in the layers of a built-up flat roof.
- Mastics and roof cements at flashings, vents and patches.
- Asphalt roofing products. Rule 1403 has provisions for asbestos-containing asphalt roofing products, and Cal/OSHA classes removing asbestos roofing and siding shingles as Class II asbestos work.
A look isn't enough: the contractors board's guide says sampling and testing are needed to confirm asbestos, and under Rule 1403 only a certified consultant or technician can treat a material as asbestos-containing without testing it.
What the rules require for a house re-roof
The survey comes first, and what follows depends on what it finds. The steps below apply in the South Coast air district, which covers large parts of Los Angeles, Orange, Riverside and San Bernardino counties.
| Step | Requirement | Source |
|---|---|---|
| Survey before work | Required before any demolition or renovation; for a single-family house, not for a renovation removing less than 100 square feet, or work the owner-occupant does personally | Rule 1403 (d)(1)(A), (j)(9), (j)(10) |
| Who surveys | A person certified by Cal/OSHA who has passed an EPA-approved building inspector course: a Certified Asbestos Consultant, or a Certified Site Surveillance Technician, with the report signed by a consultant | Rule 1403 (d)(1)(A)(iv); South Coast AQMD FAQ |
| If more than 100 square feet of asbestos material comes off | Notification to South Coast AQMD at least 10 working days before the work | Rule 1403 (d)(1)(B); South Coast AQMD FAQ |
| Who removes it | For 100 square feet or more: a contractor registered with Cal/OSHA for asbestos work and holding the contractors board's asbestos certification | South Coast AQMD FAQ; CSLB consumer guide |
| How it comes off | Intact where feasible, wet if it isn't intact, never dropped or thrown off the roof, lowered by the end of the shift and put in closed containers | Cal/OSHA, Title 8, Section 1529(g)(8)(B) |
The survey has to identify and quantify the asbestos materials the work will disturb and document who did it, when, which materials were sampled and where. South Coast AQMD doesn't issue a permit for asbestos removal, but your city or county may require its own. An earlier survey still counts if the materials and their condition haven't changed, as the air district's FAQ answers for a homeowner modifying a roof.
If the survey finds asbestos
The roofing that contains it is removed as asbestos work before, or as part of, the tear-off. For a quantity over 100 square feet, that means a registered abatement contractor, the 10-working-day notice and the waste-disposal rules in Rule 1403. Cal/OSHA's work practices for roofing apply to the crew doing the removal: the material is taken off intact where possible, kept wet if it breaks, lowered rather than thrown, and bagged or contained by the end of the shift. Small intact sections under 25 square feet can be removed by hand without wet methods if no visible dust is made.
That adds a step to the schedule, which is why the survey belongs before the contract dates are set. Where the roof needs a permit, the permit is for the re-roof; the asbestos rules run alongside it. How the re-roof itself is permitted in the City of Los Angeles is in roof permits with LADBS.
Doing it yourself
Rule 1403 exempts an owner-occupant of a single-family house who personally does the work, but the air district says the exemption doesn't extend to help from a contractor, laborer, friends or family, and it doesn't recommend that homeowners remove asbestos. The contractors board's consumer guide adds that Cal/OSHA regulates all asbestos handling and that even small amounts removed by a homeowner have to follow transport and disposal rules. The air district's FAQ notes that the rule's waste-disposal requirements still apply.
What we've seen
On a 2020 Sylmar re-roof, before a single shingle came off we had the existing covering assessed for asbestos by a testing contractor; with that settled, 25 squares of composition shingle went on over the existing sheathing and the roofing permit was finaled (the Sylmar case). Finding asbestos after a tear-off has started is the expensive way to learn it's there.
Frequently asked
Does a newer roof need an asbestos survey before it's replaced?
Who can test my roof for asbestos?
Can my roofer remove asbestos roofing?
Does a repair need a survey?
Can new roofing go over asbestos-cement shingles to avoid the issue?
Related reading
Sources & methodology
Code sections, rules and figures on this page come from the primary sources below. Codes, local requirements and product terms change; each was verified October 8, 2026.
- South Coast AQMD, Rule 1403, Asbestos Emissions from Demolition/Renovation Activities, amended October 5, 2007: (b), (c) definitions,…
- South Coast AQMD, Rule 1403 Frequently Asked Questions, updated October 27, 2020
- South Coast AQMD, Asbestos Demolition and Removal
- South Coast AQMD, About
- Cal/OSHA, Title 8, California Code of Regulations, Section 1529, Asbestos (Class II work; roofing material, (g)(8)(B))
- Contractors State License Board, A Consumer's Guide to Asbestos (2013)
- U.S. Environmental Protection Agency, Learn About Asbestos
- California Residential Code 2025, Chapter 9, Roof Assemblies, section R908.4 (UpCodes)
We line up the asbestos survey before the tear-off
Call (323) 844-7777. We inspect the roof, note the layers and materials that need sampling, and schedule the re-roof around the survey results so nothing comes off before they're in. Have ready the roof's age if you know it and any earlier survey report for the house.
Prepared by Cali Energy, October 8, 2026. This article is for general educational purposes only and is not legal, tax, financial, engineering, or utility advice. Rates, incentives, codes, permit requirements, equipment specifications, prices, and program terms may change; figures and timelines are estimates, not guarantees. Confirm current requirements with the applicable utility, AHJ, program administrator, manufacturer, or a licensed professional. See our Content Disclaimer. Cali Energy · 19201 Parthenia St, Unit E, Northridge, CA 91324 · CSLB #1032379 (B, C-10, C-39)