Asphalt Roofing Products
Asbestos-containing roofing felts have been widely used in "built-up" roofs. Built-up roofing was used on flat surfaces and consists of alternating layers of roofing felt and asphalt. The roofing felt consists of asbestos paper saturated and coated with asphalt. Asphalt-asbestos roofing products made from roofing felt coated with asphalt were reportedly used on residential structures for only a short time (1971-1974).
To determine if an asphalt roofing product is covered by the Asbestos NESHAP, examine the RACM to spot any areas where the material is in poor condition and friable. If possible, sample areas where fibers can be seen protruding from the matrix of the asphalt. The sample should be sealed into a transparent, reclosable sample bag and hand pressure applied to see if the sample can be crumbled, pulverized, or reduced to powder.
Courtesy of The EPA: NESHAP Regulated Asbestos Containing Materials Guidance

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