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How many samples of miscellaneous material or nonfriable suspected material must be taken to determine if the material is asbestos-containing material (ACM) under the Asbestos Hazard Emergency Response Act (AHERA)?

For miscellaneous material, 40 CFR part 763.86(c) states that “in a manner sufficient to determine whether material is asbestos-containing material (ACM) or not ACM, an accredited inspector shall collect bulk samples from each homogeneous area of friable miscellaneous material that is not assumed to be ACM.” Although a specific number of samples are not mentioned, at least two samples from each homogeneous area of miscellaneous material must be taken due to the plural use of the word “samples.” An accredited inspector may determine that more than two samples are necessary to determine whether or not the material is ACM. In regards to nonfriable suspected material, 40 CFR part 763.86(d) also uses the plural word “samples” and therefore also requires a minimum of two samples. An accredited inspector can use his or her discretion to take more than two samples.