Swimming Pools and Asbestos

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

Swimming Pools are regulated at the following facilities under Asbestos National Emission Standards for Hazardous Air Pollutants (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 swimming pool. The swimming pool is regulated if the following two criteria is 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 demolition or renovation Asbestos NESHAP Notification to the Maricopa County Air Quality Department (MCAQD). An Asbestos NESHAP Notification can now be submitted electronically through the AQD Online Portal. Instructions on how to do this can be found on our AQD Online Portal webpage. An Asbestos NESHAP Notification must be submitted at least 10 business days prior to starting any demolition or renovation activity. When submitting electronically, the 10-day waiting period begins immediately following an online submittal. 

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 Notification regulations and therefore is not considered demolition. If more than one living structure (i.e. guest house) is located on the property and also being demolished, the swimming pool would then be subject to the Asbestos NESHAP Notification 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 Notification regulations.

Page reviewed 16 Sep 2020