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  • Question

    Is testing the forms of HAZMAT listed above a construction of service activity?


    Answer

    A survey for lead-based paint (LBP), asbestos, and radon in existing structures is a service.  No construction work is required to complete the tests for these environmental hazards. 

    A resource for determining the type of contract to be used is the Army Corps of Engineers pamphlet ARCHITECT-ENGINEER CONTRACTING IN USACE, EP 715-1-7.   Appendix H – Environmental Services provides guidance in determining whether these efforts should be normal services under FAR part 37 or fall under Architect-Engineering services under FAR subpart 36.6.  Based on that guideline, this testing would be considered normal services and follow FAR part 37 and the appropriate agency regulations.

    https://www.publications.usace.army.mil/Portals/76/Publications/EngineerPamphlets/EP_715-1-7.pdf

    Testing for these three items can be incorporated as part of a construction contract and would be particularly important when remodeling existing structures.  Testing for radon does not require any digging and is seldom done on plain soil.  Standard radon testing done on existing structures and excavations is through monitors put in place, usually at the lowest point of the structure, over a period of time. 

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