Asbestos removal in Michigan is governed by two overlapping laws: the Asbestos Abatement Contractors Licensing Act (Public Act 135 of 1986) and the Michigan Occupational Safety and Health Act, both enforced through the MIOSHA Asbestos Program, with environmental notification and disposal rules layered on top through the Department of Environment, Great Lakes, and Energy (EGLE). Before any significant abatement work starts, a licensed contractor with accredited workers must notify two separate agencies, follow strict containment and exposure limits, and send waste only to landfills approved for asbestos. Skip a step and the fines start at civil penalties of up to $25,000 per violation per day.
Who Needs a License
The contractor license and individual worker accreditation are separate credentials, and a project needs both.
MIOSHA issues contractor licenses in two tiers based on company size. A Type I license covers contractors with one to four employees at an initial cost of $200. A Type II license, for contractors with five or more employees, costs $400 initially. Renewals drop to $100 and $300 respectively, and the renewal application must be postmarked at least 30 days before the current license expires. Miss that window and MIOSHA treats the filing as a brand-new initial application at the higher fee, with a likely gap in your authorization to work.1Michigan Department of Licensing and Regulatory Affairs. Asbestos Contractor Acquiring an Abatement License
Every person doing hands-on work or supervising it must hold individual accreditation through the MIOSHA Asbestos Program. Accreditation starts with a Michigan-approved or EPA-approved training course from a private provider. There is no separate state exam. After finishing the course, the individual sends an application to the MIOSHA Asbestos Program with training history, a color photo, photo ID, and the fee. Accredited individuals must complete annual refresher training to keep their credentials current.2Michigan Department of Licensing and Regulatory Affairs. The MIOSHA Asbestos Program Individuals Required to Become Accredited
One exemption matters for property owners. If you remove asbestos-containing material from your own property, you do not need a Michigan asbestos abatement contractor license. The exemption stops there. Any employees doing the work must still meet all MIOSHA Part 602 safety standards, including exposure limits, protective equipment, containment, and air monitoring.
Notifications Before Work Begins
Two agencies want advance notice, and the deadlines run in parallel. Forgetting either one is a violation on its own, regardless of how carefully the removal itself is done.
The MIOSHA Asbestos Program requires project notification 10 days before starting any non-emergency abatement that exceeds 10 linear feet or 15 square feet of friable asbestos-containing material.3State of Michigan. LEO – Notifications
EGLE separately enforces the federal National Emission Standards for Hazardous Air Pollutants (NESHAP) for asbestos. NESHAP notification is due at least 10 working days before beginning regulated demolition or renovation, filed through EGLE’s MiEnviro Portal. The notification must identify the type and quantity of asbestos, scheduled start and completion dates, the abatement and demolition contractors, the disposal site, the waste transporter, and the engineering controls that will be used. Emergency renovations and ordered demolitions have shorter timelines but must be reported no later than the following work day.4Michigan Department of Environment, Great Lakes, and Energy. Understanding the Asbestos NESHAP Fact Sheet
The federal NESHAP residential exemption is narrower than most homeowners assume. Only privately owned homes and residential buildings with four or fewer dwelling units qualify, and only if the building has no previous or planned commercial or public use. A five-unit apartment building, a former commercial property converted to residential use, or publicly owned housing does not qualify.
Safety and Disposal Rules on the Job
MIOSHA Part 602, the Asbestos Standard for Construction, adopts federal OSHA’s rule (29 CFR 1926.1101) and sets the exposure limits that shape everything else on site. Airborne asbestos fibers cannot exceed 0.1 fibers per cubic centimeter averaged over an 8-hour workday, and cannot exceed 1.0 fiber per cubic centimeter averaged over any 30-minute period.5Michigan Department of Licensing and Regulatory Affairs. Part 602 Asbestos Standard for Construction
Those limits drive the controls you see on a compliant project: negative pressure enclosures, wet methods to suppress fiber release, HEPA-filtered equipment, respirators and protective clothing, decontamination before anyone leaves containment, and air monitoring throughout the job. After the work is finished, clearance air testing confirms the space is safe for reoccupancy.
Waste handling is regulated just as tightly. Michigan law prohibits delivering asbestos waste to a landfill unless the facility complies with the federal disposal requirements in 40 CFR 61.154, which govern wetting, packaging, labeling, and burial.6Michigan Legislature. Michigan Compiled Laws 324.11514 Waste must be adequately wetted, sealed in leak-tight containers or bags, and labeled with asbestos warnings during transport. Dumping at an unapproved facility or skipping the wetting and packaging steps triggers penalties under both state and federal law.4Michigan Department of Environment, Great Lakes, and Energy. Understanding the Asbestos NESHAP Fact Sheet
Penalties for Getting It Wrong
Michigan runs two civil penalty tracks that can hit the same project at the same time. The Asbestos Abatement Contractors Licensing Act authorizes civil penalties of up to $10,000 for each violation, per day the violation continues. For violations of the licensing requirement itself, the cap climbs to $25,000 per violation per day, aligned with EPA’s civil penalty policy for asbestos demolition and renovation. Regulators weigh the nature and gravity of the violation, ability to pay, effect on continued operation, prior violations, and degree of culpability.7Michigan Legislature. Michigan Compiled Laws 338.3307 – Civil Penalties
MIOSHA imposes its own workplace safety penalties for violations of Part 602. Willful or repeated violations can reach $70,000 per violation. Serious violations carry a lower maximum. These are separate from and additional to the licensing act fines.8Michigan Legislature. Senate Fiscal Agency Bill Analysis – HB 4185
Certain violations are criminal. Any contractor who operates without a license, or any person who violates the act or its rules and fails to correct the violation after notice, is guilty of a misdemeanor. A first conviction carries a fine of up to $500. A subsequent conviction can bring a fine of up to $1,000, imprisonment for up to six months, or both. Repeated violations can also result in revocation of the abatement license, permanently barring the contractor from operating in Michigan. Prosecutions may be brought by the state Attorney General or the local prosecuting attorney.9Michigan Legislature. Michigan Compiled Laws 338.3311 – Violation as Misdemeanor; Penalty; Prosecution
Regulatory fines are often the smaller problem. Non-compliant contractors and property owners also face private lawsuits from people harmed by improper handling. If sloppy work leads to fiber exposure and someone later develops mesothelioma or asbestosis, damages can dwarf any regulatory penalty, and documented regulatory violations make those cases considerably easier for plaintiffs to prove.
Defenses if You’re Cited
The most effective defense in an enforcement action is showing you actually followed the rules. Training records, air monitoring data, filed notifications, and documentation of containment and disposal procedures give regulators room to reduce or withdraw penalties. This works best when the alleged violation is technical or borderline. It carries little weight when the violation is obvious, like operating without a license or skipping notification.
Property owners who unknowingly acquire contaminated land may have a separate defense. Under CERCLA, the federal innocent landowner defense protects buyers who had no knowledge of contamination at purchase, provided they conducted all appropriate inquiry beforehand.10United States Environmental Protection Agency. Third Party Defenses and Innocent Landowners Michigan offers a similar defense under Part 201 of the Natural Resources and Environmental Protection Act. Owners and operators who acquired property after June 5, 1995 can avoid liability for contamination they did not cause by conducting a baseline environmental assessment. Residential owners, commercial lessees, and those who inherit contaminated property receive additional protections and generally are not liable unless they directly caused a release. How well this defense holds up depends on the thoroughness of the pre-purchase inquiry and what the owner did once asbestos was discovered.