Tenant improvements · Colorado rules
Short answer: in Colorado, public and commercial buildings need an inspection by a state-certified asbestos building inspector before more than 160 square feet of material, or 260 linear feet of pipe, is disturbed. Painting over intact walls does not usually disturb material. Sanding, scraping, removing texture and demolition can.
Why this comes up on repaint jobs
A straight repaint of sound walls is a coating going on, not material coming off. Tenant improvement work is different. New layouts mean walls come down, ceilings get opened, textured surfaces get skimmed or scraped, and old finishes get sanded. In older buildings, some of those materials can contain asbestos, and Colorado regulates their disturbance before the work starts, not after.
The thresholds, side by side
| Building type | Inspection required before disturbing more than |
|---|---|
| Public and commercial buildings | 160 sq ft of material, or 260 linear ft of pipe |
| Single-family residences | 32 sq ft of surfaces, 50 linear ft of pipe, or a 55-gallon drum volume |
CDPHE's guidance also describes a possible exemption for buildings constructed after October 12, 1988. Check the guidance directly for how that applies to your building.
How it fits a TI schedule
- Before demo: the owner or GC arranges the inspection of materials the work will disturb.
- Results in hand: if materials test positive, abatement by licensed professionals happens before other trades proceed in that area.
- Painting: prep that sands, scrapes or removes texture waits for clearance in that area.
Voice answer: does painting over asbestos need a permit in Colorado?
Painting over intact material is generally not a disturbance. The CDPHE inspection rules apply when material will be disturbed beyond the thresholds. If you are unsure, ask CDPHE or a certified inspector before work starts.
For how we sequence painting on build-outs, see tenant improvement painting.