If a contractor is mid-tear-off on a pre-1989 roof and has just pulled back the shingles to reveal the underlayment, this page is for you. Asbestos roofing felt was banned by the EPA in 1989. Some historical formulations contained 85 to 87% asbestos by weight. The material is typically invisible until the shingles come off.
How to identify roofing felt and shingles
Asbestos roofing felt appears as a black, gray, or mottled black-and-white sheet material beneath the shingle layer, similar in appearance to modern tar paper. Color alone cannot confirm asbestos content. Lab testing is required.
The surface often has a slightly granular or rough texture compared to smooth modern synthetic underlayment. When aged, it becomes brittle and fragments rather than flexing. Modern synthetic underlayment is pliable; asbestos felt snaps. If a piece is torn or broken, the cross-section often shows a dark, fibrous internal structure.
The material is found only between the shingles and the roof deck. Homeowners do not typically encounter it until shingles are removed. Multi-ply flat roofs (built-up roofing) used multiple layers of asbestos felt laminated with tar and carry the highest asbestos content of any roofing application. The practical identification moment is during a reroofing job. If the underlayment beneath old shingles appears dark, granular, and brittle rather than smooth and flexible, sample before the job continues.
Key visual cues:
- Black or dark brown asphalt-saturated felt underlayment beneath shingles.
- Built-up roofing (flat roofs) with alternating layers of felt and hot-mopped asphalt.
- Some mineral-surfaced roll roofing from the 1950s through 1970s.
- Cutouts from renovations often reveal the felt layer against the roof deck.
Risk by home build year
| Era | Risk | Reason |
|---|---|---|
| Before 1980 | Do Not Disturb | Peak asbestos use in residential construction. |
| 1980 to 1995 | Test Recommended | Transitional period. Some manufacturers continued, others phased out. |
| After 1995 | Low Risk | Asbestos effectively phased out of this material class in US and Canada. |
Safety
Do not perform a DIY roof tearoff on a pre-1980 roof without confirming the felt and shingle composition. Intact roofing can often be overlaid with a new layer rather than stripped.
Source: EPA: Asbestos NESHAP. OSHA 29 CFR 1926.1101 exterior roofing exemptions do not eliminate all controls.
What to do next
- 1
Stop the tear-off and test
Do not allow a full shingle and underlayment removal to proceed on a pre-1989 home without testing the existing felt first. Reroofing operations that strip felt generate significant asbestos dust if the underlayment contains asbestos. A small sample taken before the job starts prevents a much larger abatement problem mid-project.
- 2
Collect a sample from an accessible edge
A bulk sample of the felt material (approximately 2 cm x 2 cm) is collected from the roof edge where a small section has already been disturbed, or from a section a contractor has already begun removing. Western Analytical explicitly lists roofing as an accepted sample category. EMSL accepts all roofing material types. Collection typically requires roof access with proper safety equipment.
- 3
Abatement before completion
Per OSHA, removal of asbestos-containing roofing felt is Class II asbestos work, requiring respiratory protection, a regulated work area, and proper disposal. National cost range: $50–$120 per sq ft for full asbestos roofing abatement including felt and shingles. Full residential roof: $8,000–$25,000 or more depending on size and story count.
Regulatory authority
The EPA's 1989 Asbestos Ban and Phase-Out Rule explicitly banned asbestos-containing roofing felt, making this the strongest primary citation for this material: a direct statutory prohibition rather than a guidance recommendation (EPA, "EPA Actions to Protect the Public from Exposure to Asbestos," epa.gov). OSHA's construction standard (29 CFR 1926.1101) classifies roofing work involving removal of asbestos-containing felt as Class II asbestos work, the second-highest regulatory classification for construction hazard (OSHA, osha.gov). Health Canada's asbestos health risk guidance applies to Canadian homeowners reroofing pre-1989 homes, where similar underlayment products were in widespread use (Health Canada, canada.ca).