How many units are in the structure? Federal EPA says not required for structures of 4 or fewer units. State requirements may be more stringent than federal requirements. EPA NESHAPS-Asbestos 40 CFR Part 61, Subpart M 1.A.1. The NESHAP does not cover roofing projects on single family homes or on residential buildings containing four or fewer dwelling units. 40 CFR 61.141. For other roofing renovation projects, if the total asbestos-containing roof area undergoing renovation is less than 160 ft2, the NESHAP does not apply, regardless of the removal method to be used, the type of material (Category I or II), or its condition (friable versus nonfriable).