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Contractors: Handling PCBs in Caulk During Renovation

This brochure is meant to provide contractors, parents, teachers, and school administrators a general overview of the practices a contractor should consider when conducting the renovation of a building that has polychlorinated biphenyl (PCB)-containing caulk. PCBs were not added to caulk after 1979. Therefore, in general, schools built after 1979 do not contain PCBs in caulk.

Contractors play an important role in protecting public health by helping prevent exposure to toxic PCBs. Ordinary renovation and maintenance activities involving the removal of PCB-containing caulk and the surrounding contaminated substrate (brick, masonry, cinder block, wood, etc.) can create dust that contains PCBs which can expose children and adults. PCBs have been demonstrated to cause a variety of adverse health effects, including cancer in animals. PCBs have also been shown to cause a number of serious non-cancer health effects in animals, including effects on the immune system, reproductive system, nervous system, endocrine system, and other health effects.

Consider Testing the Air in Buildings Built Between 1950 and 1979 to Determine Whether Your School or Building May Have PCBs

If school administrators and building owners are concerned about exposure to PCBs and wish to supplement the steps recommended in this brochure, EPA recommends testing to determine if PCB levels in the air exceed EPA's suggested public health levels. If testing reveals levels above the suggested public health levels, school and building operators should be especially vigilant in implementing and monitoring practices to minimize exposures. If PCBs are found in the air, EPA will assist in developing a plan to reduce exposure and manage the caulk. You cannot tell if caulk has PCBs by looking at it.  EPA believes the old caulk that is still flexible or is in visibly good condition may be a significant source of PCBs into the air.  The only way to be sure that caulk has PCBs is to have a professional test the caulk. Your EPA Regional PCB Coordinator can direct you to a PCB testing lab.

Take Site-Specific Protective Measures

A pilot renovation project may be warranted to verify whether the renovation goals can be met. It will allow you to compare methods, tools, and protective measures to get specific information about their effectiveness and cost.

Before Starting the Job, Consider the Types of Tools and Machinery for Removing Caulk

Notify Interested Parties and Plan for Emergencies

Take General Protective Measures

Interior Areas

Exterior Areas

Leave the Work Area Clean

On a daily basis you should:

Dispose of Renovation Waste Materials that Contain PCBs in Compliance with the Toxic Substances Control Act (TSCA)

Disposal Options

PCB bulk product waste: The disposal of PCB bulk product waste is regulated under 40 CFR 761.62 of TSCA. Under this provision, PCB bulk product waste must be disposed of in one of two ways: disposal in a permitted solid waste landfill or via risk-based disposal approval process.

Disposal in solid waste landfills: Certain PCB bulk product waste, such as PCB-containing caulk, even if the concentration of PCBs in the caulk is equal to or greater than 50 ppm, may be disposed of in non-hazardous waste landfills permitted by states. Disposal under this option does not require you to obtain approval from EPA. However, EPA recommends that you determine prior to shipment that the landfill is willing and able to accept the PCB waste. Anyone sending PCB bulk product waste to a non-hazardous waste landfill permitted by a state must send written notice to the landfill prior to shipment of the waste stating that the waste contains PCBs at greater than 50 ppm (see 40 CFR 761.72(b)(4)(ii)). This guidance document does not replace or supersede any (sampling) requirements that the receiving facility may deem necessary to determine acceptance of the waste into its facility. Additionally, this guidance does not supersede state requirements which may be more stringent than those mandated by the federal government for management of this debris.

Risk-based option: The risk-based option allows for a site-specific, risk-based evaluation of whether PCB bulk product waste may be disposed of in a manner other than under the performance-based disposal option or the solid waste landfill disposal option. Disposal of PCB bulk product waste under this option requires you to obtain approval from EPA based on a finding that the disposal will not present an unreasonable risk of injury to health or the environment.

PCB remediation waste: The disposal of PCB remediation waste is regulated under 40 CFR 761.61 of TSCA. There are three options for management of PCB remediation waste:

Additional Information on EPA's Website

EPA has developed an informational brochure and fact sheets to provide building owners and managers with key information on the current best practices for addressing PCBs in caulk. View these documents here.

Preventing Exposure to PCBs in Caulking Material || PDF version (2 pp, 2.7MB)

Fact Sheet: Testing for PCBs in Caulk in Buildings

Fact Sheet: Interim Measures for Reducing Risk and Taking Action to Reduce Exposures

Fact Sheet: Removal and Clean-Up of PCBs in Caulk and PCB-Contaminated Soil and Building Materials

Fact Sheet: Disposal Options for PCBs in Caulk and PCB-Contaminated Soil and Building Materials

EPA is Helping to Address the Issue of PCBs in Caulk

Where Can I Get More Information

EPA has conducted research on how the public is exposed to PCBs in caulk and on the best approaches for reducing exposure and potential risks associated with PCBs in caulk. Where PCBs have been found in the air, soil, or in the caulk and other building materials, EPA is committed to helping schools and communities enact plans to reduce exposure. Please contact your regional PCB coordinator for help with assessing contamination and exposure and developing cleanup plans. Please contact your regional EPA Regional PCB Coordinator help with assessing contamination and exposure and developing cleanup plans.

 

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