Current Best Practices for PCBs in Caulk Fact Sheet - Removal and Clean-Up of PCBs in Caulk and PCB-Contaminated Soil and Building Material
Last Updated: December 2012
PCBs in caulk
EPA has learned that caulk containing polychlorinated biphenyls (PCBs) was used in many buildings, including schools, during building construction, renovation, or repair from the 1950s through the late 1970s.
This fact sheet identifies for school system officials key information on removal and cleanup of PCBs in caulk and PCB contaminated soil and building material.
In addition, this fact sheet identifies who to contact at EPA for advice on addressing PCBs in caulk.
PCBs were not added to caulk after 1979. Therefore in general, schools built after 1979 do not contain PCBs in caulk. To date it has been found in buildings in the Northeast and Upper Midwest and in joints in concrete water storage basins in the western United States. Activities to address PCBs in caulk are underway in these areas. EPA is encouraging greater awareness of this issue so people can take steps to minimize potential exposure.
Exposure to PCBs can cause a variety of adverse health effects in animals and humans. PCBs have been shown to cause cancer in animals, as well as a number of serious non-cancer health effects, including effects on the immune system, reproductive system, nervous system, endocrine system and other health effects. In humans PCBs are potentially cancer-causing and can cause other non-cancer effects as well. More information on the health effects of PCBs.
As part of EPA's overall effort to provide guidance to building owners concerning PCB containing caulk in buildings, EPA has produced three other fact sheets and a brochure that address PCBs in caulk. These fact sheets can be found on EPA's website at: www.epa.gov/pcbsincaulk.
Caulk containing PCBs at levels > 50 ppm is not authorized for use under the PCB regulations and must be removed. Caulk containing PCBs at levels < 50 ppm may remain in place. PCBs in caulk are known to contaminate adjacent building material (e.g., masonry, wood, concrete) and soil surrounding the building. Any surrounding building material that is contaminated by > 50 ppm PCB-containing caulk, is considered PCB bulk product waste if the caulk is still attached to the building materials so may all be disposed of by 761.62. (Note: If your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together, you may dispose of all the materials as a PCB bulk product waste, even if the PCB caulk becomes separated from the adjacent contaminated building materials during remediation.) On the other hand, if the caulk has been removed from the surrounding building material and is disposed of separately, the adjacent contaminated building materials are PCB remediation waste and must be cleaned up using 40 CFR § 761.61. Safely removing the PCB-containing caulk, while preventing further contamination and cleaning up surrounding materials should be the focus of cleanup projects.
Removal of PCB-containing caulk and contaminated soil and building material
When removing caulk and surrounding building material that are known or suspected to contain PCBs, it is important to manage the removal in a way that minimizes workers' exposure to the PCBs (e.g., facemasks, gloves, etc.) and prevents the release of PCBs into the environment.
Caulk: Caulk containing PCBs at concentrations > 50 ppm is not authorized for use and must be removed and properly disposed. When disposed, the caulk must be managed as PCB bulk product waste, defined at 40 CFR § 761.3. Regulations governing the cleanup and disposal of PCB bulk product waste are provided at 40 CFR § 761.62. You must remove all PCB-containing caulk or caulk coated building material containing PCBs at concentrations > 50 ppm unless otherwise approved by EPA under a risk-based disposal approval issued under 40 CFR § 761.62(c).
Building Materials: Materials (e.g., concrete, brick) that are currently coated with PCB-containing caulk at concentrations > 50 ppm may be managed as PCB bulk product waste, with the same requirements as the > 50 ppm PCB-containing caulk. If your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB bulk product waste. EPA realizes that the PCB caulk may need to be separated during removal from adjacent contaminated building materials due to the presence of other hazardous materials or may accidentally be separated during the removal process. If the PCB-containing caulk has been removed from the surrounding building material and disposed of separately, the adjacent contaminated building materials must be treated as PCB remediation waste. Regulations governing the cleanup and disposal of PCB remediation waste are provided at 40 CFR 761.61. The requirements in this section vary depending on, among other things, the type of building material that contains the PCBs (i.e., porous or non-porous) and the potential exposure levels remaining after cleanup is completed.
EPA is helping to address the issue of PCBs in caulk
EPA is conducting 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 EPA PCB Regional Coordinator at 1-888-835-5372 for help with assessing contamination and exposure and developing cleanup plans.
Ask EPA experts for help addressing PCBs in caulk
For further information on cleanup and removal of PCB caulk, contact EPA's Toxic Substances Control Act (TSCA) Hotline at 1-888-835-5372 or the EPA PCB Regional Coordinator for your area.
This fact sheet is intended solely for guidance and should be used as an informal reference. It does not replace or supplant the requirements of the Toxic Substances Control Act or the PCB regulations at 40 CFR part 761, and it is not binding on the Agency or individuals. Please refer to the regulations at 40 CFR part 761 for specific requirements relating to PCBs and PCB-containing materials.