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
- Be in compliance with occupational protection regulations for contractors (PDF) (2 pp, 286K).
- Protect building occupants and passersby by containing the work area to prevent PCB-containing caulk dust from getting into the surrounding environment.
- Determine disposal options based on concentration and type of material.
- Place an encapsulant underneath the new caulk/sealant (since PCBs in the adjoining material can move into the new caulk/sealant). Use replacement caulk/sealant that is free of environmental hazards.
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
- Manual tools are recommended for soft flexible caulk:
- Advantages: no dust and no heat
- Disadvantages: labor intensive and slow
- Electromechanical tools are recommended for hardened/brittle caulk:
- Advantages: faster, less labor intensive
- Disadvantages: generate heat (which can volatilize the PCBs) and dust, requiring added protective measures. Also must consider the potential abrasive effects on sensitive adjoining structures (e.g., wood and metal).
- EPA recommends removing as much of the old caulk as possible, since any residual caulk left in place can contaminate any new caulk or sealant that is applied.
Notify Interested Parties and Plan for Emergencies
- Communicate the goals, type, and length of projects and specific behavior rules to the affected groups (PTA, school principal, etc.).
- Have an emergency contact list (hospitals, police, etc.).
- Ensure workers are properly trained.
- Prevent unauthorized persons from entering the site.
Take General Protective Measures
- Ensure workers are properly trained.
- Choose the method that minimizes the amount of dust generated.
- Choose methods that protect workers, building users, passersby, and the surroundings of the restoration project.
- Use proper containers to hold removed caulk.
- Use gloves and skin protection.
- Use eye goggles.
- Do not smoke, drink, or eat in the work area.
- Wash hands prior to breaks.
- In dusty work areas, have showers available and separate changing areas so that dust on clothing is not brought home.
- If working with solvents, provide respirators.
- Cover work areas with plastic.
- Use signs to keep residents and pets out of the work area.
- Remove furniture and belongings, or cover them securely with heavy plastic sheeting.
- Use heavy plastic sheeting to cover floors and other fixed surfaces like large appliances in the work area.
- Improve ventilation and add exhaust fans. Close and seal the ventilation system in the work area and, if necessary, turn off forced-air heating and air-conditioning systems.
- Regularly clean the work area with an industrial (HEPA) vacuum and by wet mopping.
- Properly dispose of personal protective equipment and cleaning material.
- Mark off the work areas to keep non-workers away.
- Cover the ground.
- Enclose scaffolding.
- Cover the ground and plants with heavy plastic sheeting.
- Close windows and doors near the work area.
- Move or cover play areas near the work area.
Leave the Work Area Clean
On a daily basis you should:
- Put trash and debris in heavy-duty plastic bags.
- Wrap waste building components, such as windows and doors, in heavy plastic sheeting and tape shut.
- Ensure everything, including tools, equipment, and even workers, are free of dust and debris before leaving the work area.
- HEPA vacuum the work area.
- Remember, you do not want to bring PCB dust home and expose your family.
- Remind residents to stay out of the work area. When the job is complete, you should also:
- Remove the plastic sheeting carefully, mist with water, fold dirty side in, tape shut, and dispose of it.
- HEPA vacuum all surfaces, including walls.
- Wash the work area with a general purpose cleaner.
- Check your work carefully for dust because hazardous amounts may be minute and not easily visible. If you see any dust or debris, then re-clean the area.
Dispose of Renovation Waste Materials that Contain PCBs in Compliance with the Toxic Substances Control Act (TSCA)
- PCB-containing caulk is considered PCB bulk product waste if the concentration of PCBs in the caulk is greater than or equal to (=) 50 parts per million (ppm).
- Surrounding building materials to which PCB caulk is still attached may be disposed of as a PCB bulk product waste, if there is no source of PCB contamination other than the caulk. This could apply in situations such as demolition and disposal of entire buildings, walls, etc. (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. 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 PCB caulk has been removed from the surrounding building material and disposed of separately, any contaminated surrounding building materials and adjacent soil are considered PCB remediation waste. This could apply in situations where the PCB caulk is removed, but the contaminated substrate is to be remediated.
- The decision on how to manage PCB contaminated substrate may be subject to a variety of site-specific facts. The appropriate EPA regional office and regional PCB coordinator can be consulted as necessary for assistance with making these decisions. For instance, property owners have identified instances where PCB caulk contained high levels of other hazardous constituents such as asbestos. Similarly, there are cases where PCB paint has been found to contain high levels of leachable metals. In these scenarios, care must be taken to fully characterize the waste to determine the appropriate disposal option.
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:
Self-implementing cleanup and disposal: The self-implementing option links cleanup levels with the expected occupancy rates of the area or building where the contaminated materials are present. The disposal requirements for the self-implementing regulatory option vary based on the type of contaminated material and concentration of PCBs in the materials, among other things. Cleanup and disposal under this option requires you to notify your EPA Regional PCB Coordinator.
Performance-based disposal: The performance-based option allows for disposal of the contaminated materials in either a TSCA chemical waste landfill or TSCA incinerator, through a TSCA-approved alternate disposal method, under the TSCA-regulated decontamination procedures, or in a facility with a coordinated approval issued under TSCA. Disposal under this option generally does not require you to obtain approval from EPA.
Risk-based cleanup and disposal: The risk-based option allows for a site-specific evaluation of whether PCB remediation waste may be cleaned up or disposed of in a manner other than the alternatives provided under the self-implementing or the performance-based disposal options. Disposal of PCB remediation waste under this option requires you to obtain an approval from EPA based on a finding that the disposal will not present an unreasonable risk of injury to health or the environment.
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.
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.