PCBs in Caulking
What to do about PCBs in caulking as well as other building materials is an ongoing concern. The EPA has a complex regulation that addresses all aspects of PCB use and disposal. There are a few that all contractors should be aware of.
- EPA classifies most products that contain more than 50 ppm PCBs as unauthorized. If a product is unauthorized then the continued use of the product is illegal.
- If PCBs are found in caulking at a concentration ≥50 ppm then the material must be removed.
- There is no requirement that requires testing of PCBs if the material is not being disposed of or managed.
- If caulking or building materials contaminated by the caulking are illegally disposed of then the EPA will cite all responsible parties.
What are the responsibilities of construction contractors?
If caulking is present on a jobsite but it will not be impacted by your work then you have no responsibility to determine if the caulking contains PCBs. It is the Owner’s responsibility to determine if PCBs are present or not. However, legally he has no obligation to test for PCBs.
If caulking (or other products that may contain PCBs) is present and will be impacted by your work, then the Owner should do testing to determine if PCBs are present. The contractor should be informed of the presence of PCBs so the workers can be informed (hazard communication) and procedures implemented to prevent worker exposure, clothing contamination and work area contamination. Proper industrial hygiene protocols and an exposure assessment must be performed prior to work commencing (JHA\Risk Assessment). If the contractor is responsible for disposal of the caulking or building materials that may have come in contact with the caulking then it is vital that the EPA PCB regulations are clearly understood.
The caulking material, if it is ≥50 ppm is considered by EPA to be a PCB bulk product waste and must be properly disposed of.
If PCBs leached from the caulking into adjacent building materials then the contaminated portions of the building materials is considered to be a PCB remediation waste. A PCB remediation waste has a complex definition that can be summarized as follows:
Waste containing PCBs as the result of a spill, release or other unauthorized disposal:
- Materials disposed of prior to April 18, 1978 that are currently >50 ppm PCBs regardless of concentration of original spill.
- Materials that are currently at any volume or concentration when the original source was ≥500 ppm PCBs beginning on April 18, 1978 or ≥50 ppm PCBs beginning on July 2, 1979.
- Material which are currently at any concentration if the PCBs are spilled or released from a source not authorized for use under the regulation.
To help building owners, contractors and real estate professionals navigate the complex EPA regulations we have developed a compliance flow chart. Download this FREE tool which will help you comply with the EPA regulations on your project!
If you have a question regarding PCBs in caulking or other industrial hygiene\safety issues, simply click the button to the left, fill out the form and one of our staff members will respond.