PCBs, or polychlorinated biphenyls, are a mixture of individual chemicals which were widely used until their use was banned in the late 1970’s. PCBs are environmentally persistent and have a wide range of documented detrimental health effects impacting the neurological development of children. PCBs also impact the reproductive and immune system, are an endocrine disruptor, and a potential carcinogen. These chemicals are highly regulated by the US EPA under the Toxic Substance Control Act (TSCA).
PCBs are found in building materials and can present a risk to building occupants. Exposure to PCBs may occur through inhalation of airborne PCBs or from ingesting dusts containing PCBs. Dermal exposure is also a potential pathway for exposure and is well documented in industrial settings.
Most building owners and operators are aware of the presence of PCBs in light ballasts and are aware of the regulations surrounding their proper handling and disposal. Building owners and operators are now gaining a better understanding as to the potential extent and impact that PCBs in building materials presents.
Lighting - Most buildings have undergone retrofits of lighting systems and it is likely that PCB containing ballasts have been removed as a result. Ballasts manufactured after 1978 until 1998 should be clearly marked by the manufacturer with a note indicated “No PCBs”. Ballasts manufactured after 1998 are not required to be labeled “No PCBs” but are not considered to be a potential source. If you suspect that your building contains older ballasts which may contain PCBs, special care should be taken to identify and properly handle leaking ballasts. Further, proper packing and disposal is required. The EPA recommends removing these older light ballasts which contain PCBs because they have well exceeded their useful lifespan.
Other building materials - The EPA has indicated that it believes there was a potential for the wide use of PCBs in construction materials used in schools and other structures including light ballasts associated with fluorescent fixtures, caulking, paint and, to a lesser extent, other construction materials manufactured between the 1950s through 1979.PCBs were widely used in industrial settings, electrical equipment, hydraulic fluidsand in some coatings. Materials identified as potentially containing PCBs in the built environment are shown in the table below (this is not an exhaustive list and is representative of materials commonly found to contain PCBS.
Caulking, sealants and coatings - PCBs were added to caulking, sealants and coatings because of their elastic properties. Caulking and other sealant materials can be found in locations where gaps between building materials such as masonry features, building joints, window and door frames. It is believed that PCBs may off-gas from the caulking materials which could contribute to elevated airborne levels of PCBs. Additionally, it is important to note that PCBs have been found to leach out of the caulking or sealant material and into construction materials such as stucco and concrete. These impacted adjacent materials are considered secondary sources.
Secondary sources - Materials which have become impacted by primary sources. In the example used above where PCBs containing caulking impacted adjacent stucco, the caulking would be the primary source and the stucco would be the secondary source.
Pre-renovation/Demolition Recommended Actions - Uncontrolled disturbance of these construction materials and secondary sources may cause the aerosolization of dust particles containing PCBs which can be inhaled or ingested by building occupants. Prior to impacting source materials and secondary sources during renovation projects such materials should be removed to avoid potentially exposing workers and the public to PCBs and to maintain compliance with disposal regulations.
Removal - Self-implementing clean-up 40 CFR 761.61 (a)
If the decision is made to not remove the identified PCBs and manage it in-place, then a risk based decision process is required to be followed and approval can take up to 180 days.
In place management - Risk-based clean-up 40 CFR 761.61 (c)
Proper disposal of building materials containing PCBs such as caulking and adjacent materials impacted by PCB containing materials is mandated under TSCA and state regulations. Proper testing, packaging, manifesting and disposal procedure must be followed.
If you have questions, need help assessing your risks, or for more information contact Alta at 888-608-3010 or david.Schack@altaenviron.com.