Garden State Environmental: GSE Advisor

PCBs in Caulk: Guidance for Buildings Constructed or Renovated Between 1950 and 1978

On September 25, 2009 the U.S. Environmental Protection Agency (EPA) announced a series of steps that building owners and school administrators should take to reduce exposure to PCBs that may be found in caulk in many buildings constructed or renovated between 1950 and 1978. The agency is also conducting new research to better understand the risks posed by caulk containing PCBs. This research will guide EPA in making further recommendations on long-term measures to minimize exposure as well as steps to prioritize and carry out actions to remove the caulk to better protect public health.

Polychlorinated biphenyls, or PCBs, are man-made chemicals that persist in the environment and were widely used in construction materials and a wide variety of electrical products prior to 1978. PCBs can affect the human immune, reproductive, nervous and endocrine systems and are potentially cancer-causing.

“PCBs have been banned for the last 30 years for most uses,” said EPA Administrator Lisa P. Jackson. “But unfortunately, high levels of PCBs are present in many buildings and facilities constructed prior to the PCB ban, including some schools. We’re concerned about the potential risks associated with exposure to these PCBs and we’re recommending practical, common sense steps to reduce this exposure as we improve our understanding of the science. For building owners and administrators who want to take added and more aggressive immediate steps, EPA is providing additional guidance to help them identify the extent of potential risks and determine whether mitigation steps are necessary. Local communities and governments have constrained resources that make this a particularly challenging and sensitive situation.”

Although Congress banned the manufacture and most uses of PCBs in 1976 and they were phased out in 1978, there is evidence that many buildings across the country constructed or renovated from 1950 to 1978 may have PCBs at high levels in the caulk around windows and door frames, between masonry columns and in other masonry building materials. Exposure to these PCBs may occur as a result of their release from the caulk into the air, dust, surrounding surfaces and soil and through direct contact. EPA has calculated prudent public health levels that maintain PCB exposures below the “reference dose”, the amount of PCB exposure that EPA does not believe will cause harm. Those levels vary depending on the age group and use assumptions about potential PCB exposures from other sources, such as diet.

Although this is a serious issue, the potential presence of PCBs in buildings should not be a cause for immediate alarm. For buildings erected or renovated between 1950 and 1978, EPA recommends that owners implement steps to minimize exposure to potentially contaminated caulk in the following ways:

Prevent damage to caulk by keeping the area dry and regularly painting
Periodically cleaning air ducts
Improving ventilation by opening windows and using or installing exhaust fans where possible
Cleaning frequently to reduce dust and residue inside buildings using a wet or damp cloth or mop to clean surfaces
Not sweeping wtih dry brooms and minimizing the use of dusters in areas near potential PCB-containing caulk
Using vacuums with high efficiency particualte air filters
Washing hands with soap and water often, particularly before eating and drinking and after handling suspected PCB contaminated caulk
Washing children’s toys often

EPA also recommends tesing, peeling, brittle, cracking or deteriorating caulk directly for the presence of PCBs and removing the caulk if PCBs are present at significant levels. Alternately, the building owner can assume that PCBs are present and proactively remove deteriorating caulk. If removal is undertaken, appropriate environmental controls and personal protective equipment should be used. This is best accomplished with professional oversight by a qualified and experienced industrial hygienist or environmental consultant.

Building owners and facility managers should also consider testing to determine if PCB levels in the air exceed EPA’s suggested public health levels, especially if they suspect deteriorating caulk in their buildings. If testing reveals PCBs in the air above recommended levels, building owners should be especially vigilant in implementing and monitoring ventilation and hygienic practices to minimize exposures. Owners and managers are encouraged to re-test PCB levels in air to determine whether these practices are reducing the potential for PCB exposures. Should these practices not reduce exposure, caulk and other known sources of PCBs should be removed as soon as practicable.

Where buildings were constructed or renovated between 1950 and 1978, EPA recommends that PCB-containing caulk be removed during planned renovations and repairs (when replacing windows, doors, roofs, ventilation, etc.). It is critically important to ensure that PCBs are not released to the air during replacement or repair of caulk in affected buildings. EPA is recommending simple, common-sense work practices to prevent the release of PCBs during these operations.

Please note that many older caulks also contain asbestos, further highlighting the need for routine caution and proper safety precautions during renovation projects that might disturb suspect caulking.

The potential for airborne release of hazardous materials including PCBs and asbestos during renovations and remodeling is also covered under the NJ Public Employers Occupational Safety and Health (NJPEOSH) Indoor Air quality Regulation [N.J.A.C. 12:100-13 (2007)] - http://www.state.nj.us/health/eoh/peoshweb/peoshiaq.htm

There are several unresolved scientific issues that must be better understood to assess the magnitude of the problem and identify the best long-term solutions. For example, the link between the concentrations of PCBs in caulk and PCBs in the air or dust is not well understood. The agency is doing research to determine the sources and levels of PCBs in buildings in the U.S. and to evaluate various strategies to reduce exposures. The results of this research will be used to provide further guidance to building owners as they develop and implement long-term solutions.

Toward these goals, on January 19, 2010, The EPA announced an agreement with the City of New York to address the risks posed by PCBs in caulk found in some city schools. The agreement is intended to result in a city-wide approach to assessing and reducing potential exposures to PCBs in caulk in schools.

“The work that the City of New York has agreed to do will go a long way toward helping us better understand the potential risks posed by PCBSs in caulk, and our work to reduce the exposure of school children, teachers and others who work in New York City public schools,” said Judith Enck, EPA Regional Administrator. “New York City’s 1,600 public schools make it the largest school system in the nation, and we believe that the program outlined in this agreement, along with general EPA guidance on managing the issue, will serve as a mode for school systems across the country.”

The agreement requires the city to conduct a study in five schools to determine the most effective strategies for assessing and reducing potential exposures to PCBs in caulk. The city will then produce a proposed plan for any cleanups needed in the five schools and use this information to develop a recommended city-wide approach. EPA is also requiring the city to develop and submit for approval best management practices for reducing exposure to PCBs in caulk in school buildings. These may include cleaning the schools, improving ventilation, and addressing the deteriorating caulk,

Once the study is concluded the city will work with EPA to develop and implment a plan to indentify, prioritize, and address the presence of PCBs within the New York City school system. In addition, the agreement calls for the development of a citizens’ participation plan to ensure that school administrators, parents, teachers, students and members of the public are kep fully informed throughout the process.

More information can be found at http://www.epa.gov/pcbsincaulk.

GSE is working directly with building owners and managers facing PCB in caulk problems by helping them develop practical approaches to reduce exposures and minimize associated risks.

Anyone seeking technical guidance or information about our inspection, environmental testing and risk management programs should contact GSE at 201-652-1119.

P. 201.652.1119
F. 201.652.0612
info@gseconsultants.com

To get updates on Environmental Health Concerns Please sign up for GSE Advisor	Indoor Air Quality & Mold Training Health & Safety Environmental GSE Updates Upcoming Events PCBs in Caulk: Guidance for Buildings Constructed or Renovated Between 1950 and 1978 On September 25, 2009 the U.S. Environmental Protection Agency (EPA) announced a series of steps that building owners and school administrators should take to reduce exposure to PCBs that may be found in caulk in many buildings constructed or renovated between 1950 and 1978. The agency is also conducting new research to better understand the risks posed by caulk containing PCBs. This research will guide EPA in making further recommendations on long-term measures to minimize exposure as well as steps to prioritize and carry out actions to remove the caulk to better protect public health. Polychlorinated biphenyls, or PCBs, are man-made chemicals that persist in the environment and were widely used in construction materials and a wide variety of electrical products prior to 1978. PCBs can affect the human immune, reproductive, nervous and endocrine systems and are potentially cancer-causing. “PCBs have been banned for the last 30 years for most uses,” said EPA Administrator Lisa P. Jackson. “But unfortunately, high levels of PCBs are present in many buildings and facilities constructed prior to the PCB ban, including some schools. We’re concerned about the potential risks associated with exposure to these PCBs and we’re recommending practical, common sense steps to reduce this exposure as we improve our understanding of the science. For building owners and administrators who want to take added and more aggressive immediate steps, EPA is providing additional guidance to help them identify the extent of potential risks and determine whether mitigation steps are necessary. Local communities and governments have constrained resources that make this a particularly challenging and sensitive situation.” Although Congress banned the manufacture and most uses of PCBs in 1976 and they were phased out in 1978, there is evidence that many buildings across the country constructed or renovated from 1950 to 1978 may have PCBs at high levels in the caulk around windows and door frames, between masonry columns and in other masonry building materials. Exposure to these PCBs may occur as a result of their release from the caulk into the air, dust, surrounding surfaces and soil and through direct contact. EPA has calculated prudent public health levels that maintain PCB exposures below the “reference dose”, the amount of PCB exposure that EPA does not believe will cause harm. Those levels vary depending on the age group and use assumptions about potential PCB exposures from other sources, such as diet. Although this is a serious issue, the potential presence of PCBs in buildings should not be a cause for immediate alarm. For buildings erected or renovated between 1950 and 1978, EPA recommends that owners implement steps to minimize exposure to potentially contaminated caulk in the following ways: Prevent damage to caulk by keeping the area dry and regularly painting Periodically cleaning air ducts Improving ventilation by opening windows and using or installing exhaust fans where possible Cleaning frequently to reduce dust and residue inside buildings using a wet or damp cloth or mop to clean surfaces Not sweeping wtih dry brooms and minimizing the use of dusters in areas near potential PCB-containing caulk Using vacuums with high efficiency particualte air filters Washing hands with soap and water often, particularly before eating and drinking and after handling suspected PCB contaminated caulk Washing children’s toys often EPA also recommends tesing, peeling, brittle, cracking or deteriorating caulk directly for the presence of PCBs and removing the caulk if PCBs are present at significant levels. Alternately, the building owner can assume that PCBs are present and proactively remove deteriorating caulk. If removal is undertaken, appropriate environmental controls and personal protective equipment should be used. This is best accomplished with professional oversight by a qualified and experienced industrial hygienist or environmental consultant. Building owners and facility managers should also consider testing to determine if PCB levels in the air exceed EPA’s suggested public health levels, especially if they suspect deteriorating caulk in their buildings. If testing reveals PCBs in the air above recommended levels, building owners should be especially vigilant in implementing and monitoring ventilation and hygienic practices to minimize exposures. Owners and managers are encouraged to re-test PCB levels in air to determine whether these practices are reducing the potential for PCB exposures. Should these practices not reduce exposure, caulk and other known sources of PCBs should be removed as soon as practicable. Where buildings were constructed or renovated between 1950 and 1978, EPA recommends that PCB-containing caulk be removed during planned renovations and repairs (when replacing windows, doors, roofs, ventilation, etc.). It is critically important to ensure that PCBs are not released to the air during replacement or repair of caulk in affected buildings. EPA is recommending simple, common-sense work practices to prevent the release of PCBs during these operations. Please note that many older caulks also contain asbestos, further highlighting the need for routine caution and proper safety precautions during renovation projects that might disturb suspect caulking. The potential for airborne release of hazardous materials including PCBs and asbestos during renovations and remodeling is also covered under the NJ Public Employers Occupational Safety and Health (NJPEOSH) Indoor Air quality Regulation [N.J.A.C. 12:100-13 (2007)] - http://www.state.nj.us/health/eoh/peoshweb/peoshiaq.htm There are several unresolved scientific issues that must be better understood to assess the magnitude of the problem and identify the best long-term solutions. For example, the link between the concentrations of PCBs in caulk and PCBs in the air or dust is not well understood. The agency is doing research to determine the sources and levels of PCBs in buildings in the U.S. and to evaluate various strategies to reduce exposures. The results of this research will be used to provide further guidance to building owners as they develop and implement long-term solutions. Toward these goals, on January 19, 2010, The EPA announced an agreement with the City of New York to address the risks posed by PCBs in caulk found in some city schools. The agreement is intended to result in a city-wide approach to assessing and reducing potential exposures to PCBs in caulk in schools. “The work that the City of New York has agreed to do will go a long way toward helping us better understand the potential risks posed by PCBSs in caulk, and our work to reduce the exposure of school children, teachers and others who work in New York City public schools,” said Judith Enck, EPA Regional Administrator. “New York City’s 1,600 public schools make it the largest school system in the nation, and we believe that the program outlined in this agreement, along with general EPA guidance on managing the issue, will serve as a mode for school systems across the country.” The agreement requires the city to conduct a study in five schools to determine the most effective strategies for assessing and reducing potential exposures to PCBs in caulk. The city will then produce a proposed plan for any cleanups needed in the five schools and use this information to develop a recommended city-wide approach. EPA is also requiring the city to develop and submit for approval best management practices for reducing exposure to PCBs in caulk in school buildings. These may include cleaning the schools, improving ventilation, and addressing the deteriorating caulk, Once the study is concluded the city will work with EPA to develop and implment a plan to indentify, prioritize, and address the presence of PCBs within the New York City school system. In addition, the agreement calls for the development of a citizens’ participation plan to ensure that school administrators, parents, teachers, students and members of the public are kep fully informed throughout the process. More information can be found at http://www.epa.gov/pcbsincaulk. GSE is working directly with building owners and managers facing PCB in caulk problems by helping them develop practical approaches to reduce exposures and minimize associated risks. Anyone seeking technical guidance or information about our inspection, environmental testing and risk management programs should contact GSE at 201-652-1119.

P. 201.652.1119 F. 201.652.0612 info@gseconsultants.com