CONTRACTORS
Handling PCBs in Caulk
During Renovation
 EPA-747-F-09-004

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         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 reno-
vation of a building that has polychlorinated biphenyl
(PCB)-containing caulk. PCBs were not added to caulk
after 1978. Therefore, in general, schools built after 1978
do not contain PCBs in caulk.

Contractors play an important role in protecting pub-
lic health by helping prevent exposure to toxic PCBs.
Ordinary renovation and maintenance activities involving
the removal of PCB-containing caulk and the surround-
ing contaminated substrate (brick, masonry, cinder block,
wood, etc.) can create dust that contains PCBs which
can expose children and adults.  PCBs  have been dem-
onstrated to cause a variety of adverse  health effects,  in-
cluding 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, repro-
ductive system, nervous system, endocrine system, and
other health effects.

Consider Testing the Air in Buildings Built Between
1950 and 1978 to Determine Whether Your School or
Building May Have PCBs
If school administrators and building owners are con-
       cerned 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 PCB levels
                       above these levels, schools
                        and buildings should be espe-
                         cially vigilant in implement-
                         ing 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. Caulk that is peeling or deteriorating
may be tested to determine its PCB content. Your EPA
regional PCB coordinator can direct you to a PCB testing
lab.

Take Site-Specific Protective Measures
•  Be in compliance with occupational protection regula-
 tions for contractors. (http://www.osha.gov/OshDoc/
 data_General_Facts/ppe-factsheet.pdf).
• 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.
• Use replacement caulk/sealant that is free of environ-
 mental 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.

• Electric 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).

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.

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• 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.

Interior Areas
• 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
 vents  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.

Exterior Areas
• 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 com-
                           ponents, such as windows
                           and doors, in heavy plastic
                           sheeting and tape shut.
                           • Ensure that everything,
                           including tools, equipment,
                          and even workers, is free of
                          dust and debris before leav-
                            ing the work area.
                            • HEPA vacuum the work
                           area.
                          • Clean air ducts.
                         1 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 gen-
   eral purpose cleaner.
 -Check your work
   carefully for dust
   because haz-
   ardous amounts
   may be min-
   ute and
   not eas-
   ily visible.  If
   you see any dust
   or debris,  then
   reclean the area.

Dispose of Renovation Waste Materials that Contain
PCBs in Compliance with the Toxic Substances Con-
trol 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).
• If PCBs have contaminated either the surrounding build-
 ing materials or adjacent soil, these materials are consid-
 ered PCB remediation waste.

Disposal Options
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 a
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 > 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.

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

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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 contami-
nated 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 un-
der this option requires you to notify your EPA Regional PCB
Coordinator (http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/
coordin.htm).

Performance-based disposal.  The  performance-based
option allows for disposal of the contaminated materials in
either a TSCA chemical waste landfill or TSCA incinera-
tor, 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 remedia-
tion waste may be cleaned up or disposed of in a manner
other than the alternatives provided under the self-imple-
menting or the performance-based disposal options.  Dis-
posal 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.
   &EPA
   Office of Pollution Prevention and Toxics
   United States Environmental Protection Agency
   Washington, D.C. 20460
   September 2009
Additional Information on EPA's Website
(www.epa.gov/pcbsincaulk/)
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.  You can find these documents at
http://www.epa.gov/pcbsincaulk/:

Preventing Exposure to PCBs in Caulking Material
(http://www.epa.gov/waste/hazard/tsd/pcbs/pubs/caulk/
caulkexposure.htm)

Fact Sheet: Testing for PCBs in Buildings (http://www.epa.
gov/osw/hazard/tsd/pcbs/pubs/caulk/caulktesting.htm)

Fact Sheet: Interim Measures for Reducing Risk and
Taking Action to Reduce Exposures (http://www.epa.gov/
osw/h aza rd/tsd/pcbs/pu bs/ca u I k/ca u I ki nte ri m. htm)

Fact Sheet: Removal and Clean-Up of PCBs in Caulk
and PCB-Contaminated  Soil and Building Materials
(http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/caulk/
caulkremoval.htm)

Fact Sheet: Disposal Options for PCBs in Caulk and PCB-
Contaminated Soil and Building Materials (http://www.epa.
gov/osw/hazard/tsd/pcbs/pubs/caulk/caulkdisposal.htm)

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 reduc-
ing 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
at 888-835-5372 for help with assessing contamination
and exposure and developing  cleanup plans.

Where Can I Get More Information?
For more information on how to properly test for and
address PCBs in caulk, contact the Regional PCB
Coordinator (http://www.epa.gov/osw/hazard/tsd/pcbs/
pubs/coordin.htm) for your state. For more detailed
information on renovation and removal, go to http://www.
epa.gov/pcbsincaulk/ or call the PCBs in Caulk Hotline at
888-835-5372.
        Recycled/Recyclable
        Printed with Vegetable Oil-Based Inks on Recycled Paper
        (Minimum 50% Postconsumer) Process Chlorine Free

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