Current Best Practices for PCBs in Caulk Fact Sheet Disposal Options for PCBs in Caulk and PCB-contaminated Soil and Building Materials Last Updated September 2009

CURRENT BEST PRACTICES FOR PCBS IN CAULK FACT SHEET
Disposal Options for PCBs in Caulk and PCB-Contaminated Soil and Building Materials
Last Updated: September 2009
PCBs in caulk
EPA has learned that caulk containing polychlorinated biphenyls (PCBs) was used in many
buildings, including schools, during building construction, renovation, or repair from the 1950s
through the late 1970s.
This fact sheet identifies for school system officials key information on disposal options for
PCBs in caulk and contaminated soil and building materials.
In addition, this fact sheet identifies who to contact at EPA for advice on addressing PCBs in
caulk.
PCBs were not added to caulk after 1978. Therefore in general, schools built after 1978 do not
contain PCBs in caulk. To date it has been found in buildings in the Northeast and Upper
Midwest and in joints in concrete water storage basins in the western United States. Activities to
address PCBs in caulk are underway in these areas. EPA is encouraging greater awareness of this
issue so people can take steps to minimize potential exposure.
Exposure to PCBs can cause a variety of adverse health effects in animals and humans. PCBs
have been shown to cause cancer in animals, as well as a number of serious non-cancer health
effects, including effects on the immune system, reproductive system, nervous system, endocrine
system and other health effects. In humans PCBs are potentially cancer-causing and can cause
other non-cancer effects as well. For more information on the health effects of PCBs, go to:
www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/effects.htm.
As part of EPA's overall effort to provide guidance to building owners concerning PCB
containing caulk in buildings, EPA has produced three other fact sheets and a brochure on PCBs
in caulk. These fact sheets can be found on EPA's website at www.epa.gov/pcbsincaulk.
Determining disposal requirements
The PCB regulations separate PCB waste into several categories, with different disposal
requirements for each. When assessing your building, it is important to determine what types of
PCB waste you will be disposing of.
PCB-containing caulk is considered PCB bulk product waste if the concentration of PCBs in the
caulk is greater than or equal to (>) 50 ppm (see, 40 C.F.R. § 761.3). PCB bulk product waste
includes waste derived from manufactured products containing PCBs in a non-liquid state where
the concentration at the time of designation for disposal is > 50 ppm PCBs (see, 40 C.F.R. §§
761.3 & 761.62). Caulk with PCB concentrations > 50 ppm is not authorized for use and must
be disposed of as PCB bulk product waste according to 40 C.F.R. § 761.62.

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If PCBs have contaminated either the surrounding building materials or adjacent soil, these
materials are considered PCB remediation waste. PCB remediation waste is subject to the
cleanup and disposal requirements listed in 40 C.F.R. §761.61.
It is possible that while the following disposal options are available under the federal PCB
regulations, state or local regulations may not allow disposal of materials containing PCBs at
concentrations > 50 ppm. It is also possible that a landfill which meets the regulatory conditions
may choose not to accept materials containing PCBs at concentrations > 50 ppm. When finding
a disposal facility, you should ensure that the facility is able and willing to accept the waste.
Disposal options
PCB bulk product waste:
The disposal of PCB bulk product waste is regulated under 40 CFR § 761.62. Under this
provision, PCB bulk product waste must be disposed of in one of three ways: performance-
based disposal; disposal in solid waste landfills; or risk-based disposal approval.
Performance-based disposal. The performance-based option allows for disposal of PCB
bulk product waste in a TSCA incinerator; a TSCA chemical waste landfill; a RCRA
hazardous waste landfill; under 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 does not require you to obtain approval
from EPA.
Disposal in solid waste landfills. Certain PCB bulk product waste, such as PCB-
containing caulk, even if the concentration of PCB's 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 disposal landfill 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.
Remediation waste:
The disposal of PCB remediation waste is regulated under 40 CFR § 761.61. 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

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materials, among other things. Cleanup and disposal under this option require you to
notify your Regional PCB Coordinator.
Performance-based disposal. The performance-based option allows for disposal or
decontamination of the contaminated materials in a TSCA chemical waste landfill; a
TSCA incinerator; through a TSCA approved alternate disposal method; under the TSCA
regulation's decontamination procedures; or in a facility with a coordinated approval
issued under TSCA. Disposal under this option generally does not require you to obtain a
separate 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.
Finding a disposal facility for PCB-containing caulk
A listing of TSCA approved disposal facilities is located on EPA's web site at:
www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/stordisp.htm.
To find a solid waste disposal facility that will accept PCB-containing caulk, please contact your
state environmental agency. Information on how to contact the state agencies is located on
EPA's web site at: www.epa.gov/epawaste/wvl/stateprograms.htm.
Ask EPA experts for help addressing PCBs in caulk
If you are considering the risk-based disposal option for either bulk product or remediation
waste, you should contact EPA's PCBs in Caulk Hotline at 888-835-5372 or the EPA Regional
PCB Coordinator in your area to discuss the requirements.
Find the PCB coordinator for your state at
www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/coordin.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 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 at 888-835-5372 for help with assessing contamination and
exposure and developing cleanup plans.
This fact sheet is intended solely for guidance and should be used as an informal reference. It
does not replace or supplant the requirements of the Toxic Substances Control Act or the PCB

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regulations at 40 C.F.R. part 761, and it is not binding on the Agency or individuals. Please refer
to the regulations at 40 C.F.R. part 761 for specific requirements relating to PCBs and PCB-
containing materials.

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