U. S. Environmental Protection Agency

Practical Actions for Reducing
Exposure to PCBs in Schools
and Other Buildings

Guidance for school administrators and
other building owners and managers

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July 28, 2015

Polychlorinated Biphenvls (PCBs)
in Building Materials

Based on the information available, the EPA
believes that there was potential widespread use
of PCB-containing building materials in schools
and other buildings built or renovated between
about 1950 and 1979. This is an important issue
because PCBs have been identified as probable
human carcinogens and may cause a variety of
non-cancer health effects. Although the
presence of PCBs in schools and other buildings
may be a concern, the presence of PCBs alone is
not necessarily a cause for immediate alarm.
However, if PCBs are present or suspected of
being present, EPA recommends actions
outlined in this document be taken by school
administrators, building owners and building
managers to reduce PCB exposures. You may
also reference the document PCBs in Building
Materials—Questions & Answers for more
information.

What do I do if I think PCBs are in
my building?

Regardless of whether PCBs are known to be
present, the EPA recommends that all schools and
other buildings built between about 1950 and 1979
implement the following best management practices
to minimize potential building occupant exposure to
PCBs:

•	Remove all PCB-containing fluorescent light
ballasts (FLBs) (details on page 2)

•	Conduct the following best management
practices (BMPs) listed below on a frequent
ongoing basis to minimize potential exposures to
PCBs (details on page 2)

•	Remove PCB-containing caulk, paint and other
PCB-containing building materials during
planned renovations and repairs (when replacing
windows, doors, roofs, ventilation, etc.) (details
on page 3)

•	Consider encapsulation to reduce PCB exposure
(details on page 4)

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U. S. Environmental Protection Agency

July 28, 2015

What do I do if I think PCBs
are in my building?

Remove all PCB-containing fluorescent light ballasts
(FLBs)

EPA recommends that non-leaking PCB FLBs be removed and retrofitted as part of lighting
upgrades or as a stand-alone project. Leaking PCB FLBs must be removed and disposed of as
required under 40 CFR part 761, subpart D. The EPA recommends that an experienced contractor
or properly trained facilities maintenance staff person perform the removal, cleanup and disposal of
PCB-containing FLBs, light fixtures and building surfaces. Consult with your EPA Regional PCB
Coordinator to ensure that all relevant cleanup procedures are followed; see
https://www.epa.gov/pcbs/epa-regional-polychlorinated-biphenyl-pcb-programs

The EPA's recommended procedures for the proper removal and disposal of PCB FLBs are listed at:

Conduct the following best management practices (BMPs) listed below on a
frequent ongoing basis to minimize potential exposures to PCBs

/ Ensure that ventilation systems are operating properly and are regularly inspected and
maintained according to system manufacturer instructions and guidelines or ANSI/
ASHRAE/ACCA Standard 180-2012—Standard Practice for Inspection and Maintenance of
Commercial Building HVAC Systems. If system cleaning is needed, follow ANSI/ACCA

Standard 6 - Restoring the Cleanliness of HVAC Systems (2007).

^ Clean inside schools and other buildings frequently to reduce dust and residue.

^ Use a wet or damp cloth or mop to clean surfaces.

^ Use vacuums with high efficiency particulate air (HEPA) filters.

^ Do not sweep with dry brooms or use dry cloths for dusting.

^ Wash hands with soap and water, particularly before eating.

^ Wash children's toys.

For EPA's general school cleaning recommendations, visit: http://www.epa.gov/iaq/schools/
clean maintenance.html.

Due to building specific factors, these BMPs may not always adequately reduce PCB exposure. In
some cases, additional and more frequent cleaning or other actions to identify and address PCB
sources may be warranted.

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U. S. Environmental Protection Agency

July 28, 2015

Remove PCB-containing caulk, paint and other PCB-containing building materials
during planned renovations and repairs (when replacing windows, doors, roofs,
ventilation, etc.)

Prior to removal, EPA recommends PCB testing for caulk and other building materials that are going to
be removed to determine what protections are needed during removal and to determine proper disposal
requirements. Where testing confirms the presence of PCBs at regulated levels in building materials,
they must be disposed of or decontaminated in accordance with the PCB regulations at 40 CFR part
761, subpart D. In lieu of testing, caulk, paint and other building materials potentially containing PCBs
that are part of building repair and renovation activities may be assumed to contain PCBs at regulated
levels and disposed of in accordance with 40 CFR part 761, subpart D.

To ensure that PCB-containing building material does not contaminate surrounding surfaces when it is
removed and disposed of, repairs that disturb PCB-containing building material, such as window
removal and replacement, should be conducted by trained workers who use safe work practices to
minimize dust and contain contaminated waste. EPA has developed guidance for minimizing exposures
when conducting repair and renovation activities, including cleaning the work area once the work is
completed; see https: //www.epa.gov/pcbs/steps-safe-renovation-and-repair-activities.

Actions contractors should take include:

•	Ensure workers are properly trained and are using gloves, eye goggles, skin protection and
approved particulate breathing masks.

•	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.

•	Use heavy plastic sheeting to cover floors and other fixed surfaces like large appliances in the work
area.

•	Close and seal vents in the work area and turn off forced-air heating and air-conditioning systems.

•	Regularly clean the work area using a HEPA vacuum and wet mopping.

•	Properly dispose of personal protective equipment and cleaning material.

Building occupants should be notified of the PCB repair and renovation activities (including PCB FLB
removal) and be completely isolated from the parts of the building undergoing PCB repair and
renovation activities to prevent exposure to PCBs. Additional actions, including physically isolating the
work space with physical barriers and negatively pressurizing work areas may be necessary (see http://
www.epa.gov/iaq/schooldesign/renovation.html). If complete isolation of the work space cannot be
assured, school administrators and building owners and operators should temporarily remove
occupants from the area of the building while the work is underway.

For additional guidance on protecting occupants during renovations or other construction activities, see
ANSI/SMACNA 008-2008: IAQ Guidelines for Occupied Buildings Under Construction. The
guidelines are available from the Sheet Metal and Air Conditioning Contractors National Association,
Inc. (SMACNA) at http://www.smacna.org.

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U. S. Environmental Protection Agency

July 28, 2015

Consider encapsulation to reduce PCB exposure

Encapsulation may be useful for the reduction of air emissions from secondary sources such as
contaminated building materials under and around PCB-containing caulk or paint that has been
removed. Because each site will present unique circumstances, please consult your EPA Regional PCB
Coordinator regarding the application of encapsulation measures on a case-by-case basis. EPA has
conducted research on the effectiveness of encapsulation and additional details may be found at:
https://www.epa.gov/pcbs/fact-sheets-summarizing-research-polvchlorinated-biphenvls-pcbs-school-
buildings

Contact your EPA Regional PCB Coordinator

After implementing BMPs, school administrators should consult with the EPA Regional PCB Coordina-
tor to assess if there still may be the potential for PCB releases in their school and whether to consider
testing indoor air for PCBs. Each school is unique, which means that many factors should be considered
when deciding whether and how to test the indoor air at a school. This decision should be made in
consultation with the EPA Regional PCB Coordinator and the decision makers should thoughtfully
consider all available information, such as: school-specific conditions (e.g., building age, types of
materials used in construction, layout, maintenance or renovation history), BMPs already implemented
to address PCB sources, and available technical resources, costs, and public concerns.

Only air testing can determine if PCBs are present in indoor air after BMPs and other actions have
been implemented. In cases where school administrators, building owners and building managers
have implemented BMPs and taken other actions but still have concerns about PCB exposure and
potential sources, EPA recommends that they consult with their EPA Regional PCB Coordinator

on appropriate next steps.

For more information visit:

https://www, epa.gov/pcbs/polychlorinated-biphenyls-pcbs-biiilding-materials

Or Call:

EPA Region 1 (CT, MA, ME, NH, RI, VT) Tel: 617-918-1527

EPA Region 2 (NJ, NY, PR, US Virgin Islands) Tel: 732-906-6817

EPA Region 3 (DE, DC, MD, PA, VA, WV) Tel: 215-814-2177

EPA Region 4 (AL, FL, GA, KY, MS, NC, SC, TN) Tel: 404-562-8512

EPA Region 5 (IL, IN, MI, MO, OH, WI) Tel: 312-886-7890

EPA Region 6 (AK, LA, NM, OK, TX) Tel: 214-665-6796

EPA Region 7 (IA, KS, MO, NE) Tel: 913-551-7504

EPA Region 8 (CO, MT, ND, SD, UT, WY) Tel: 303-312-6446

EPA Region 9 (AZ, CA, HI, NY, American Samoa, Guam) Tel: 415-972-3360

EPA Region 10 (AK, ID, OR, WA) Tel: 206-553-1616

vvEPA

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